Midway Subarea Planned Action

Final Environmental Impact Statement
City of Kent Comprehensive Plan Review and

Midway Subarea Planned Action Environmental Impact Statement
City of Kent, Washington

Economic & Community Development Department
September 2011
City of Kent Comprehensive Plan Review and Midway Subarea Planned Action
Environmental Impact Statement
Prepared for:
City of Kent
Economic and Community Development Department
Planning Division
400 West Gowe Street
Kent, WA 98032
Contact: Charlene Anderson
Prepared by:
710 Second Avenue, Suite 550

Seattle, WA 98104
Contact: Yonnel Gardes
206/801-2844
September 2011
This document should be cited as:
ICF International. 2011. Final Environmental Impact Statement. City of Kent Comprehensive Plan Review and Midway
Subarea Planned Action EIS. September. (ICF #00941.08.) Seattle, WA. Prepared for City of Kent, Kent, WA.
Fact Sheet
Project Title
City of Kent Comprehensive Plan Review and Midway Subarea Planned Action
Proposed Action and Alternatives

Three alternatives were analyzed in this Environmental Impact Statement (EIS): the
Proposal, the No Action Alternative, and the FEIS Review Alternative.
Proposal
The City of Kent (City) is proposing to evaluate the impacts of alternative growth
strategies at a programmatic level for the Kent Planning Area (covering the City
limits and Potential Annexation Area) that would result in capacity to accommodate
up to an additional estimated 25,773 households and 35,183 jobs between the 2006
base year and a 2031 planning horizon year, with additional growth focused in
Downtown, the Midway Subarea, and the five potential Activity Centers identified as
Benson/240th, Benson/256th, Kent-Kangley/132nd, Panther Lake, and
Meeker/Washington. Although specific Comprehensive Plan and zoning amendments
are not part of the Proposal for the Kent Planning Area, if the City later wishes to
implement a new growth scenario this would require specific policy and/or code
amendments that would include amendments to the Comprehensive Plan Land Use
Plan map and Comprehensive Plan policy text that encourages increased mixed-use
and taller building heights in the five potential Activity Centers; and Zoning Districts
map and zoning text in support of the programmatic Comprehensive Plan update,
including potential updates to the zoning districts in the potential Activity Centers.
The Proposal also adopts the Midway Subarea Plan, developed as an outgrowth of
the Envision Midway subarea planning process, and a planned action ordinance to
cover a portion of the Midway Subarea. In addition, the City is exploring different
concepts for growth elsewhere in the Kent Planning Area that could be part of future
policy discussions about its Comprehensive Plan.
Specifically, the Proposal includes adopting and incorporating the Midway Subarea
Plan into the Kent Comprehensive Plan, including amendments to the
Comprehensive Plan Land Use Plan map and text amendments to implement it,
Zoning Districts map, and zoning text amendments including design guidelines in the
Midway Subarea implementing the Midway Subarea Plan, and adoption of a planned
action ordinance for the northern portion of the Midway Subarea Plan (northern
Transit-Oriented Community [TOC]) where future growth will be focused in
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September 2011
proximity to planned high capacity transit improvements along or in the vicinity of

Pacific Highway South (State Route [SR] 99).
No Action Alternative
Under the No Action Alternative, a subarea plan would not be adopted for the
Midway Subarea, no amendments would be made to the Comprehensive Plan,
Zoning Districts map, or zoning code text in the Midway Subarea, and a planned
action ordinance would not be adopted for a portion of the Midway Subarea. In
addition, under the No Action Alternative, the Citys current Comprehensive Plan
would be retained, and growth would continue to the 2031 planning horizon without
change.
FEIS Review Alternative

The FEIS Review Alternative is the same as the Proposal for the Kent Planning Area.
However, the FEIS Review Alternative for the Midway Subarea assumes a phased
approach to the same level of future growth in the Midway Subarea. It would also
provide more specific zoning, development standards, and design guidelines to
implement the land use concept of the subarea plan.
Phasing of growth is assumed because of the economic downturn and Sound

Transits delay in providing planned light rail service to the Midway Subarea. Under
the FEIS Review Alternative, a low level of growth is assumed to continue for the
first10 years of the planning periodcompared to what is assumed for the No Action
Alternativefollowed by a higher level of growth in the second 10 yearscompared
to the growth assumed under the Proposal. Because growth is assumed to be phased
over time, the City plans to phase in its implementation of Comprehensive Plan
amendments necessary to support the higher level of growth in the subsequent
10-year period as well.
The FEIS Review Alternative differs from the Proposal for the Midway Subarea in
the following ways:
Refines the Draft Midway Subarea Plan reflecting public input and adds a figure
(Figure 6 in the draft Midway Subarea Plan) which identifies Midway Subarea
Land Use Plan Map designations. Changes to the Land Use Plan Map compared
to the Proposal include adding a small portion of area near the Midway
Highlands west of Military Road into a Transit Oriented community designation.
Changes the policy language and implementing measures that provide more
flexibility in the land uses allowed to provide a transition from existing auto-
oriented land uses located throughout the Midway Subarea to a dense pedestrian-
friendly form, particularly in the TOC areas. For example, the FEIS Review
Alternative would allow new single-story construction, rather than requiring
buildings to be a minimum of two stories in height.
Amends Midway Subarea Plan transportation policy language to assume phased
growth and identifies street improvements needed for the latter half of the
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Midway Subarea Planned Action EIS
Fact Sheet
planning period, identifies a city-wide transportation analysis and funding

structure, and incorporates them into the Citys 2014 Comprehensive Plan update
(see Policy MT-4.4). Until such a time as these improvements are added to the
Citys Comprehensive Plan Transportation Element and the Citys Transportation
Master Plan, the No Action Alternative level of growth is assumed in the
Midway Subarea.
Adds additional goal and policy language that addresses transportation analysis
findings, including adding parallel northsouth transportation routes that serve as
an alternative to SR 99, accounting for transportation system management (TSM)
techniques, as well as adding language on coordinating with the City of Des
Moines and Washington State Department of Transportation (WSDOT) on a
local connection at the I-5/SR 509 interchange, as identified in the DEIS (new
policy MT-1.4).
Divides the Midway Subarea into implementing zones. Zones are mapped in a
manner in which a new Midway Subarea zone (Midway Transit Community 1, or
MTC-1) with a lower maximum height (five stories or 55 feet) is applied to the
entire MTC-1 zone. In addition, the MTC-1 zone would provide further height
restrictions of 35 feet in height within 20 feet of a residential district, and 45 feet
in height within 40 feet of a residential district, for example adjacent to lower
intensity residential districts located further to the west, residential districts east
of the southern TOC area, and at two locations abutting the Mobile Home Park
(MHP) residential district. Other implementing zones (Midway Transit
Community-2 [MTC-2], and Midway Commercial/Residential [MCR]), with
maximum heights of 200 feet or 16 stories are located farther east in the northern
Midway TOC.
Does not include minimum building heights or maximum parking standards
though parking provisions are addressed through design guidelines.
Overall, the FEIS Review Alternative for the Midway Subarea Plan assumes the
same level of growth as the Proposal, but phases it, and refines the approach to
building heights through the implementing zones, particularly MTC-1.
Location
The Kent Planning Area consists of the existing City limits as well as the Citys
Potential Annexation Area. This area is located south of the cities of Tukwila and
Renton, west of the City of Covington, north of the cities of Auburn and Federal
Way, and east of the cities of Des Moines, and SeaTac.
The Midway Subarea is defined as an area located on the western edge of the City
limits, generally centered on SR 99 between S 272nd Street on the south and the
Kent-Des Moines Road (SR 516) on the north. The western limit of the Midway
Subarea is the City limits, and the eastern edge extends east of Military Road to the
edge of the ridge to include the Kent Highlands and south of SR 516 to include a
cluster of commercially zoned properties.
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September 2011
Proponent
The City of Kent
Lead Agency
The City of Kent
Responsible Official
Charlene Anderson, Planning Manager
City of Kent
Economic and Community Development Department
Planning Division
400 West Gowe Street
Kent, Washington 98032
(253) 856-5454
canderson@ci.kent.wa.us
Contact Person
See Responsible Official.
Required Approvals
Review and recommendation by the Land Use and Planning Board followed by
approval by the Kent City Council of the Comprehensive Plan Land Use Plan
map and text amendments associated with the Comprehensive Plan Update, and
approval of Zoning Districts map and zoning text amendments associated with
the Comprehensive Plan Update.
Land Use and Planning Board review and recommendation followed by approval
by the Kent City Council of the Midway Subarea Plan, and associated
Comprehensive Plan Land Use Plan map and text amendments related to the
Midway Subarea, associated Zoning Districts map and zoning text amendments
including design guidelines related to the Midway Subarea, and a planned action
ordinance for a portion of the Midway Subarea called the Midway Planned
Action Area (northern TOC).
Development and building permit review by the City of any future development
proposals.
In addition, the State of Washington Department of Commerce reviews proposed
Comprehensive Plan and development regulation amendments during a 60-day
review period prior to adoption. The Puget Sound Regional Council reviews
comprehensive plans and in particular transportation element amendments for
consistency with regional plans.
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Fact Sheet
EIS Authors and Principal Contributors

The EIS has been prepared under the direction of the City of Kent Planning Division
staff.
Principal Authors
ICF International
710 Second Avenue, Suite 550
Seattle, WA 98104
(206) 801-2800
(EIS management; Natural Environment; Air Quality; Land Use and Plans and
Policies; Aesthetics; Public Services and Utilities; and Noise)
Contributing Authors
Fehr and Peers
Safeco Plaza
1001 4th Avenue, Suite 4120
Seattle, WA 98154-1155
(206) 576-4220
(Transportation)
Weinman Consulting, LLC

9350 SE 68th Street
Mercer Island, WA 98040
(206) 295-0783
(Planned Action Ordinance)
Public Comment
The DEIS was issued on October 22, 2010. A public comment period was held
between October 22 and November 23, 2010, during which time written comments
on the DEIS were invited. A public hearing regarding the DEIS was held on
December 6, 2010 1, for interested parties.
Date of DEIS Issuance

October 22, 2010
1 The City originally scheduled and advertised this public hearing for Monday, November 22, 2010, during the
official DEIS comment period. However, the public hearing was canceled because of heavy snow and the resulting
hazardous traveling conditions. The City rescheduled the public hearing for December 6, 2010, and allowed public
comment on the DEIS to be taken at that time because the original public hearing included comment on the DEIS
on its agenda.
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September 2011
Date of Implementation
Expected adoption by the Kent City Council of the Midway Subarea Plan,
Comprehensive Plan Land Use Plan map and text amendments in the Midway
Subarea and Zoning Districts map and zoning text amendments in the Midway
Subarea implementing the Midway Subarea Plan is Fourth Quarter, 2011.
Previous Environmental Documents

A list of previous environmental documents related to the City of Kent
Comprehensive Plan amendments since 2004 is provided below:
2004 Comprehensive Plan Update, July 20, 2004
Rezones to Implement 2004 Comprehensive Plan Update, November 2, 2004
2004 Annual Amendment to Comprehensive Plan Capital Facilities Element and
adoption of School District Capital Facilities Plans, December 14, 2004
Downtown Strategic Action Plan, April 19, 2005
2004 Annual Comprehensive Plan land use map and zoning amendments, April
19, 2005
Urban Density Study, November 15, 2005
2005 Annual Docket of Comprehensive Plan Updates, April 4, 2006
Muth Amendment, November 7, 2006
Annual Amendment to Comprehensive Plan Capital Facilities Element and
Amendment to Comprehensive Plan and zoning designations Citywide relating to
publicly owned property for parks and open space, June 5, 2007
Reconciling Single-Family Residential (SFR) Designations Citywide including
considering Lake Meridian Subbasin designations, June 5, 2007
Draft SEIS for Kent Events Center (approve special use combining district for
Kent Events Center), February 2007
Final SEIS for Kent Events Center (approve special use combining district for
Kent Events Center), May 2007
Adoption of Transportation Master Plan and Comprehensive Plan Transportation
Element, June 17, 2008
2008 Amendment to Comprehensive Plan adopting 2008 Water System Plan and
2008 Drainage Master Plan and incorporating them into Comprehensive Plan
Capital Facilities Element, September 2, 2008
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Fact Sheet

Approval of updated City of Kent Shoreline Master Program including goals and
policies as an element of the Citys Comprehensive Plan, September 15, 2009
2008 Annual Docket Amendment to Capital Facilities and Park and Open
Space Elements adopting the Park and Open Space Plan, inventory of streets and
bridges, and reference to 2008 Transportation Master Plan, May 4, 2010.
adoption of School District Capital Facilities Plans, December 14, 2010.
2010 Annual Docket Amendment to Comprehensive Plan Land Use Plan Map
for Kentara Short Plat Lot 21, April 19, 2011.
Where appropriate, prior environmental documentation was considered in the
preparation of this EIS.
Location of Background Information

City of Kent Economic & Community Development Department, Planning Division.
See Contact Person listed above.
FEIS Purchase Price

Copies of the FEIS can be obtained from the City of Kent Economic & Community
Development Department, Planning Division (see Contact Person) for the cost of
production.
The document is also posted on the Citys website at <http://www.ci.kent.wa.us/> or

<http://www.kentwa.gov/> and available as a reference at the Kent Public Library
located at 212 2nd Avenue N, Kent, Washington 98032.
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Table of Contents
Chapter 1. Summary............................................................. 1-1
1.1. Proposed Action and Location ............................................ 1-1
1.1.1. The Proposal............................................................ 1-1
1.1.2. Proposal Objectives ................................................. 1-2
1.1.3. Location ................................................................... 1-2
1.1.4. Description of Alternatives ....................................... 1-3
1.2. SEPA Procedures and Public Involvement ......................... 1-5
1.2.1. Purpose of the EIS ................................................... 1-5
1.2.2. Level of Analysis ...................................................... 1-5
1.2.3. EIS Scoping and Public Comment ........................... 1-7
1.3. Summary of Impacts ........................................................... 1-7
1.3.1. Impacts Common to All Alternatives ........................ 1-7
1.3.2. Summary of Impacts by Alternative........................ 1-18
1.4. Mitigation Measures .......................................................... 1-72
1.5. Significant Unavoidable Adverse Impacts ......................... 1-81
1.5.1. Natural Environment .............................................. 1-81
1.5.2. Air Quality .............................................................. 1-81
1.5.3. Land Use/Plans and Policies.................................. 1-81
1.5.4. Aesthetics .............................................................. 1-82
1.5.5. Transportation ........................................................ 1-83
1.5.6. Public Services and Utilities ................................... 1-84
1.5.7. Noise ...................................................................... 1-84
Chapter 2. Description of Alternatives ............................... 2-1

2.1. Introduction ......................................................................... 2-1
2.1.1. Proposal Overview ................................................... 2-1
2.1.2. Proposal Objectives ................................................. 2-2
2.2. Planning Process ................................................................ 2-2
2.2.1. Growth Management Act ......................................... 2-2
2.2.2. City of Kent Comprehensive Plan ............................ 2-3
2.2.3. Midway Subarea Plan .............................................. 2-3
2.2.4. Development Regulations ........................................ 2-4
2.3. Planned Action .................................................................... 2-8
2.3.1. Planned Action Overview ......................................... 2-8
2.3.2. Planned Action Environmental Impact Statement .... 2-8
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September 2011
2.3.3. Planned Action Ordinance ....................................... 2-8

2.4. Environmental Review ........................................................ 2-9
2.4.1. Prior Environmental Review ..................................... 2-9
2.4.2. Level of Analysis .................................................... 2-11
2.4.3. Scope of Review .................................................... 2-12
2.4.4. Public Comment ..................................................... 2-13
2.4.5. Overview ................................................................ 2-14
2.4.6. The Proposal.......................................................... 2-15
2.4.7. No Action Alternative.............................................. 2-32
2.4.8. FEIS Review Alternative ........................................ 2-33
2.4.9. Alternatives Comparison ........................................ 2-35
2.5. Benefits and Disadvantages of Delaying the Proposal...... 2-40
2.6. Alternatives Previously Considered and Future
Alternatives ....................................................................... 2-42
Chapter 3. Environmental Analysis .................................... 3-1

3.1. Kent Planning Area ............................................................. 3-1
3.2. Midway Subarea ................................................................. 3-1
3.2.1. Natural Environment ................................................ 3-2
3.2.2. Air Quality ................................................................ 3-2
3.2.3. Land Use Patterns and Plans and Policies .............. 3-3
3.2.4. Aesthetics ................................................................ 3-5
3.2.5. Transportation .......................................................... 3-8
3.2.6. Public Services and Utilities ..................................... 3-8
3.2.7. Noise ........................................................................ 3-8
Chapter 4. Clarifications and Corrections ......................... 4-1

4.1. Natural Environment ........................................................... 4-1
4.1.1. Revisions to DEIS Page 3.1-19 ................................ 4-1
4.2. Air Quality ........................................................................... 4-3
4.2.1. Revisions to DEIS Table 3.2-9 ................................. 4-3
4.3. Land Use Patterns and Plans and Policies ......................... 4-5
4.3.2. Revisions to DEIS Page 3.3-61 and 3.3-62 .............. 4-6
4.4. Aesthetics ........................................................................... 4-6
4.4.1. Revision to DEIS Page 3.4-21.................................. 4-6
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Contents

4.4.4. Revision to DEIS Page 3.4-31.................................. 4-7
4.4.9. Revisions to DEIS Page 3.4-34 .............................. 4-10
4.4.10. Revisions to DEIS Page 3.4-34 ........................... 4-10
4.4.12. Revisions to DEIS Page 3.4-40 to 3.4-41 ............ 4-11
4.5. Transportation ................................................................... 4-12
4.5.1. Revisions to DEIS Table 3.5-3 ............................... 4-12
4.6. Public Services and Utilities .............................................. 4-20
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September 2011

Chapter 5. Responses to Comments .................................... 5-1

5.1. Written Comments .............................................................. 5-1
5.1.1. Responses to Comments ......................................... 5-2
5.2. Public Hearing Comments .................................................. 5-8
5.2.1. Responses to Public Hearing Comments ............... 5-10
5.3. Marked Comment Letters.................................................. 5-11
Chapter 6. Distribution List ................................................. 6-1

6.1. Federal Agencies ................................................................ 6-1
6.2. Tribal, State and Regional Agencies ................................... 6-1
6.3. Cities and Neighboring Planning Departments ................... 6-2
6.4. Public Services, Transportation, and Utilities ...................... 6-3
6.5. Individuals and Companies ................................................. 6-3
6.6. City Officials, Commissions, and Departments ................... 6-7
Appendices
Appendix A. Planned Action Ordinance
Appendix B. Draft Midway Subarea Plan
Appendix C. Draft Midway Design Guidelines
Appendix D. Draft Midway Zoning Map
Appendix E. Draft Midway Zoning and Development Regulation Amendments
Appendix F. Traffic Volumes for SR 99 Intersections within the Midway Subarea
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Contents
Tables
Table 1-1. Summary Comparison of Impacts Unique to Each Alternative for the Kent
Planning Area .................................................................................................. 1-19
Table 1-2. Summary Comparison of Impacts Unique to Each Alternative for Midway
Subarea ........................................................................................................... 1-42
Table 1-3. Summary of Mitigation Measures for the Kent Planning Area ......................... 1-72
Table 1-4. Summary of Mitigation Measures for Midway Subarea ................................... 1-76
Table 2-1. City of Kent Comprehensive Plan EIS Growth Alternatives Comparison ........ 2-35
Table 2-2. City of Kent Comprehensive Plan EIS Alternatives Comparison ..................... 2-36
Table 2-3. Alternatives Comparison by Centers and Corridors ........................................ 2-37
Table 2-4. Midway Subarea Growth Alternatives Comparison ......................................... 2-38
Table 2-5. Midway Subarea Alternatives Comparison ...................................................... 2-38
Table 5-1. Public Comment Letters Received .................................................................... 5-1
Table 5-2. Responses to Letter Comments ........................................................................ 5-2
Table 5-3. Public Hearing Comments Received ................................................................. 5-8
Table 5-4. Responses to Public Hearing Comments ........................................................ 5-10
Figures
Figure 2-1. Kent Planning Area............................................................................................ 2-5
Figure 2-2. Midway Subarea and Planned Action Area ....................................................... 2-7
Figure 2-3. Centers and Corridors ..................................................................................... 2-17
Figure 2-4. Midway Subarea under the Proposal .............................................................. 2-19
Figure 2-5. Comparison of Total Households2006 and 2031 Alternatives ..................... 2-20
Figure 2-6. Comparison of Household Growth Share by Alternative (20062031) ............ 2-20
Figure 2-7. Total Jobs2006 and 2031 Alternatives ......................................................... 2-21
Figure 2-8. Comparison of Job Growth Share by Alternative (20062031) ....................... 2-22
Figure 2-9. Downtown Growth in Households and Jobs (20062031)............................... 2-23
Figure 2-10. Activity Centers Growth in Households and Jobs (20062031) ...................... 2-23
Figure 2-11. Midway Subarea Growth (20062031) ............................................................ 2-29
Figure 2-12. Planned Action Area Development Process .................................................... 2-31
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September 2011
Acronyms
BMPs best management practices
CB Community Business
CC Community Commercial
CC-MU Community Commercial-Mixed Use
CFAI Commission on Fire Accreditation International
City City of Kent
CM-2 Commercial Manufacturing II
Comprehensive Plan City of Kent Comprehensive Plan
CPPs Countywide Planning Policies
CPTED crime prevention through environmental design
CTR Commute Trip Reduction
DEIS Draft Environmental Impact Statement
DSAP Downtown Strategic Action Plan
EIS Environmental Impact Statement
EMTs emergency medical technicians
FEIS Final Environmental Impact Statement
FHWA Federal Highway Administration
FTA Federal Transit Administration
GC General Commercial
GIS geographic information system
GMA Growth Management Act
HOV high-occupancy vehicle
I Interstate
IAFC International Association of Fire Chiefs
ICMA International Cities/Counties Management Association
LEED Leadership in Energy and Environmental Design
M-1 Industrial Park
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Contents
MCR Midway Commercial/Residential

MHP Mobile Home Park
MR-G Low Density Multifamily
MR-H High Density Multifamily
MRT-16 Townhouse/Condo
MTC-1 Midway Transit Community 1
MU Mixed Use
NRPA National Recreation and Park Association
O Office
PSCAA Puget Sound Clean Air Agency
PSRC Puget Sound Regional Council
RCW Revised Code of Washington
RFA Regional Fire Authority
SEPA State Environmental Policy Act
SFR Single-Family Residential
SR State Route
TCMS transportation concurrency management system
TMP Transportation Master Plan
TOC transit-oriented community
TOD transit-oriented development
TSM transportation system management
VMT vehicle miles traveled
WAC Washington Administrative Code
WSDOT Washington State Department of Transportation
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September 2011
Chapter 1. Summary 0B
The Draft Environmental Impact Statement (DEIS) issued on October 22, 2010,
presented a description of two alternatives and an evaluation of several environmental
elements. The Final Environmental Impact Statement (FEIS) completes the
environmental review process for the Proposal and the No Action Alternative, as well as
describes another alternative called the FEIS Review Alternative, which addresses
refinements in the Midway Subarea Plan since publication of the DEIS. Text that has
been inserted or deleted since the DEIS is shown in strikeout or underline format.
References to the FEIS are to this document whereas references to the Environmental
Impact Statement (EIS) include the DEIS and the FEIS. This chapter summarizes
significant impacts, mitigation measures, and significant unavoidable adverse impacts
evaluated in this Draft Environmental Impact Statement (DEIS) for the City of Kent
Comprehensive Plan Review and Midway Subarea Planned Action.
1.1. Proposed Action and Location

1B
ThreeTwo alternatives are analyzed in this DEIS: the Proposal, and the No Action
Alternative, and the FEIS Review Alternative.
1.1.1. The Proposal

6B
To accommodate future population and employment growth, the City of Kent (City) is
proposing the following three actions:
Kent Planning Area (the City and Potential Annexation Area). Complete a
programmatic impact evaluation for alternative growth strategies to accommodate up
to an additional estimated 25,773 households and 35,183 jobs between the 2006 base
year and a 2031 horizon year. The additional growth would be focused in
Downtown, the Midway Subarea, and five potential Activity Centers identified as
Benson/240th, Benson/256th, Kent-Kangley/132nd, Panther Lake, and
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September 2011
Meeker/Washington. Specific City of Kent Comprehensive Plan (Comprehensive

Plan) and zoning amendments are not part of the Proposal for the Kent Planning
Area. If the City later wishes to implement a growth strategy for one or more of these
areas, the following policy and code amendments would be required:
Update of the Comprehensive Plan Land Use Plan map and policy text to reflect
the strategy; and
Update of the Zoning Districts map and text to support the Comprehensive Plan
update.
Midway Subarea. Adopt and incorporate the Midway Subarea Plan into the Kent
Comprehensive Plan and adopt Zoning map and text amendments including design
guidelines to implement it.
Midway Planned Action Area (i.e., the northern Transit-Oriented Community [TOC]
within portion of the Midway Subarea). Adopt a planned action ordinance for the
northern portion of the Midway Subarea Plan located in closest to planned high
capacity transit improvements along or in the vicinity of Pacific Highway South
(State Route [SR] 99).
1.1.2. Proposal Objectives

7B
The Citys objectives for this Proposal are as follows:
Explore alternative growth concepts in the Kent Planning Area to form the basis for
future policy decisions about accommodating projected household and employment
growth through 2031 and beyond; and prepare the City for its upcoming state-
mandated Comprehensive Plan update. 1 0F
Adopt the Midway Subarea Plan to facilitate increased intensity of development with
a mix of land uses that would increase revenues, job opportunities, and housing
choices, in proximity to the SR 99 corridor where high capacity transit is planned.
Implement a planned action ordinance in the northern portion of the Midway Subarea
to increase the level of certainty about development potential in the area nearest the
future high capacity transit station. The planned action ordinance would streamline
State Environmental Policy Act (SEPA) review for future development proposals
within that area, by addressing up-front the likely environmental impacts associated
with the overall master development plan.
1.1.3. Location
8B
The Kent Planning Area consists of the existing City limits and the Citys Potential
Annexation Area. This area is located south of the cities of Tukwila and Renton, west of
the City of Covington, north of the cities of Auburn and Federal Way, and east of the
cities of Des Moines, and SeaTac.
1 RCW 36.70A.130 as amended by SSB-6611 in the 2010 Washington Legislative session establishes the deadline
for the Citys update of its Comprehensive Plan as December 1, 2014.
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Summary
The Midway Subarea is located on the western edge of the City limits, generally centered
on SR 99 between S 272nd Street on the south and the Kent-Des Moines Road (SR 516)
on the north. The western limit of the Midway Subarea is the City limits, and the eastern
edge extends east of Military Road S to the edge of the Ridge to include Kent Highlands
and south of SR 516 to include a cluster of commercially zoned properties.
1.1.4. Description of Alternatives

9B
Proposal
The City is exploring different concepts for growth in the Kent Planning Area that could
be part of future policy discussions about its Comprehensive Plan.City is proposing to
adopt the Midway Subarea Plan developed as an outgrowth of the Envision Midway
subarea planning process, and adopt a planned action ordinance to cover a portion of the
Midway Subarea. In addition, the City is proposing to adopt the Midway Subarea Plan
developed as an outgrowth of the Envision Midway subarea planning process, and adopt
a planned action ordinance to cover a portion of the Midway Subarea. City is exploring
different concepts for growth elsewhere in the Kent Planning Area that could be part of
future policy discussions about its Comprehensive Plan.
The Proposal includes adopting the Midway Subarea Plan and amending the
Comprehensive Plan Land Use Plan map, Zoning Districts Map, and zoning text
amendments in the Midway Subarea implementing the Midway Subarea Plan, and
adoption of a planned action ordinance for a portion of the Midway Subarea Plan where
future growth will be focused in proximity to planned high capacity transit improvements
along Pacific Highway South (SR 99).
The Proposal also evaluates the impacts of alternative growth strategies at a

programmatic level for the Kent Planning Area that would add capacity to accommodate
up to an additional estimated 25,773 households and 35,183 jobs between 2006 and 2031,
with additional growth focused in Downtown, the Midway Subarea, and the five Activity
Centers. Although specific Comprehensive Plan and zoning amendments are not part of
the Proposal for the Kent Planning Area (outside of the Midway Subarea), if the City
later wishes to implement a new growth scenario for these other areas, this would require
specific policy and/or code amendments that would include amendments to the
Comprehensive Plan Land Use Plan map and Comprehensive Plan policy text that
encourages increased mixed-use and taller building heights in the Activity Centers; and
amendments to the Zoning Districts map and zoning text in support of the programmatic
Comprehensive Plan update, including potential updates to the zoning districts in the
Activity Centers.
The Proposal also includes adopting the Midway Subarea Plan; amending the
Comprehensive Plan Land Use Plan map, Zoning Districts Map, and zoning text
including design guidelines in the Midway Subarea to implement the Midway Subarea
Plan; and adopting a planned action ordinance for a portion of the Midway Subarea Plan
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September 2011
where future growth will be focused in proximity to planned high capacity transit
improvements along or in the vicinity of Pacific Highway South (SR 99).
No Action Alternative
Under the No Action Alternative, a subarea plan would not be adopted for the Midway
Subarea; no amendments would be made to the Comprehensive Plan, Zoning Districts
map, or zoning code text in the Midway Subarea; and a planned action ordinance would
not be adopted for a portion of the Midway Subarea. In addition, the Citys current
Comprehensive Plan would be retained, and growth would continue to the 2031 planning
horizon without change.

The FEIS Review Alternative is the same as the Proposal for the Kent Planning Area.
However, the FEIS Review Alternative for the Midway Subarea assumes a phased
approach to the same level of future growth in the subarea. It would also provide more
specific zoning to implement the land use concept of the subarea plan.
Phasing of growth is assumed because of the economic downturn and Sound Transits
delay in providing planned light rail service to the Midway Subarea. Under the FEIS
Review Alternative, a low level of growth is assumed to continue for the first 10 years of
the planning periodcompared to what is assumed for the No Action Alternative
followed by a higher level of growth in the second 10 yearscompared to the growth
assumed under the Proposal. Because growth is assumed to be phased over time, the City
plans to phase in its implementation of Comprehensive Plan amendments necessary to
support the higher level of growth in the subsequent 10-year period as well.
The FEIS Review Alternative differs from the Proposal for the Midway Subarea in the
following ways:
(Figure 6 in the draft Midway Subarea Plan) which identifies Midway Subarea Land
Use Plan Map designations. Changes to the Land Use Plan Map compared to the
Proposal include adding a small portion of area near the Midway Highlands west of
Military Road into a TOC designation.
flexibility in the land uses allowed to provide a transition from existing auto-oriented
land uses located throughout the Midway Subarea to a dense pedestrian-friendly
form, particularly in the TOC areas. For example, the FEIS Review Alternative
would allow new single-story construction, rather than requiring buildings to be a
minimum of two stories in height.
growth and identifies street improvements needed for the latter half of the planning
period, identifies a city-wide transportation analysis and funding structure, and
incorporates them into the Citys 2014 Comprehensive Plan update (see Policy MT-
4.4). Until such a time as these improvements are added to the Citys Comprehensive
1-4
Summary
Plan Transportation Element and the Citys Transportation Master Plan, the No
Action Alternative level of growth is assumed in the Midway Subarea.
findings, including adding parallel northsouth transportation routes that serve as an
alternative to SR 99, accounting for transportation system management (TSM)
techniques, as well as adding language about coordinating with the City of Des
Moines and Washington State Department of Transportation (WSDOT) on a local
connection at the I-5/SR 509 interchange, as identified in the DEIS (new policy MT-
1.4).
MTC-1) with a lower maximum height (five stories or 55 feet) is applied to the entire
MTC-1 zone. In addition, the MTC-1 zone would provide further height restrictions
of 35 feet in height within 20 feet of a residential district, and 45 feet in height within
40 feet of a residential district, for example adjacent to lower intensity residential
districts located further to the west, residential districts east of the southern TOC
area, and at two locations abutting the Mobile Home Park (MHP) residential district.
Other implementing zones (Midway Transit Community-2 [MTC-2], and Midway
Commercial/Residential [MCR]), with maximum heights of 200 feet or 16 stories are
located farther east in the northern Midway TOC.
Does not include minimum building heights or maximum parking standards, though
parking provisions are addressed through design guidelines.
Overall, the FEIS Review Alternative for the Midway Subarea Plan assumes the same
level of growth as the Proposal, but phases the growth, and refines the approach to
1.2. SEPA Procedures and Public Involvement

2B
1.2.1. Purpose of the EIS

10B
The purpose of the environmental review in the DEIS is to provide an analysis of the
probable natural and built environment impacts of the No Action Alternative, and the
Proposal, and the FEIS Review Alternative, and identify appropriate mitigation measures.
This information is made available to City decision makers, other agencies, and the
public for 30 days (see Fact Sheet). Following the comment period, the City will prepare
a Final Environmental Impact Statement (FEIS) that will respond to comments and may
provide a Preferred Alternative.
1.2.2. Level of Analysis

1B
SEPA (Revised Code of Washington [RCW] 43.21C) requires government officials to

consider the environmental consequences of actions they are about to take and better or
less damaging ways to accomplish these proposals. The officials must consider whether
the Proposal will have a probable significant adverse environmental impact on the
1-5
September 2011
following elements of the natural and built environment: earth, water, plants and animals,
energy and natural resources, environmental health, land and shoreline use,
transportation, and public services and utilities.
This DEIS considers potential environmental impacts in the Kent Planning Area at a
programmatic level of detail, and at a more detailed level for the Midway Subarea, part of
which is being considered for a planned action ordinance.
Kent Planning Area

29B
This DEIS provides a qualitative and quantitative analysis of environmental impacts as

appropriate to the general nature of a Comprehensive Plan update. The adoption of
Comprehensive Plan or other long-range planning activities is classified by SEPA as a
nonproject (i.e., programmatic) action. A nonproject action is defined as an action that is
broader than a single site-specific project and involves decisions on policies, plans, and
programs. An EIS for a nonproject proposal does not require site-specific analyses;
instead, the EIS discusses impacts and alternatives appropriate to the scope of the
nonproject proposal and to the level of planning for the proposal (Washington
Administrative Code [WAC] 197-11-442).
The Kent Planning Area consists of the existing City limits as well as the Potential
Annexation Area. In general, environmental analysis for the Kent Planning Area has been
conducted at a cumulative planning area level. This broad review involves evaluating
alternative growth concepts, potential City-initiated changes to land use classifications,
and updates to the Citys household and employment projections extending to a 2031
planning horizon.
SEPA encourages the use of phased environmental review to focus on issues that are
ready for decision and exclude from consideration issues already decided or not yet ready
for decision-making (WAC 197-11-060(5)). Phased review is appropriate where the
sequence of a proposal is from a programmatic document, such as an EIS addressing a
comprehensive plan, to other documents that are narrower in scope, such as those
prepared for site-specific, project-level analysis. The City is using phased review in its
environmental review of the Comprehensive Plan for the Kent Planning Area with a
programmatic review of alternative growth concepts and potential plan amendments.
Examples of proposals that may require more area-specific or site-specific SEPA review
when more details are known include, but are not limited to capital improvement
projects, and private development applications.
Midway Subarea
30B
The City plans to complete a planned action ordinance to encourage redevelopment in a

portion of the Midway Subarea, particularly in proximity to a planned light rail station
which is anticipated to be located near in the vicinity of Highline Community College.
The Kent Midway Planned Action Area, where the planned action ordinance is
anticipated to apply, would consist of the northern portion of the Midway Subarea,
1-6
Summary
generally north of S 246th Street and including the Kent Highlands property and
associated smaller parcels.
Because this portion of the City is being considered for a planned action ordinance, and
to allow the City some flexibility in determining its final planned action boundaries, this
DEIS provides an area-specific discussion of the Midway Subarea under each element of
the environment that encompasses the Midway Subarea. Where appropriate, the DEIS
also identifies area-specific mitigation measures to address identified impacts. The DEIS
also establishes recommended threshold levels, where appropriate references existing or
proposed regulations, and prescribes mitigation measures for impacts to allow future
development that falls within these thresholds or complies with prescribed
regulations/mitigation to proceed with minimal future SEPA review. Please refer to
Section 2.4.6, Description of Alternatives of this EIS for an additional discussion of the
Midway Subarea.
1.2.3. EIS Scoping and Public Comment

12B
In accordance with the requirements of SEPA and GMA, the City has provided for
continuous public review and comment over the course of the planning process. The City
conducted scoping, including an opportunity for written and oral comments (see Section
2.4.3 of this EIS for additional description of the scoping process). In addition, a 33-day
comment period washas been initiated with issuance of theis DEIS, and the City will hold
held a public meeting during the public comment period to take comments. 2 1F
1.3. Summary of Impacts

3B
Section 1.3.1 describes impacts common to the threeboth alternatives studied in this
DEIS broken out by the Kent Planning Area and Midway Subarea geographic areas.
Section 1.3.2 summarizes the environmental impacts unique to each alternative with
analysis broken out by the Kent Planning Area and Midway Subarea geographic areas.
Table 1-1 addresses impacts unique to each alternative in the Kent Planning Area and
Table 1-2 addresses impacts unique to each alternative in the Midway Subarea.
1.3.1. Impacts Common to AllBoth Alternatives

13B
1.3.1.1. Natural Environment

2B
Natural environment impacts cover earth, water, and plants and animals subjects. Under
both alternatives, growth would occur and new development and redevelopment are
2 The City originally scheduled and advertised this public hearing for Monday, November 22, 2010, during the
official DEIS comment period. However, the public hearing was canceled because of heavy snow and the resulting
hazardous traveling conditions. The City rescheduled the public hearing for December 6, 2010, and allowed public
comment on the DEIS to be taken at that time because the original public hearing included comment on the DEIS
on its agenda.
1-7
September 2011
projected. New development has the potential to affect or be affected by the natural
environment in the following ways:
Kent Planning Area

31B
Earth
59B
Earth-disturbing construction could accelerate erosion, particularly in steep areas.

Converting open space or agricultural land uses to developed land uses could result
in lost soil productivity through topsoil removal, coverage by impervious surfaces,
contamination, and compaction.
Building in seismic hazard areas would put structures in those areas at an increased
risk of damage during an earthquake compared to other areas.
Limited instances in which building in landslide hazard areas occurs would be at risk
of loss or damage because of earth movement.
Water
60B
Impervious surfaces could intercept precipitation and alter the timing and volume of
discharge to groundwater and surface water.
Impervious surfaces are generally pollutant sources. Thus, roads would receive
pollutants from vehicles, and all impervious surfaces would receive airborne
pollutants.
Earth-disturbing construction could increase erosion and result in sediment discharge
to stormwater systems and/or surface waters.
Impervious surfaces could interrupt the recharging of groundwater by diverting
natural flow patterns.
Residential development is a potential source of stormwater and groundwater
pollution through pet waste, and use of yard care products including fertilizers and
toxic biocides.
Any development in floodplains would be at an increased risk of flood and could also
alter flood storage of the floodplain and affect flood elevations and duration upstream
or downstream from the development.
Plants and Animals

61B
New development that converts open space to residential and commercial uses would
generally result in a loss of habitat or habitat quality.
Changes in surface water pollutant loading and flow regime could adversely affect
fish and other aquatic organisms, either directly or through habitat alteration.
Redevelopment could affect the natural environment through the same mechanisms as
new development. However, the potential for these impacts is less, since previously
developed areas may not require new excavations and generally have lower productivity
soil, higher impervious surface area, and reduced habitat compared to undeveloped land.
1-8
Summary
Midway Subarea
32B
The Midway Subarea would be subject to increased density of development and the
associated potential impacts on the natural environment discussed previously under
Impacts Common to Both All AlternativesKent Planning Area. However, the small
wetland areas within the subarea are assumed to remain undeveloped under both all
alternatives due to mitigation requirements for impacts on wetlands. Although new
development could occur on portions of both former landfills, it is likely that large
portions of both former landfill sites would remain as passive open space under both all
alternatives.
1.3.1.2. Air Quality

23B
Kent Planning Area

3B
Development under either all alternatives could increase localized air pollutant emissions
from construction activities and commercial activity, and increase regional vehicle travel
and tailpipe emissions. See Section 3.2, Air Quality of the DEIS for more details on Air
Quality impacts.
Construction Emissions
62B
Construction emissions include dust from excavation and grading activities, diesel-
powered engine emissions from construction vehicles and equipment, odors detectable to
people in the vicinity of construction activities (such as paving operations), and increases
in general traffic-related emissions due to delays caused by construction equipment and
material hauling activity. Construction activity and equipment must comply with relevant
Puget Sound Clean Air Agency (PSCAA) regulations. However, despite compliance with
such regulations, local construction-related emissions could cause temporary, localized
impacts on air quality.
Emissions from Commercial and Industrial Operations

63B
Emissions from commercial and industrial operations could cause air pollution issues at
adjacent residential properties, unless properly controlled. However, all new commercial
and industrial facilities would be required to register pollutant-emitting equipment with
PSCAA and comply with PSCAA standards to minimize emission. Therefore, it is
unlikely that new commercial and industrial operations would cause significant air
quality issues.
Emissions from Vehicle Travel

64B
Potential air quality impacts caused by increased tailpipe emissions are divided into two
general categories: CO hot-spots caused by localized emissions at heavily congested
intersections and regional photochemical smog caused by combined emissions
throughout the Puget Sound region. With respect to localized hot-spot air quality, it is
unlikely that increased vehicle travel on existing public roads would cause significant
localized air pollutant concentrations at local intersections, forming a hot-spot. PSCAA
1-9
September 2011
has not indicated any exceedances over the past several years, and EPAs ongoing motor
vehicle regulations have provided steady decreases in tailpipe emissions from vehicles,
which possibly could more than offset the increase in vehicle traffic.
In terms of regional impacts, although population and vehicle travel in the study area
would increase under both all alternatives, the increase in tailpipe emissions would be
very small relative to the overall regional tailpipe emissions within the Puget Sound air
basin. Based on the Puget Sound Regional Councils (PSRCs) air quality conformity
analysis, forecasted regional emissions for its 2030 planning year are far below the
allowable budgets. None of the studied alternatives would cause a substantial percentage
increase in regional vehicle miles traveled (VMT) throughout the Puget Sound air basin.
Therefore, the forecasted population growth and VMT for both the Proposal and No
Action all Aalternatives would not appear to alter PSRCs conclusion that future Puget
Sound regional emissions will be less than the allowable emissions budgets mandated by
the air quality maintenance plans.
Greenhouse Gas Emissions

65B
This section compares estimated GHG emissions from the Kent Planning Area and from
the Puget Sound region. As described in Section 3.2, the Proposal/FEIS Review
Alternative would reduce regional GHG emissions compared to the No Action
Alternative. The analysis assumes a similar amount of overall new development in the
2006 to 2031 timeframe, with future increases in developed square footage in the Kent
Planning Area under the Proposal/FEIS Review Alternative balanced against
corresponding regional growth under the No Action Alternative. In addition, more of the
development under the Proposal/FEIS Review Alternative in the Kent Planning Area
would occur in the form of transit-oriented development (TOD) under the Proposal/FEIS
Review Alternative. See Section 3.2, Air Quality and Appendix D of the DEIS for more
detail on how Greenhouse GasGHG Eemissions were calculated.
Because the Proposal/FEIS Review Alternative would provide TOD in several centers
and corridors, overall GHG emissions increases under this alternative are slightly lower
than for the No Action Alternative. The overall annualized GHG emissions increases
from 2006 to 2031 are 648,101 metric tons/year under the Proposal/FEIS Review
Alternative, compared to 693,084 metric tons/year under the No Action Alternative.
Thus, the Proposal/FEIS Review Alternative represents a net reduction of 44,983 metric
tons/year of regional GHG emissions (6.5% GHG reduction compared to the No Action
Alternative).
Midway Subarea
34B
Although the Midway Subarea would result in smaller increases in population and
employment than the Kent Planning Area, impacts on air quality under both all
alternatives would be similar to those described for the Kent Planning Area above.
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Summary
1.3.1.3. Land Use Patterns/Plans and Policies

24B
Kent Planning Area

35B
Land Use Patterns

6B
Under both all alternatives the amount of single-family and multifamily residential
development increases, with more of the residential development occurring as
multifamily either as part of a mixed-use development or as a single use.
Under both all alternatives, the amount of mixed-use development within the Kent
Planning Area as a whole is anticipated to grow, as more intensive development within
Downtown and other areas with a mixed-use designation occurs. However, the intensity
of development occurring within these areas varies by alternative.
Direct, construction-related impacts associated with both all alternatives would include
dust, traffic delays, noise, and general inconvenience. Cumulative impacts would include
a reduction in vacant and redevelopable or underutilized lands over time, increased urban
activity such as traffic, noise, glare, and pedestrian activity; and loss of some natural
vegetation on currently vacant lands (to be replaced by required landscaping).
Plans and Policies

67B
Growth Management Act. The Comprehensive Plan meets the broad requirements of the
Growth Management Act (GMA). Under both all alternatives, plan policies would
continue to comply with major goals of the GMA.
Shoreline Management Act. Under both all alternatives, the City protects and allows uses
within shorelines in accordance with the Citys adopted Shoreline Management Program.
King County Countywide Planning Policies. The Comprehensive Plan, under either all
alternatives, is generally consistent with the provisions of the Countywide Planning
Policies (CPPs). Both All alternatives support the CPPs relating to land use patterns by
focusing urban levels of growth within urban areas, and critical areas by protecting those
areas. BothAll alternatives provide large increases of future growth in Downtown, and
growth in Downtown would continue to be guided by the Downtown Strategic Action
Plan (DSAP) under both all alternatives. Additionally, both all alternatives support
orderly development and provision of urban services by focusing growth as
redevelopment in urban areas with infrastructure in place, or that can be improved to
support that growth. Also, both all alternatives demonstrate consistency with
Transportation CPPs, although the alternatives vary in consistency, particularly related to
high capacity transit investments. The alternatives differ with respect to growth capacity
in relation to growth targets which is described under each alternative.
City of Kent Comprehensive Plan. Under either all alternatives, the City would maintain its
current fundamental pattern of land use designations, and would generally meet and be
consistent with the framework goals and policies of the Comprehensive Plan. Downtown
1-11
September 2011
would be an area of focused future development guided by the strategies and

recommended actions of the Downtown Strategic Action Plan under both all alternatives.
However, the extent to which the City achieves various goals and policies under each
individual element would vary based upon alternative.
The Valley Floor Industrial Area is preserved as a manufacturing and industrial center for
manufacturing and related uses under both all alternatives consistent with Goals LU-15
and LU-18 and associated policies. In addition, under both all alternatives, natural
resources are protected and enhanced for multiple benefits consistent with Land Use
Goals LU-23 and LU-26.
Midway Subarea
36B
Under both all alternatives, there would be growth in households and jobs in the Midway
Subarea, as vacant and redevelopable parcels found throughout the subarea are
developed. However the amount and type of development, as well as land use
designations applied, varies by alternative. See Table 1-2 for more impacts by alternative.
1.3.1.4. Aesthetics
25B
Kent Planning Area

37B
Under both all alternatives, the Kent Planning Area would experience increased
development to accommodate new residents and jobs. This increased development would
mostly be directed to Downtown and the Activity Centers. Channeling new development
into these areas would lead to increased density and building heights over current
conditions, as most of the Activity Centers are not developed to their maximum capacity.
The levels of increased development and corresponding impacts on aesthetic character
anticipated for each Activity Center would differ by alternative and are summarized in
Table 1-1.
Midway Subarea
38B
While the Midway Subarea would experience growth under both all alternatives, the
levels of growth projected for each alternative differ greatly, as do the built environments
that would result from these different levels of growth. Impacts specific to each
alternative are discussed in Table 1-2.
1.3.1.5. Transportation
26B
Kent Planning Area

39B
Under both all alternatives, the Kent Planning Area would experience growth in
population and employment. This development would increase vehicle, pedestrian,
bicycle, and transit demand creating additional needs for transportation facilities and
1-12
Summary
improvements. The two alternatives differ, however, regarding the scope, intensity, and
location of these improvements.
The growth assumed under both all the Proposal and the No Action Aalternatives would
result in additional traffic accessing state and regional transportation facilities.
Midway Subarea
40B
Implementation of either all alternatives would result in increased traffic volumes and
demand for transportation facilities in the Midway Subarea. These increased traffic
volumes would influence operations at the following intersections:
Kent-Des Moines Road/I-5 Southbound Ramps,

Kent-Des Moines Road/I-5 Northbound Ramps,
Kent-Des Moines Road/S Military Road, and
S 231st Street/S Military Road.
Traffic flows at these locations would be substantially influenced by WSDOTs final SR

509 connections, which are still unknown. Conceptual alternatives for the SR 509 project
are described in the I-5/SR 509 Corridor Completion and Freight Improvement Project
Traffic Operations Report (WSDOT 2008). SR 99 operates at LOS F under both all
alternatives, with the amount of delay varying by alternative. See Section 3.5,
Transportation of the DEIS for more detail.
1.3.1.6. Public Services/Utilities

27B
Kent Planning Area

41B
Under both all alternatives, the Kent Planning Area would experience growth in
households and employment through the 2031 planning horizon. This growth would
result in additional demand for City and non-City-provided services and infrastructure.
Given the long planning horizon, exact population and employment projections are
difficult to make.
Police
68B
Growth in households and employment under both all alternatives is expected to result in
increased traffic volumes, resulting in slower police response time. The degree to which
growth affects response time varies by alternative. Under both all alternatives annexation
of the Citys remaining Potential Annexation Areas would result in a slightly larger
service area for City of Kent Police, as relatively small areas currently served by the King
County Sheriffs Office are taken over by the Police Department.
The Citys second LOS standard for police is a community sense of security as derived
by public surveys. This LOS standard cannot be measured or projected into the future.
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September 2011
Fire and Emergency Medical Services

69B
Growth in households and employment under both all alternatives is expected to result in
increased traffic volumes, which may impede fire and emergency medical service
response time and reduce service capacity of existing resources. The degree to which
growth affects response time varies by alternative.
Parks, Recreation, and Community Services

70B
Increases in population and employment throughout the Kent Planning Area would result
in a need for more parks and recreation space under both all alternatives. Annexation of
the remaining Potential Annexation Areas near the edges of the Kent Planning Area
would result in a slightly larger parks and recreation service area for the Parks
Department.
Schools
71B
Growth in households under both all alternatives would result in additional students
attending the Kent, Federal Way, Auburn, and Highline school districts. Slightly more
than 300 students would attend Auburn School District based on an existing land use
application on the Verdana/Bridges property, part of the City limits located south of and
outside of the contiguous Kent Planning Area boundaries.
Water
72B
Growth under both all alternatives would result in higher demands for potable water for
the City of Kent, Soos Creek Water and Sewer District, Water District #111, and
Highline Water Districts serving the Kent Planning Area.
Sewer
73B
Growth under both all alternatives is expected to result in higher volumes of sewage and
sewage treatment needs for the City of Kent, Soos Creek Water and Sewer District,
Midway Sewer District, and Lakehaven Utility District serving the Kent Planning Area.
Stormwater
74B
Growth anticipated in the Kent Planning Area under both all alternatives is expected to
increase impervious surface areas throughout the Kent Planning Area, and thus the need
for development and installation of stormwater conveyance and storage facilities,
consistent with the Citys stormwater code. Under both all alternatives annexation of the
Citys remaining Potential Annexation Areas would result in a slightly larger service area
for City of Kent Stormwater Utility as these relatively small areas currently served by
King County would be transferred to the City.
Solid Waste
75B
Under both all alternatives, growth in population and employment would result in
increased solid waste generation, including the generation of recyclables and the
percentage of solid waste that is recycled is expected to increase.
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Summary
Midway Subarea
42B
Under both all alternatives, the Midway Subarea would experience growth in households
and employment through the 2031 planning horizon. This growth would result in
additional demand for City and non-City-provided services and infrastructure.
Police
76B
Growth in the Midway Subarea under both all alternatives would cause an increase in
congestion, which may cause an increase in response time for police services.
Under both all alternatives, the Midway Subareas irregular boundary with Des Moines
would require the City to maintain some type of mutual aid agreement with neighboring
jurisdictions to ensure timely response to calls for police service in the Midway Subarea.

7B
Growth in the Midway Subarea under both all alternatives would cause an increase in
congestion which willmay cause an increase in response time for fire and emergency
medical services and a decrease in service capacity in the Midway Subarea. Kent Fire
Department Regional Fire Authority (RFA) would need to maintain and improve existing
service to the Midway Subarea to minimize impacts on service capacity and established
levels of service.
Under both alternatives, the Midway Subareas irregular boundary with Des Moines
would require the City to maintain some type of mutual aid agreement with neighboring
jurisdictions to ensure timely response to calls for fire and emergency medical service
delivery in the Midway Subarea.

78B
Under both all alternatives, the Midway Subarea and the larger Kent West Hill area
would experience a deficit of parks and recreation space.
Schools
79B
Under both all alternatives, Midway Subarea population growth would cause an increase
in student enrollment for the Kent, Federal Way and Highline school districts.
Water
80B
Growth under both all alternatives is expected to result in higher demands for potable
water from the Highline Water District serving the Midway Subarea. The Highline Water
District would need to maintain and improve existing collection, storage, and distribution
systems, and extend infrastructure as required by the districts service area agreement
throughout the planning period.
Sewer
81B
Growth under both all alternatives is expected to result in higher volumes of sewage and
sewage treatment needs for the City and Midway Sewer District serving the Midway
Subarea.
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September 2011
Stormwater
82B
Growth anticipated in the Midway Subarea under both all alternatives is expected to
result in increases in impervious surfaces throughout the Midway Subarea, and thus result
in the need for development and installation of stormwater conveyance and storage
facilities, consistent with City stormwater code.
Solid Waste
83B
Under both all alternatives, growth in the population and employment in the Midway
Subarea would increase solid waste generation, including the generation of recyclables
and percentage of solid waste that is recycled.
1.3.1.7. Noise 28B
Kent Planning Area

43B
Under both all alternatives, anticipated growth in population, employment, and traffic
would increase noise generated by construction activities, commercial facilities, and
traffic in the Kent Planning Area.
Construction Noise
84B
Development in the Kent Planning Area would require demolition and construction
activity, which would temporarily increase noise levels at residential housing units close
to development sites. Temporary daytime construction activity is exempt from the City
noise ordinance limits. This type of activity could cause annoyance and speech
interference at outdoor locations adjacent to the construction sites, and could cause
discernible noise (for several blocks away from the development site). Nighttime
construction activity, if required at all, is not exempt from the Citys noise ordinance, and
would be required to comply with the nighttime limits specified by the City noise
ordinance (see Section 3.7, Noise of the DEIS).
Operational Impacts and Traffic Noise

85B
Land use development would mostly be concentrated in the Citys identified centers and
corridors and would consist of a mix of residential housing and retail, office, and
commercial buildings. It is likely that new commercial development would occur near
either current or future residential housing. Unless properly controlled, mechanical
equipment (e.g., rooftop air conditioning units) and trucks at loading docks of office and
retail buildings could cause ambient noise levels at nearby residential housing units to
exceed the City noise ordinance limits.
Noise from Increased Traffic

86B
For most residents adjacent to roadways, increased traffic would result in the greatest
increase in ambient noise levels, caused by moving traffic, vehicles idling at
intersections, and transit vehicles at new bus stops.
1-16
Summary
Increased population and development could lead to increases in traffic volumes along
roadways; increases in traffic volumes and speeds resulting from improvements to
existing roadways; and widening of existing roadways, resulting in noise impacts on
homes located near the roadways. Construction of new roadways through lightly
development developed land and construction of new homes close to existing highways
or arterials with high traffic volumes and high speed limits would also cause noise
impacts. The magnitude of the traffic noise impact near any given roadway would depend
on the traffic volume, traffic speed, and number of lanes.
For construction of new roads and widening of existing roads, all residences subjected to
traffic noise levels exceeding the Federal Highway Administration (FHWA) standards
would be considered affected. If the City used state or federal funds to construct any
roadway improvements, then it would be required to consider traffic noise abatement
measures and provide noise abatement if it were shown to be acoustically feasible and
constructible at a reasonable cost. However, if other roadway improvements were
constructed using only local funding, then the City would not be required to consider
noise abatement.
Midway Subarea
4B
Noise impacts caused by increased construction activities, commercial facilities, and

traffic in the Midway Subarea would be similar to those described in detail under the
Impacts Common to Both All Alternatives section above for the Kent Planning Area.
Under both all alternatives, the proposed mixed-used residents and existing homes
adjacent to SR 99 and the future light rail station could be affected by the noise generated
from increased traffic, and buses, and the future light rail. However, the extent of
potential impacts varies by alternative.
Noise from Increased Traffic on SR 99

87B
Based on the analysis found in Section 3.7, Noise of the DEIS modeled peak-hour
exterior noise levels for both all alternatives would be high enough to interfere with
normal speech at outdoor use areas (e.g., exterior balconies) and cause excessive indoor
noise levels for buildings adjacent to SR 99. Although traffic noise is exempt from the
City noise ordinance, based on site-specific considerations, the City may at its discretion,
require new residential development to install triple-pane glass windows or other building
insulation measures based on the Citys adoption of the State Energy Code
(KCC 14.01.010). This may change if the City uses WSDOT funding for future roadway
widening on SR 99, because WSDOTs 66-dBA impact criterion applies to exterior noise
levels, regardless of the Citys acoustical building code requirements.
Instantaneous Noise at Residences Adjacent to Bus Stops

8B
Noise generated by the increased buses anticipated as part of King County Metros
RapidRide program along SR 99 is not expected to be noticeable because there are no
known noise sensitive receivers in the immediate project area and the ambient noise level
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September 2011
along the corridor is high. However, future light rail service and the proposed growth in
the area may result in increased demand for bus service in the Midway Subarea.
Increased bus service in the subarea could cause additional noise from increased bus
traffic at existing and new bus stops along SR 99.
Residences adjacent to a bus stop could be affected by noise from accelerating buses
leaving the area. Based on studies that compare noise from conventional diesel buses and
diesel-electric hybrid buses (Ross and Staiano 2007), hybrid buses are not significantly
quieter than the conventional buses in the idle and acceleration conditions. In the future,
proposed land use on SR 99 would mostly be a mix of multifamily residential housing
and retail, office, and commercial buildings, which could be constructed adjacent to the
sidewalk with a shorter setback to the roadway. Buses decelerating, accelerating, and
idling at bus stops along SR 99 would increase ambient noise and could impact future
residences immediately adjacent to these bus stops.
Noise from Potential Light Rail Station

89B
Sound Transit is proposing a new light rail service in the Midway Subarea with a light
rail station in the vicinity of Highline Community College. Under both all alternatives,
trains decelerating and accelerating at the new light rail station would increase ambient
noise and could affect existing and future residences adjacent to the station and rail track.
1.3.2. Summary of Impacts by Alternative

14B
This section summarizes impacts by alternative broken out by the Kent Planning Area
(Table 1-1) geography, and the Midway Subarea (Table 1-2) geography.
Each Ttable 1-1 summarizes unique impacts of each alternative by environmental topic.
The discussion is intentionally brief, and the reader is encouraged to read the full
discussion of impacts in Chapter 3, Affected Environment, Significant Impacts, and
Mitigation Measures of the DEIS in the context of the affected environment and impact
analysis. Mitigation measures would be applied as noted in Section 1.4 above and
Chapter 3 of the DEIS.
1-18
Summary
Table 1-1. Summary Comparison of Impacts Unique to Each Alternative for the Kent Planning Area
Alternatives
Topics Proposal/FEIS Review Alternative 3 2F No Action Alternative
3.1 Natural Environment With increased development throughout the Kent Planning Under this alternative, the City would maintain the existing
Area there would be an incremental increase in Natural comprehensive plan and associated development regulations.
Environment Impacts Common to All Alternatives described Without additional incentives for redevelopment of centers and
above. However, because the ProposalProposal/FEIS corridors, new development and associated impacts (see
Review Alternative would focus growth within these centers Impacts Common to BothAll Alternatives) may expand into
and corridors, there would likely be a decreased level of the previously undeveloped areas elsewhere in the Kent Planning
impacts for the remainder of the Kent Planning Area. Area at a slightly higher rate than under the
Downtown/Activity Centers ProposalProposal/FEIS Review Alternative.
Concentrating growth in Downtown and the activity centers Downtown/Activity Centers
would reduce the intensity of growth in other, less developed Without incentives for redevelopment of Downtown and the
areas, where the majority of fish and wildlife habitat exists. Activity Centers, few changes would be expected in the highly
Because Downtown and the Activity Centers are nearly fully developed Downtown and Activity Centers beyond the No
developed, impacts would be almost entirely associated with Action Alternative. These areas would be essentially
redevelopment. Since existing impervious surface area (e.g., unchanged regarding natural resources.
buildings, parking, roads, and sidewalks) in these areas
exceeds the existing site coverage standards (i.e., area
covered by buildings or structures), redevelopment would
result in little or no additional impervious surfaces or
stormwater volume. Some excavation for construction would
occur, but would not result in a significant loss of vegetation
or soil productivity.
Because Downtown and the Activity Centers are nearly fully
developed, there would be little or no loss of habitat for plants
and animals associated with the ProposalProposal/FEIS
Review Alternative, and little, if any, change in precipitation
runoff characteristics in these areas.
The ProposalProposal/FEIS Review Alternative avoids
impacts on most categories of environmentally sensitive
areas by focusing growth in already developed areas.
However, the Downtown and Meeker/Washington Activity
Center are both located entirely within a seismic hazard area,
and portions of these areas have been designated as 100-
year floodplain. Structures in Downtown would be subject to
an increased risk of soil liquefaction during an earthquake.
3 The impacts of the FEIS Review Alternative are the same as the Proposal for the Kent Planning Area because the same level of overall household and employment growth is anticipated as under
the Proposal, and growth would be concentrated in the same centers and corridors as described under the Proposal.
1-19
September 2011
Alternatives

Those portions of Downtown and the Meeker/Washington
Activity Center that are in the 100-year floodplain would also
be at risk of flooding during a major flood event.
3.2 Air Quality The Kent Planning Area is expected to experience greater Under this alternative, the Kent Planning Area would
population and employment growth than under the No Action experience a lower amount of growth than anticipated under
Alternative, especially in the corridors and centers. the ProposalProposal/FEIS Review Alternative. Development
Development under this alternative would result in a greater under this alternative would still lead to increases in population
increase in localized air pollutant emissions from construction and employment throughout the Kent Planning Area, and could
activities and commercial activities and regional tailpipe increase localized air pollutant emissions from construction
emissions from vehicle travel described under Impacts activities and commercial activities, and increase regional
Common to Both All Alternatives. vehicle travel and tailpipe emissions. Therefore, the air quality
Air quality impacts would not be significant due to compliance impacts under this alternative would be the same as those
with PSCAA regulations relating to fugitive dust control and impacts described under Impacts Common to Both All
requirements for emissions control and permitting. Alternatives.
Localized impacts caused by traffic emissions at congested Downtown and Activity Centers
intersections would likely be insignificant because of steady Impacts on air quality would be the same for both the centers
improvement in vehicle emissions for new cars. Federal- or and corridors as for the remainder of the Kent Planning Area
state-funded projects must conduct CO hot-spot analysis. under this alternative.
Regional air quality impacts caused by population growth and
transportation emissions in the Kent Planning Area would not
be significant.
Forecasted population and VMT for the
ProposalProposal/FEIS Review Alternative are slightly higher
than the forecasted values for the No Action Alternative.
Therefore, it is likely the air pollutant emissions in the Kent
Planning Area would be higher under the
ProposalProposal/FEIS Review Alternative than under the No
Action Alternative. Analysis in Section 3.2, Air Quality of the
DEIS concludes that future Kent Planning Area emissions
from residential areas, commercial activity, and motor
vehicles would not cause significant regional air quality
impacts.
Downtown and Activity Centers
Under the ProposalProposal/FEIS Review Alternative, future
TOD would be concentrated in centers and corridors.
Therefore, net reductions in GHG emissions within the overall
Kent Planning Area would mostly be attributed to TOD in the
centers and corridors. Otherwise impacts on air quality under
the ProposalProposal/FEIS Review Alternative would be the
same for both the centers and corridors as the remainder of
1-20
Summary
Alternatives

the Kent Planning Area.
3.3 Land Use/Plans and Policies Land Use Patterns Land Use Patterns
Under the ProposalProposal/FEIS Review Alternative, a This alternative would continue the land use development
larger amount of the Citys residences would be multifamily trend of the existing Comprehensive Plan. Changes to land
compared to both base year and the No Action Alternative. use patterns occurring over the planning period would result in
New multifamily development, under the more intensive, mixed-use development compared to the base
ProposalProposal/FEIS Review Alternative would be year conditions. However, land use patterns would be less
concentrated in mixed-use, pedestrian-friendly nodes intensive and include less mixed-use development than the
throughout the Kent Planning Area. The majority of new ProposalProposal/FEIS Review Alternative.
multifamily development within the Kent Planning Area would Overall, more development under the No Action Alternative
be located in the Citys centers and corridors. would occur as single-use commercial or residential
Job growth under the ProposalProposal/FEIS Review development, resulting in less development being
Alternative would also be concentrated in the proposed accommodated in centers and corridors, compared to the
centers and corridors to a greater extent than found under the ProposalProposal/FEIS Review Alternative. This alternative
No Action Alternative. Downtown would include the greatest would provide about 20% of the additional housing that could
increase in jobs compared to the base year, and the second be accommodated under the ProposalProposal/FEIS Review
largest increase in jobs compared to the No Action Alternative. Under this alternative, a larger percentage of new
Alternative. Most of the Activity Centers would see an housing would be single-family households constructed
increase in jobs compared to the No Action Alternative. outside of the Activity Centers, than under the
However, both the Benson/SE 256th and Panther Lake ProposalProposal/FEIS Review Alternative. Less multifamily
Activity Centers would experience a slightly smaller amount development would occur in Activity Centers under this
of job growth, as less development occurring in those areas alternative.
would be commercial-only development and a larger Overall job growth in the Kent Planning Area would be less
percentage would be mixed-use development. under this alternative compared to the ProposalProposal/FEIS
Changes anticipated in the ProposalProposal/FEIS Review Review Alternative. A higher percentage of the job growth
Alternative would allow the City to preserve designated under this alternative would occur in areas outside of the
single-family and industrial areas for their respective centers and corridors, compared to the ProposalProposal/FEIS
purposes, while concentrating additional commercial, office, Review Alternative.
and residential growth above that found in the No Action
Alternative as more intensive mixed-use development within
corridors and centers. There would be a greater amount of Downtown and Activity Centers
new single-family households located outside of the corridors Housing in Downtown would increase by 56% compared to the
and centers under the ProposalProposal/FEIS Review base year, but would include more than 2,400 fewer
Alternative compared to the No Action Alternative. However, households than under the ProposalProposal/FEIS Review
residential development outside of the corridors and centers Alternative. Activity Centers would all experience increases in
represents a smaller percentage of new housing households compared to the base year, but smaller increases
development under the ProposalProposal/FEIS Review compared to the ProposalProposal/FEIS Review Alternative.
Alternative, compared to the No Action Alternative. Residential growth would occur in less intensive development
patterns compared to the ProposalProposal/FEIS Review
Alternative.
Downtown and Activity Centers
The majority of new job growth within centers and corridors
1-21
September 2011
Alternatives

Future development in the Activity Centers would generally would occur in Downtown, which would experience almost
consist of taller buildings and a higher percentage of site twice the new job growth of the five Activity Centers under this
coverage in comparison to the base year and the No Action alternative. However, without implementation of focused
Alternative. Under the ProposalProposal/FEIS Review economic development strategies anticipated in the
Alternative, Activity Centers would experience development ProposalProposal/FEIS Review Alternative, Downtown would
of taller buildings, and Downtown would have a larger experience less than half of the increase in jobs compared to
number of multistory buildings than what currently exists. In the ProposalProposal/FEIS Review Alternative.
particular, the Benson/SE 240th Activity Center would Under this alternative, total job growth in Activity Centers
experience the most significant change in height compared to would result in fewer jobs than anticipated under the
the No Action Alternative as building heights would increase ProposalProposal/FEIS Review Alternative. However, two of
from three to four stories, with a maximum of up to 10 stories. the Activity Centers (Benson/256th and Panther Lake) would
The Benson/SE 256th and Kent-Kangley/132nd Activity experience slightly greater job growth under this alternative
Centers would also see increases in height. Allowed site compared to the ProposalProposal/FEIS Review Alternative.
coverage in all five Activity Centers is anticipated to increase
from 30% to 65% range currently allowed to something in the Building height and site coverage allowances would remain the
range of 75% to 100%, reflecting more urban standards same as under base year conditions in Downtown, and the
necessary for mixed-use development. Activity Centers in this alternative. However, development
anticipated under this alternative would generally increase
Downtown would continue with similar building heights and building heights to taller buildings meeting the existing zoning
site coverage compared to the No Action Alternative, though regulations for maximum building heights. Site coverage within
additional development would be anticipated under the the Activity Centers would remain lower than the
ProposalProposal/FEIS Review Alternative in comparison to ProposalProposal/FEIS Review Alternative under this
the No Action Alternative as a result of focused alternative. As a result of lower heights and smaller site
implementation of Downtown economic development coverage allowances, development occurring in Activity
strategies. Centers would tend to be lower scale, less intensive, and more
auto-oriented than under the ProposalProposal/FEIS Review
Alternative.
Plans and Policies Plans and Policies

Growth Management Act. The ProposalProposal/FEIS Growth Management Act. The No Action Alternative would
Review Alternative for the Kent Planning Area is consistent be generally consistent with the GMA. However, this
with the GMA. This alternative ProposalProposal/FEIS alternative would only address growth to the 2022 planning
Review Alternative is particularly consistent with goals related horizon. The City would have until 2014 to complete a
to focusing growth in urban areas with adequate services, Comprehensive Plan update to address the new growth
encouraging economic development, and provision of targets in its goals and policies.
efficient multimodal transportation systems. It would extend King County Countywide Planning Policies. This alternative
the Comprehensive Plan planning horizon to maintain at least would also be generally consistent with the CPPs considering
a 20-year horizon (to 2031), consistent with the GMA 2022 growth targets. Based upon the Citys assessment of the
requirements. The ProposalProposal/FEIS Review Citys Buildable Lands data and a more recent assessment of
Alternative would include subsequent text revisions to the long-term growth potential in the Urban Center, the City has
Comprehensive Plan to ensure internal consistency as well adequate housing and employment capacity under existing
as consistency with a number of updated functional plans. Comprehensive Plan and zoning to accommodate both 2022
King County Countywide Planning Policies. The and 2031 housing and employment targets, but the 2006-2031
1-22
Summary
Alternatives

ProposalProposal/FEIS Review Alternative is consistent with targets would take up the Citys remaining existing land
the CPPs. A selected summary of policies and consistency capacity.
analysis under each of the major topic headings in the CPPs Comprehensive Plan
is provided in Section 3.3, Land Use/Plans and Policies of the
DEIS. The ProposalProposal/FEIS Review Alternative Framework Policies. This alternative would be generally
demonstrates consistency with CPPs, particularly relating to consistent with the Comprehensive Plans framework policies.
land use patterns, urban centers, transportation, and orderly However, it would make less efficient use of land and would
development and provision of urban services. This alternative not update Comprehensive Plan policies to be consistent with
also demonstrates consistency with CPPs in the following the growth targets for households and employment ratified by
categories: critical areas, affordable housing, community King County jurisdictions in May 2010, or the new 2031
character and open space, and economic development. planning horizon.
Comprehensive Plan Land Use Element. This alternative would be generally
consistent with the Citys Land Use Element, but not to the
Framework Policies. The ProposalProposal/FEIS Review extent of the ProposalProposal/FEIS Review Alternative. In
Alternative is consistent with the Comprehensive Plans particular, this alternative focuses a greater percentage of the
framework policies which generally reflect state and regional household and employment growth in Downtown compared to
planning priorities addressed in the GMA and CPPs. In other areas of the City, consistent with Goal LU-3. However,
particular, the ProposalProposal/FEIS Review Alternative is this alternative would provide less overall growth in households
consistent with framework policies related to urban growth. and jobs in Downtown compared to the
Land Use Element. The ProposalProposal/FEIS Review ProposalProposal/FEIS Review Alternative. In addition, it
Alternative is consistent with goals and policies of the Land would not designate Activity Centers that allow for a mixed-use
Use Element. In particular, the ProposalProposal/FEIS development throughout the Kent Planning Area as called for
Review Alternative designates Activity Centers in existing in Goal LU-6 and related policies. This alternative would
commercial areas where a mix of retail, office, and residential provide adequate land capacity to accommodate updated
development can occur consistent with Goals LU-6 and LU-7 targets for jobs and housing. But, there would be no additional
and associated policies. capacity to accommodate growth beyond the 2031 planning
The ProposalProposal/FEIS Review Alternative would extend horizon. However, targets would be different from those noted
the Citys planning horizon and planned capacity to meet in Goal LU-9, and amendments would be required for
growth targets for households and jobs ratified by King consistency with updates to the CPPs that occurred in May
County jurisdictions in 2010. Though the 2010. Although Activity Centers are not designated under this
ProposalProposal/FEIS Review Alternative would be alternative, the City would continue to implement the DSAP.
generally consistent with Goal LU-9 relating to growth targets, Community Design Element. This alternative would maintain
Goal LU-9 would need to be amended for consistency with existing codes and regulations related to community design
the updated targets. Although the Downtown already has a and aesthetics. Therefore, Downtown would generally be
subarea plan, the ProposalProposal/FEIS Review Alternative consistent with the Community Design Element of the
identifies five potential Activity Centers. If the City designates Comprehensive Plan. However, other areas of the City,
them as Activity Centers, then Policy LU-14.1 calls for including the five Activity Centers would be more auto-
development of subarea plans for new Activity Centers. oriented, lower-scale land uses. See Section 3.4, Aesthetics of
Community Design Element. Under all alternatives, the City the DEIS for more information.
would continue to apply the Downtown, Multifamily and Mixed Housing Element. This alternative would generally be
Use Design Review Guidelines to relevant projects in consistent with Housing Element goals and policies except that
Downtown and in most commercial and office zoning districts. it would not support as much development of housing near
1-23
September 2011
Alternatives

Furthermore, under the Proposal/FEIS Review Alternative, transportation hubs (Policy H-2.4), and it would not encourage
Tthe City would adopt specific design regulations for portions as much housing in Downtown (Policy H-5.5) as the
of the Midway Subarea consistent with goals and policies of ProposalProposal/FEIS Review Alternative.
the Community Design Element related to using design to Capital Facilities Element. Growth anticipated under this
reinforce pedestrian orientation of development and to reduce alternative, similar to that anticipated under the
the bulk and height of buildings, as well as to reduce the ProposalProposal/FEIS Review Alternative would have an
effect of parking on the built environment. See Section 3.4, impact on public services. However, the existing Capital
Aesthetics of the DEIS for more information. Facilities Element accounts for public service and facility needs
Housing Element. Although both all alternatives encourage through the 2022 planning horizon. Beyond that, a lesser
additional housing development within the City, the amount of growth anticipated under this alternative is expected
ProposalProposal/FEIS Review Alternative supports the to result in less impact on public services than the
development of more housing near transportation hubs and ProposalProposal/FEIS Review Alternative. Any additional
employment centers, consistent with Policy H-2.4. The capital facilities needed for the lower level of growth
ProposalProposal/FEIS Review Alternative also encourages anticipated under this alternative to the 2031 planning horizon
more housing in Downtown than the No Action Alternative, would need to be included in the Capital Facilities Element
consistent with Policy H-5.5. consistent with Policy CF-1.4. See Section 3.6, Public Services
Capital Facilities Element. The ProposalProposal/FEIS and Utilities of the DEIS for more information.
Review Alternative would have a greater effect on public Transportation Element. This alternative would be generally
services than the No Action Alternative because of the larger consistent with the Transportation Element, as it is based on
amount of growth considered. However, additional growth growth assumptions made for the Citys current Transportation
would be provided in a more efficient manner under this Master Plan. However, this alternative does not accomplish as
alternative compared to the No Action Alternative. The much as the ProposalProposal/FEIS Review Alternative in
Capital Facilities Element would need to be amended to developing mixed-use development within walking distance of
incorporate additional capital facilities necessary for ensuring major transit investments. See Section 3.5, Transportation of
adequate capital facilities are in place in time to the DEIS for more information.
accommodate growth as called for in Policy CF-1.4. See Economic Development Element. The No Action Alternative
Section 3.6, Public Services and Utilities of the DEIS for more would be generally consistent with the goals and policies of the
information. Economic Development Element, but not to the same extent
Transportation Element. Both All alternatives provide for a as the ProposalProposal/FEIS Review Alternative.
balanced multimodal transportation system that supports Downtown Strategic Action Plan. The goals and strategic
current and projected land uses consistent with the overall actions of the DSAP would continue to be implemented under
goal of the Transportation Element. However, the this alternative. However, not as much growth in Downtown
ProposalProposal/FEIS Review Alternative would do more to would occur under this alternative as compared to the
promote multimodal facilities and services consistent with ProposalProposal/FEIS Review Alternative.
Policy TR-1.9 by focusing a large percentage of growth
proximate to existing and planned high capacity transit
improvements. It would also provide more opportunities to
encourage the development of alternatives to single-
occupancy vehicles consistent with Goal TR-8.
However, amendments to the Comprehensive Plan are
anticipated to incorporate expected new improvements to the
Citys transportation infrastructure to account for the new
1-24
Summary
Alternatives

increment of additional household and employment growth
and to finance those improvements. (See Section 3.5,
Transportation, of the DEIS for more information on the
ProposalProposal/FEIS Review Alternatives consistency with
the Transportation Element.)
Economic Development. The ProposalProposal/FEIS
Review Alternative would be consistent with the Citys
Economic Development Element by encouraging new
housing and employment development to be located closer to
existing and planned transit service including the Downtown
transit hubs.
Downtown Strategic Action Plan. The City would continue
to implement goals and actions of the DSAP but with more
focused economic development initiatives that are expected
to yield a greater amount of growth within the Downtown
compared to the No Action Alternative. In particular, the City
would have greater success at attracting new residential units
as part of mix of new development under the
ProposalProposal/FEIS Review Alternative compared to the
No Action Alternative.
3.4 Aesthetics Under the ProposalProposal/FEIS Review Alternative, a Under the No Action Alternative, the City would not alter
larger amount of new growth would be accommodated in the growth patterns, and all growth anticipated for the planning
Citys centers and corridors, including Downtown and Activity period would occur under existing development regulations.
Centers. The additional growth increases density over Visual Character
existing conditions. In general, this would result in taller
buildings, greater site coverages, reduced parking, and a In general, development under this alternative would result in a
greater emphasis on transit use. This shift in development development pattern and visual character that is similar to
patterns is anticipated to result in the following aesthetic existing conditions. Predominant zoning in the Activity Centers
effects. prescribes relatively low site coverage requirements and
requires front setbacks similar to the current pattern of
Visual Character commercial and office development. Portions of Activity
Under the ProposalProposal/FEIS Review Alternative, the Centers are zoned with mixed use designations which allow
visual character of the Activity Centers is anticipated to development with no street setbacks.
transition from the current auto-centric development pattern With the exception of those areas covered by a mixed-use
to one focused on mixed uses and pedestrian-oriented zoning overlay, implementation of this alternative is anticipated
development. To put into effect the ProposalProposal/FEIS to result in a visual character very similar to the current pattern
Review Alternative in the Kent Planning Area, it is expected of auto-centric development. Impacts specific to each of the
that land use and zoning designation changes would be Activity Centers are discussed in Section 3.4, Aesthetics of the
needed resulting in greater site coverages, development DEIS.
located closer to the street, and taller building heightsall of
which would represent a departure from the current visual Height and Bulk
character of the Activity Centers. An exception to this would Under this alternative, no changes would be made to
1-25
September 2011
Alternatives

be Downtown, which would not undergo any changes in land maximum allowed heights in the Kent Planning Area. Overall,
use or zoning designations under the ProposalProposal/FEIS heights in the Downtown would increase over existing
Review Alternative, and the Meeker/Washington Activity conditions, which, without the application of design standards,
Center, which is intended to remain a primarily auto-focused would have the potential to adversely affect the visual
area, due to its location adjacent to SR 167. Impacts on character and pedestrian environment of the area by cutting off
visual character in Downtown and the Meeker/Washington solar access, as well as being out of scale with much of the
Activity Center are anticipated to be similar to the No Action development surrounding Downtown, which is restricted to less
Alternative. than 40 feet by current zoning. However, implementation of
All Other Activity Centers. To prevent adverse effects on design standards currently applied in the Downtown (KCC
the visual character of the Activity Centers from anticipated 15.09.046) would address, in part, issues related to taller
increase in intensity, mitigation will be necessary in the form building heights anticipated in the Downtown.
of design review standards or specific provisions in the Few existing buildings in the Activity Centers currently achieve
revised development standards to ensure that development the maximum height allowed under current zoning regulations,
under the ProposalProposal/FEIS Review Alternative will not leaving potential for future development to increase heights
result in a more intense version of the current development over current conditions. While this is anticipated to generate a
pattern. Given the intensity and height of development small increase in height and visual bulk over time, heights
envisioned, over current conditions, the currently adopted would remain under 40 feet, and the increased density of
Downtown Design Review Guidelines could provide a solid development would not lead to a significant increase in visual
base for mitigating potential adverse effects on visual bulk over current conditions.
character. See Section 3.4.3, Mitigation, of the DEIS for Pedestrian Environment
additional discussion of specific measures to be applied to
future development in these areas. While the overall quality of the pedestrian environment is
linked to other factors, such as visual character and height and
Height and Bulk bulk, the pedestrian experience is also heavily influenced by
Under the ProposalProposal/FEIS Review Alternative, the presence or absence of specific design elements, including
building heights are anticipated to increase over existing sidewalks, landscaping, and street furniture. Adverse impacts
conditions, as well as over what is allowed under current associated with the pedestrian environment occur when the
zoning, with the exception of Downtown, the action would remove pedestrian infrastructure, decrease
Meeker/Washington Activity Center, and the Panther Lake pedestrian safety, or otherwise make the pedestrian
Activity Center. Multi-story buildings can have positive environment less inviting or comfortable for users. Overall, the
impacts in a community, including adding visual interest to pedestrian experience in the Activity Centers is expected to
the built environment, creating views, and providing eyes on decline with implementation of this alternative, as future growth
the street. Potential adverse impacts associated with height is anticipated to increase levels of vehicular traffic, which
and bulk could occur if buildings are out of scale with the would exacerbate the existing lack of buffer between public
surrounding environment, either by being significantly taller sidewalks and adjacent traffic lanes that is found in all areas
than nearby development or through a monolithic appearance except Downtown. Impacts specific to each of the Activity
that encroaches on the visual landscape. A building with Centers are discussed in Section 3.4, Aesthetics of the DEIS.
high-quality design can also create height and bulk issues if it Scenic Views
overshadows its surroundings and does not provide adequate
access to light and air. These effects can make the area Flat topography, low building heights, and intervening
uncomfortable for pedestrian use, and without appropriate vegetation combine to preclude scenic views of the Cascades,
design features, such as upper story setbacks and Mount Rainier, or the Kent Valley from within the Activity
pedestrian-scaled faade details, can degrade the visual Centers. No adverse impacts on views are anticipated as
1-26
Summary
Alternatives

quality of an area. heights would remain low under this alternative.
To encourage high quality and sensitively designed buildings Light and Glare
and minimize the potential for adverse effects, the Additional growth in the Activity Center would introduce new
ProposalProposal/FEIS Review Alternatives development sources of light and glare, such as increased numbers of
regulation amendments should include a requirement for new automobiles, additional exterior illumination for buildings, and
development to incorporate upper-story setbacks, to help new street lighting. However, as the Activity Centers are
prevent pedestrians from being overwhelmed by the visual commercial areas and already highly auto-oriented, additional
bulk of buildings, as well as help preserve solar access to the light and glare from growth under this alternative is not
ground level. See Section 3.4, Aesthetics of the DEIS for anticipated to result in any significant adverse impacts.
more detail on height and bulk impacts by Activity Center.
Solar Access/Shading Conditions
Pedestrian Environment
As building heights under this Alternative would increase only
In addition to absorbing additional growth, the slightly over existing conditions, no significant impacts
ProposalProposal/FEIS Review Alternative is intended to associated with shading or solar access are anticipated over
encourage pedestrian oriented mixed-use development in the the long term. As each Activity Center redevelops at the
Activity Centers. This style of development would result in currently allowed maximum height, review on a per-project
increased site coverages, mixed uses, and reduced parking basis will be necessary to identify and mitigate impacts
compared with existing conditions. The resulting from proposed taller buildings adjacent to existing
ProposalProposal/FEIS Review Alternative would also shorter development.
implement street and landscaping standards to foster
pedestrian and bicycle traffic in the Activity Centers, though
specific regulations and standards have not yet been
developed. To successfully create a human-scaled
pedestrian environment and mitigate potential impacts from
increased building heights and lot coverages, it would be
necessary for the City to apply streetscape and building
design standards to future development in the Activity
Centers. The currently adopted Downtown Design Review
Guidelines would provide an appropriate basis for developing
Activity Center-specific standards for the mitigation of
adverse effects to the pedestrian environment.
Scenic Views
The City has listed preservation of views to the Cascades,
Mount Rainier, and the Kent Valley as a goal of the
Community Design Element of the Comprehensive Plan.
However, no specific view corridors are currently designated
for protection. Flat topography, low building heights, and
intervening vegetation combine to preclude scenic views of
the Cascades, Mount Rainier, or the Kent Valley from within
the Activity Centers. However, as building heights within the
Activity Centers are anticipated to increase under this
alternative, they have the potential to create visual
1-27
September 2011
Alternatives

obstructions from other parts of the Kent Planning Area,
specifically the West Hill. All Activity Centers are located on a
line of sight between the West Hill and visual resources
called out for view preservation, particularly the Cascades.
The Kent-Kangley/132nd Activity Center could also be within
the view corridor to Mount Rainier.
The potential of new development under the
ProposalProposal/FEIS Review Alternative to affect scenic
views would vary with the maximum allowed height for each
Activity Center. Conversely, increased heights under the
ProposalProposal/FEIS Review Alternative have the potential
to create scenic views by raising viewers high enough to see
vistas and landmarks that are not visible at ground level due
to flat topography or existing development and vegetation.
Light and Glare
Additional growth in the Activity Centers would introduce new
sources of light and glare, such as increased numbers of
automobiles, and additional exterior illumination for buildings.
Exterior light and glare under the ProposalProposal/FEIS
Review Alternative would come more from streetlights and
illuminated signage than from automobiles or lighted
billboards, but increased growth in the Activity Centers still
has the potential to create additional lighting and glare
issues, particularly in the evening hours, when lighting from
retail and entertainment uses may impact residences in
mixed-use areas. Furthermore, although there is potential for
interior lighting to contribute to increased ambient light and
glare during evening hours, the effects would be localized
and highly dependent on the glazing and architectural
features of individual buildings. Compared to impacts
associated with exterior illumination and street lighting,
interior building lighting is not anticipated to be a major factor
in light and glare impacts. The application of design
standards for lighting would be necessary to ensure that no
significant lighting and glare impacts are generated under the
ProposalProposal/FEIS Review Alternative.
In urban environments, solar access and shading conditions
are intrinsically linked to many factors including building
height and bulk of buildings, the presence of trees on or near
the property, and local topography. Buildings that are
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Summary
Alternatives

significantly taller than neighboring structures or that fail to
provide upper-story setbacks have the potential to cast
perpetual shadows on those properties, blocking solar access
for any public and pedestrian spaces in these locations.
Shading conditions under the ProposalProposal/FEIS Review
Alternative would vary within the Activity Centers, depending
on location relative to new development. Those properties
closest to the new building would be most strongly affected,
as they have the potential to be shaded under both winter
and summer conditions. While some shading of adjacent
structures is unavoidable in dense urban environments, it is
desirable to reduce these effects as much as possible,
particularly in relation to sensitive public and pedestrian
spaces such as parks and plazas. The application of
measures for the preservation of solar access, such as upper
story setbacks, would be necessary to mitigate adverse
effects under the ProposalProposal/FEIS Review Alternative.
3.5 Transportation Street System Impacts Street System

The ProposalProposal/FEIS Review Alternative is projected The transportation improvements defined in the TMP are
to worsen LOS on the following four corridors when needed for the City to maintain concurrency under this
compared to the No Action Alternative: alternative. Table 3.5.-6 in Section 3.5, Transportation of the
S 212th Street/S 208th Street, DEIS provides a summary of roadway network and LOS
assumed for the No Action Alternative.
S 260th Street/Reith Rd/W Meeker Street,
S 272nd Street, and The table shows that with TMP improvements in place, there
are no additional LOS impacts identified under this alternative.
Military Road.
Several projects found within the TMP have been completed
For three of the above corridors, the transportation since the TMP was completed. However, improvements to S
improvement projects implemented under the TMP are 272nd Street that were originally included in the TMP, have
expected to be sufficient to accommodate the increased since been dropped from the project list. Without the assumed
delay, and allow the facilities to meet the Citys LOS improvements to S 272nd Street in place, it is likely that this
standards. See Section 3.5, Transportation of the DEIS for a corridor would operate below the Citys standard under both
summary of roadway network and LOS assumed for the the No Action alternative and the ProposalProposal/FEIS
ProposalProposal/FEIS Review Alternative. Review Alternative in 2031.
One corridor, S 272nd Street, would operate below the Citys Bicycle, Pedestrian, and Transit Facilities
LOS standard under the ProposalProposal/FEIS Review
Alternative by 2031. Thus, the ProposalProposal/FEIS While this alternative would result in increased demands for
Review Alternative would result in an LOS impact on only the bicycle, pedestrian, and transit facilities, the Citys TMP is
S 272nd Street corridor, which would have overall corridor planning for a system that would help meet future demands.
operations of LOS F. The analysis for both the Moreover, the Citys development guidelines require that the
ProposalProposal/FEIS Review Alternative and the No Action increased demands for these facilities are addressed.
Alternative, however, assumed improvements to S 272nd
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September 2011
Alternatives

Street that were originally included in the TMP, but have
since been dropped from the project list. Without the
assumed improvements to S 272nd Street in place, it is likely
that this corridor would operate below the Citys standard
under both the No Action alternative and the
ProposalProposal/FEIS Review Alternative in 2031.
Congestion in Downtown and along SR 99 is also projected
to increase under the ProposalProposal/FEIS Review
Alternative. Specifically, delays at Downtown intersections
are expected to increase by about 15%. Average delays
along SR 99 increase from 95 seconds to 108 seconds.
However, because the City has established an LOS F
standard for roadway facilities in these areas, these
increases in delay are not considered significant impacts.
Bicycle, Pedestrian, and Transit System
While the ProposalProposal/FEIS Review Alternative would
result in increased demands for bicycle, pedestrian, and
transit facilities, it is not anticipated to adversely affect these
facilities. The following factors lessen the
ProposalProposal/FEIS Review Alternatives impact on
bicycle, pedestrian, and transit facilities:
The Citys TMP plans for future non-motorized system
improvements;
The Citys development guidelines require that the
increased demands for these facilities are addressed as
a condition of development approval; and
The higher density and mixed use development patterns
in the centers and corridors, under the
ProposalProposal/FEIS Review Alternative would be
more conducive to mobility via transit and non-motorized
modes.
3.6 Public Services/Utilities Police Public service provision under this alternative reflects the Citys
It is difficult to quantify how growth in population and current Comprehensive Plan land use forecasts as developed
employment in the Kent Planning Area would affect the and updated for development of the Citys 2008 TMP.
Police response time LOS standard. However, the Therefore, public service providers who have updated their
ProposalProposal/FEIS Review Alternatives growth of functional plans since that time are more likely to have planned
approximately 60% in population and employment is for and programmed improvements to address facility and
expected to result in greater congestion, particularly on service needs resulting from this alternative than the
routes identified in Section 3.5, Transportation of the DEIS. ProposalProposal/FEIS Review Alternative.
As noted in Section 3.5, Transportation of the DEIS both the Police
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Summary
Alternatives

Downtown area and the Pacific Highway South corridor Under this alternative, population would grow by 12% over
operate at LOS F under the future conditions under both existing conditions. Although growth under this alternative is
alternatives, making these areas increasingly congested and expected to result in greater congestion, particularly on routes
affecting response times for Police. Future congestion identified in Section 3.5, Transportation, of the DEIS for this
associated with the ProposalProposal/FEIS Review alternative, it would result in less overall congestion than
Alternative is more prominent compared to the No Action at S anticipated under the ProposalProposal/FEIS Review
272nd Street west of 36th Avenue South, S 260th/Reith Alternative. Still, the City may need to construct new facilities
Road/Meeker Street corridor, the 36th Avenue South corridor, to provide faster response time, or expand current facilities
and the S 212th Street/SE 208th Street corridor. The City depending upon location of growth and additional congestion.
may need to construct new police facilities to provide faster To maintain the ability to respond to emergency calls in a
response time, or expand current facilities, depending upon timely manner, it may be necessary for the Police Department
location of growth and additional congestion. to hire additional officers and support staff during the planning
The need for police protection under the period compared to existing conditions. However, since
ProposalProposal/FEIS Review Alternative could be reduced population and employment growth would be smaller under
through requirements for security-sensitive design of this alternative, fewer police officers and support staff would be
buildings and the associated landscaping. needed to meet service call needs.
To maintain the ability to respond to emergency calls in a Fire and Emergency Medical Services
timely manner, it may be necessary for the Police Similar to the Police Department, the Kent Fire Department
Department to hire additional officers and support staff during RFAs LOS standards are related to response time. Although
the planning period. the Kent Planning Area is only a portion of the Kent Fire
Fire and Emergency Medical Services Department RFAs service area, this alternatives 12%
Although the Kent Planning Area is only a portion of the Kent increase in population in the Kent Planning Area would have
Fire Department Regional Fire Authority (RFA)s regional an effect of increasing traffic congestion in a number of
service area, a 60% increase in population and employment locations compared to existing conditions (see Section 3.5,
in the Kent Planning Area would have an effect of eroding Transportation of the DEIS for detail on congested corridors).
existing service capacity and increasing vehicular trips which However, with improvements included as noted in the Citys
willcould slow response time. Congestion is expected to vary TMP, congestion would also be reduced on some corridors
based on location as noted in Section 3.5, Transportation of compared to existing conditions. For areas where congestion
the DEISand as described under Police, above. Increases in increases under this alternative, the rate at which it increases
congestion would also have a similar effect of slowing would vary based upon location as noted in Section 3.5,
response time to emergency medical calls. Therefore growth Transportation of the DEIS. Increases in congestion would also
anticipated under the ProposalProposal/FEIS Review have a similar effect on slowing emergency medical
Alternative can be expected to result in a need for additional responses, causing a potential need to develop new facilities
fire and emergency response facilities and/or expansion of and/or expand existing facilities to serve the additional
existing facilities to serve the larger population anticipated population and employment expected under this alternative.
under the ProposalProposal/FEIS Review Alternative. However, since the growth rate under this alternative is lower
than under the ProposalProposal/FEIS Review Alternative, it is
The Kent Fire Department RFA will use its geographic anticipated that congestion would be less, resulting in less
information system (GIS) to assess impact of future need for additional facilities.
population and employment growth upon fire services, similar
to the No Action Alternative. The department RFA also plans The Kent Fire Department RFA uses GIS to assess impact of
to analyze the Citys updated population and employment future population and employment growth upon fire services.
The department RFA plans to analyze the Citys updated
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September 2011
Alternatives

projections, update its Concurrency Management Plan and population and employment projections, update its
assess potential impacts and facility needs using its Concurrency Management Plan, and assess potential impacts
Mitigation and Level of Service Contribution policy (Rabel and facility needs using its Mitigation and Level of Service
pers. comm.). Contribution policy as it plans for future facilities (Rabel pers.
The number of calls for fire and emergency response comm.).
services would increase in conjunction with the Citys In order to maintain the ability to respond to emergency calls in
increase in population. In order to maintain the ability to a timely manner, it may be necessary for the Kent Fire
respond to emergency calls in a timely manner, it willmay be Department RFA to hire additional firefighters, EMTs and
necessary for the Kent Fire Department RFA to hire support staff during the planning period. However, since
additional firefighters, emergency medical technicians (EMTs) population and employment growth is lower under this
and support staff during the planning period. alternative, it can be assumed that there would be a smaller
need for firefighters, EMTs, and support staff under this
Parks, Recreation, and Community Services alternative compared to the ProposalProposal/FEIS Review
Alternative.
With greater population growth anticipated in the Kent
Planning Area, there would be deficits in both park and
recreation space compared to existing facilities. Parks, Recreation, and Community Services
If the City were to lower its LOS standards for parks and Under this alternative, population growth is estimated to be
recreation for the Kent Planning Area population anticipated somewhat lower than that assumed in the 2010 Parks and
under the ProposalProposal/FEIS Review Alternative, the Open Space Plans 2031 population estimate.
City would need to make the following adjustments: Applying the Parks LOS standard to growth projected under
Lower overall park LOS standards from 15.24 this alternative shows that the City would experience a small
acres/1,000 population to 8.98 acres/1,000 population; deficit of 296 acres of park land and a surplus of recreation
and space at the planning horizon compared to current facilities.
Lower overall recreation LOS standards from 1.86 Comparing this alternative to the ProposalProposal/FEIS
square feet per person to 1.84 square feet per person. Review Alternative, the City would need about 777 fewer acres
of park land and 94,880 fewer square feet of recreation space
The LOS standards focus on quantity of parks and recreation under this alternative.
in relation to population. Another consideration is location of
facilities near population. Under the ProposalProposal/FEIS Under this alternative, demand for additional parks is likely to
Review Alternative, 27% of residential growth is focused in be greater outside of Downtown or Activity Centers in the more
the five potential Activity Centers compared to 9% under the residential areas of the City. Since there would be less
No Action Alternative; however, since there are no formal concentration of growth in Downtown and five Activity Centers
parks and recreation spaces located in the Activity Centers, in this alternative compared to the ProposalProposal/FEIS
these areas are expected to show a greater additional Review Alternative, there would be less need for parks and
demand for parks and recreation than other areas. Although recreation facilities located in or proximate to the five Activity
some of this demand would be met by existing parks and Centers. Downtown would still exhibit a need for parks and
recreation facilities in the immediate vicinity of Activity recreation space, but at a lower level of need than under the
Centers, existing facilities may not be enough to keep up with ProposalProposal/FEIS Review Alternative.
localized demand, in Activity Centers. Under this alternative
the need for parks and recreation spaces in walking distance
of Activity Centers is more important than under the No
Action Alternative to achieving City goals for accessing parks
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Summary
Alternatives

and recreation services as well as increasing non-auto mode
share. Downtown is expected to experience a tripling of
residential population under the ProposalProposal/FEIS
Review Alternative. Although Downtown has existing parks
and recreation facilities located in its boundaries, as noted
under Affected Environment, the expected increase in
population under the ProposalProposal/FEIS Review
Alternative is expected to result in a need for additional parks
and recreation facilities in and near Downtown under the
Proposal. The 2010 Parks and Open Space Plan emphasizes
developing trails and greenway corridors to connect parks,
schools, and neighborhoods including the Activity Centers.
This may result in additional parks and recreation acquisitions
in or near potential Activity Centers. The plan also indicated
the Citys direction to develop a more qualitative parks and
recreation standard.
Schools Schools
Kent School District: The Kent School District projects Kent School District: Under this alternative, the portion of the
enrollment increasing to 7% over the next 6 years (Kent Kent Planning Area served by the Kent School District is
School District 2009). Although the Kent Planning Area expected to grow by approximately 13% over the planning
encompasses only a portion of the Kent districts service period. The composition of housing stock in the Kent School
area, it includes a number of areas where growth is proposed District portion of the Kent Planning Area is expected to remain
to be concentrated under the ProposalProposal/FEIS Review largely unchanged with multifamily share of housing increasing
Alternative, including Downtown and the five potential Activity slightly from 37% of housing in 2006 to 38% at end of the
Centers. Even though these areas are targeted for more planning horizon under this alternative.
intensive growth under the ProposalProposal/FEIS Review Applying the School Districts estimated student generation
Alternative, most of that growth would occur in the form of ratios to growth in households anticipated under this
multifamily housing which has a lower student generation alternative provides an estimate that the Kent Planning Areas
ratio than single family housing. portion of the school districts enrollment would increase to
Applying the Kent School Districts estimated student approximately 28,100 students. This is approximately 6,300
generation ratios for single-family and multifamily housing to fewer students than expected under the
household growth anticipated under the ProposalProposal/FEIS Review Alternative, but would still
ProposalProposal/FEIS Review Alternative provides an exceed the school districts existing permanent student
estimate that the Kent Planning Areas portion of the school capacity of 27,321. The Kent School District 2009 Six-Year
districts enrollment would increase to approximately 34,400 Capital Facilities Plan indicates that the school district
students, exceeding the school districts existing permanent anticipates exceeding existing permanent capacity district-wide
student capacity of 27,321. The districts 2009 Six Year in 2015, and the district has projects and plans in place to add
Capital Facilities Plan indicates that the district anticipates permanent capacity for an estimated students over the six year
exceeding existing permanent capacity district-wide in planning period.
2015.The Kent School Districts 2009 Six Year Capital The school district will continue planning proactively and will
Facilities Plan also includes projects that are expected to add incorporate the Citys work on updating its Comprehensive
permanent capacity for an estimated 885 students during the
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September 2011
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Districts 6-year planning period, helping to alleviate some of Plan into future student enrollment forecasts. In addition, the
the projected deficits from growth anticipated under the school district makes use of relocatables to help provide
ProposalProposal/FEIS Review Alternative. temporary capacity and/or capacity needed in a particular
The school district will continue planning proactively and location, when it does not make sense to construct a
would incorporate the Citys work on updating its permanent facility.
Comprehensive Plan into future student enrollment forecasts. Federal Way School District: The Federal Way School
In addition, the school district makes use of relocatables to District overlaps the Kent Planning Area in the West Hill,
help provide temporary capacity or capacity needed in a including a portion of the Midway Subarea. See Table 1-2 for
particular location, when it does not make sense to construct analysis of impacts in the Midway Subarea.
a permanent facility. The majority of the approximately 320 households anticipated
Federal Way School District: The Federal Way School in the Kent portion of the district would be constructed in the
District overlaps the Kent Planning Area in the West Hill, West Hill outside the Midway Subarea under this alternative.
including a portion of the Midway Subarea. See Table 1-2 for These new households are expected to generate
analysis of impacts in the Midway Subarea. approximately 224 students attending schools noted under
Under the ProposalProposal/FEIS Review Alternative, the affected environment above. The Federal Way School
district can expect an increase of approximately 5,400 Districts 2010 Capital Facilities Plan includes facility
households in the Kent portion of the school district over the improvements to schools serving the West Hill which is
planning period. Of this increase, a smaller increase of expected to address any anticipated capacity needs.
between 600 and 700 households would occur in residential Compared to the Proposal/FEIS Review Alternative, Iit is less
neighborhoods located outside the Midway Subarea. likely that the increase in population anticipated under this
The portion of the Federal Way School District located in alternative would result in capacity deficits for Federal Way
Kent would experience an increase of 2,400 students over school facilities. The school district may also make use of
the planning period. Only 500 to 600 of the students would be relocatables, attendance boundary adjustments, or similar
located in the portion of the Kent West Hill outside the measures to ensure student capacity is available at the time it
Midway Subarea is needed.
The Federal Way School Districts 2010 Capital Facilities Highline School District: The Highline School District
Plan identifies some infrastructure projects that would add overlaps the Kent Planning Area on the West Hill, taking in
capacity to area facilities, including Sunnycrest Elementary most of the Midway Planned Action Area portion of the Midway
School. These improvements would help address school Subarea as well as a small single-family residential
capacity needs, at least in part. The increase in student neighborhood west of SR 99. The only part of the districts
population from areas of the Kent West Hill would not provide service area in the Kent Planning Area that is not within the
a large increase on its own, but in conjunction with the Midway Subarea is an already built-out single-family residential
Midway Subarea Plan described below, it is likely that neighborhood. Because of limited opportunity for new
additional capacity would be needed at one or more level of development or redevelopment in that area, it is not anticipated
school facilities in this portion of the Federal Way School to cause any increase in Highline School District enrollment.
District. The school district may also make use of See Midway Subarea analysis below for impacts within the
relocatables, attendance boundary adjustments, or similar Midway Subarea.
measures to ensure student capacity is available at the time it
is needed.
Highline School District: The Highline School District
overlaps the Kent Planning Area on the West Hill, taking in
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Summary
Alternatives

most of the Midway Planned Action Area portion of the
Midway Subarea as well as a small single-family residential
neighborhood west of SR 99 and outside the Midway
Subarea boundaries. Since the existing residential
neighborhood outside the subarea is already developed, a
large increase in student enrollment is not anticipated to
occur in this portion of the districts boundaries. See Midway
Subarea analysis below for analysis of the portion of the
district within the Midway Subarea.
Water Water
City of Kent Water: Under the ProposalProposal/FEIS City of Kent Water: The Citys 2008 Water System Plan
Review Alternative, the Kent Water Service Area would see a generally accounts for growth anticipated under this
54% increase in new households and 47% increase in new alternative. The plans 2030 horizon year anticipates a service
jobs compared to the 2006 base year in the Citys water area population of approximately 27,900 households and
service area. A review of the Citys 2008 Water System Plan employment of 69,372, similar to the No Action Alternative
indicates that it accounts for growth under the No Action growth estimates.
Alternative, but not the ProposalProposal/FEIS Review Under this alternative, the water systems total yearly average
Alternative. The 2008 Water System Plan anticipates a 2030 supply of 17.45 MGD and peak dependable supply of
population of approximately 27,900 households and 69,400 approximately 30 MGD is adequate to meet the needs of the
jobslower than what is anticipated under the City to the 2031 planning horizon with the programmed capital
ProposalProposal/FEIS Review Alternative for the Citys improvement projects contained in the 2008 Water System
water service area. Plan. The 2008 Water System Plan includes a total capital
Due to the concentration of additional growth in Downtown, improvement plan with expenditures in excess of $160 million
and the three Activity Centers served by Kent Water, the Kent with potential funding mechanisms identified. The City
Water Service Area would see the largest increase in overall anticipates paying for these improvements through a revised
new development in Downtown, and the Meeker/Washington rate structure that would include a new base rate accounting
Activity Center in the Citys 240 Pressure Zone (Green River for the actual cost to deliver water to each customer as well as
Valley), and the Benson/SE 240th Street and Benson/SE an update to connection charges to ensure that new
256th Street Activity Centers in the Citys 590 Pressure zone. development pays its fair share of system wide improvements
Although the City water system has not analyzed the impacts (City of Kent 2008).
of the larger increment of growth anticipated under the Soos Creek Water and Sewer: Under this alternative, the
ProposalProposal/FEIS Review Alternative, it can be Soos Creek Water and Sewer District, serving much of the
assumed that this additional growth would require further Citys East Hill and the Panther Lake Activity Center is
upgrades to the Citys existing water supply, storage, and expected to grow by approximately 475 households and 160
distribution system. The Citys 2008 Water System Plan employees compared the existing conditions, lower than
describes a peak dependable water supply of 30 MGD of anticipated under the ProposalProposal/FEIS Review
water including the Tacoma Second Supply source. Although Alternative.
this supply is anticipated to be adequate to meet projected The 2005 Soos Creek Comprehensive Water Plan was
population and employment water supply needs, the 2008 developed using the Citys existing Comprehensive Plan to
Water System Plan identified supply issues with providing guide future water demand and system analysis. Therefore, it
adequate fire flow in its 240 Pressure Zone (Green River is anticipated that the districts existing 2005 Comprehensive
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September 2011
Alternatives

Valley). With anticipated additional growth in this Pressure Water Plan, with infrastructure improvements and amendment
Zone, particularly in Downtown, there may be additional to the City of Seattle supply contract identified in it, would
water infrastructure needs to attain an adequate fire flow in account for most if not all of the growth anticipated under this
the 240 Pressure Zone. Although improvements identified in alternative.
the 2008 Water System Plan would help alleviate some of the Water District #111: Growth anticipated in the Water District
deficiencies in water supply, storage, and distribution, the #111 portion of the Kent Planning Area under this alternative
additional growth in population and employment under the would provide an increase of approximately 730 households
ProposalProposal/FEIS Review Alternative can be expected and 1,490 employees over existing conditions. The Water
to introduce new deficiencies which the City Water Utility District #111 portion of the Kent Planning Area would include
should identify and address at its next water system plan approximately 7,450 households and 2,730 employees in 2031
update or earlier, if possible. under this alternative. The 2007 District Comprehensive Water
Soos Creek Water and Sewer District: Under the Plan plans for a district-wide population of 7,676 households
ProposalProposal/FEIS Review Alternative, the Soos Creek and 3,855 employees in 2028.
Water and Sewer District Water Service Area in the Kent The Water District #111 2007 Water Comprehensive Plan
Planning Area is expected to grow by approximately 1,375 describes the district water supply strategy (Water District
households and 20 jobs compared to existing conditions. #111 2007). The district currently has sufficient supply to meet
Approximately 33% of this growth is expected to occur in the the average daily demand for its planning period extending to
Panther Lake Activity Center located at Benson/SE 208th 2028. However, there may be occasion when water demand
Street. A review of the population projections in Appendix G reaches the projected maximum that would create a shortfall of
of the 2005 Soos Creek Comprehensive Water Plan indicates an estimated 0.64 MGD. The district indicates that its supply
that the district anticipates serving 26,114 households district- can be managed by looking both negotiating water supply
wide by 2030 (Soos Creek Water and Sewer District 2005). delivery schedules with the City of Auburn and managing
Although there are no break-outs of projections that show customer usage, as well as through the multiple interties it has
exact projections for the Kent Planning Area, the districts in place with adjacent purveyors that would provide satisfy
2005 plan shows that it is planning for a 20% growth in needs for the short term, and a contract with the City of
households over the 2010 to 2030 timeframe. This is a larger Tacoma for provision of long-term firm water, which would be
increase than the 14% increase in population growth accomplished by 2014.
anticipated under the ProposalProposal/FEIS Review
Alternative in the Soos Creek water service area portion of The districts 2007 Comprehensive Water Comprehensive Plan
the Kent Planning Area in the 2006-2031 timeframe. extends to a 2028 planning horizon and includes projects to
address minor system deficiencies related to minimum
Since the most recent Soos Creek Water System Plan was pressure, maximum velocity and fire flow issues in the
prepared using the Citys current Comprehensive Plan, it can distribution system, as well as construction of an additional
be reasonably assumed that additional water system storage facility to address a projected storage deficit in the
improvements would be needed to account for this additional 2028 planning horizon. Given that the plan was developed
increment in population and employment. using the Citys current Comprehensive Plan as the basis for
Water District #111: Under the ProposalProposal/FEIS future water demand and system analysis, it is likely thatwith
Review Alternative, Water District #111s water service area the improvements and water supply strategy identified in the
in the Kent Planning Area would see an increase in 2007 Comprehensive Water Comprehensive Plan,the district
population by approximately 1,440 households and 2,480 would be able to meet the water supply, storage, and
employees compared to existing conditions. The Kent distribution needs of this alternative. The district will use the
Planning Area portion of Water District #111 would include a Citys updated population and employment projections when
planning horizon population of 8,170 households and 3,710 updating its comprehensive water plan in the future.
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Summary
Alternatives

employees. Approximately one-third of population growth and Highline Water District: The Highline Water District serves a
10% of employment growth is anticipated to occur in the large portion of the West Hill, including the entire Midway
Kent-Kangley/132nd Avenue SE Activity Center. The districts Subarea. Because the majority of the district is within the
2007 Comprehensive Water Comprehensive Plan plans for a Midway Subarea, impacts to the Highline Water District are
district wide population of 7,676 households and 3,855 found under the Midway Subarea section (see Table 1-2).
employees in 2028.
The plan includes projects to address minor system
deficiencies, as well as construction of an additional storage
facility to address a projected storage deficit in the 2028
planning horizon. Since the 2007 Water District #111
Comprehensive Water Comprehensive Plan was prepared
using the Citys current Comprehensive Plan, it can be
reasonably assumed that additional water system
improvements would be needed to account for the additional
increment in population anticipated under the
ProposalProposal/FEIS Review Alternative. The district will
use the Citys updated population and employment
projections when updating its comprehensive water
comprehensive plan in the future.
Highline Water District: The Highline Water District serves
portions of the Citys West Hill, including the entire Midway
Subarea. See Midway Subarea analysis below for information
on Highline Water District.
Sewer Systems Sewer Systems

The Kent Planning Areas sewer service is provided by the The Kent Planning Area is served by the City, Soos Creek
City, Soos Creek Water and Sewer District, Lakehaven Utility Water and Sewer District, Lakehaven Utility District, and
District, and the Midway Sewer District. Midway Sewer District for sewer service.
City of Kent: Because the City relies on a regional King City of Kent: Because the City relies on a regional King
County Metro sewage treatment plant in Renton, the City County Metro sewage treatment plant in Renton, the City
sewer utility must ensure it has adequate conveyance, sewer utility must ensure it has adequate conveyance,
distribution, and pumping capacity to transport wastewater to distribution, and pumping capacity to transport wastewater to
the South Treatment Plant in Renton. The City 2000 the South Treatment Plant in Renton. The City 2000
Comprehensive Sewer System Plan indicates that the City Comprehensive Sewer System Plan indicates that the City has
has capacity to accommodate 40 to 42 MGD of wastewater capacity to accommodate 40 to 42 MGD of wastewater flow.
flow. The Citys existing Comprehensive Sewer Plan does not
The Citys 2000 Comprehensive Sewer System Plan account for land use projections used for this alternative.
describes growth forecasts to the year 2010 using the Citys Under the No Action Alternative, the Kent Sewer Service Area
1994 Comprehensive Plan. Under the would grow by approximately 3,200 households and 21,400
ProposalProposal/FEIS Review Alternative, the Kent Sewer jobs compared to existing conditions. According to City sewer
service area would grow by roughly 15,000 households and utility staff, the Citys sewer system is developed based on
23,300 jobs compared to existing conditions. The land use capacity, and therefore, it is sized to account for most
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September 2011
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ProposalProposal/FEIS Review Alternative anticipates long-term population and employment projections (Vesper
concentrating new households and jobs above and beyond pers. comm.). Although the Citys 2000 Comprehensive Sewer
those anticipated under the existing Comprehensive Plan in Plan did not analyze the specific population and employment
identified centers and corridors. The Citys Sewer Utility projections of this alternative, the plan indicates that it is
serves Downtown, and four of the five Activity Centers. planning to serve an ultimate Kent Sewer Service population of
Between Downtown and the four Activity Centers being 151,240 (City of Kent 2000), which is more than the estimated
covered by the City Sewer System, they represent a little less population of approximately 75,000 for the Kent Sewer Service
than half of the new households and jobs anticipated under Area under this alternative. This shows that the City is planning
the ProposalProposal/FEIS Review Alternative. to serve a larger population than anticipated under the No
According to City Sewer Utility staff, the Citys sewer system Action Alternative. The City will use population and
is developed based on land use capacity, and therefore it is employment projections contained in this DEIS when updating
sized to account for most long-term population and its sewer plan.
employment projections (Vesper pers. comm.). Although the Based on Ecologys estimates of a per capita contribution to
Citys 2000 Comprehensive Sewer Plan did not analyze the wastewater flow of 100 gpd (Vesper pers. comm.), the Citys
specific population and employment projections of the sewer system portion of the Kent Planning Area is estimated to
ProposalProposal/FEIS Review Alternative, the plan indicates produce 7.5 million gpd of wastewater in 2031 under this
that it is planning to serve an ultimate Kent Sewer Service alternative, an increase of approximately 0.8 million gpd over
population of 151,240 (City of Kent 2000), which is more than estimates for the base year, and approximately 3 million gpd
the estimated planning horizon population of 105,000 for the less than flows estimated for the ProposalProposal/FEIS
Kent Sewer service area under the ProposalProposal/FEIS Review Alternative.
Review Alternative. The City will use population and Soos Creek Water and Sewer District: The Soos Creek
employment projections contained in this EIS when updating Water and Sewer District provides sewer service to portions of
its Sewer Plan. Based on Ecologys current estimates of a the Citys East Hill, including the Panther Lake Activity Center.
per capita contribution to wastewater flow of 100 gallons per The 2005 Comprehensive Sewer Plan projects a population of
person per day (Vesper pers. comm.), the Citys sewer approximately 18,200 households and 10,800 employees for
system portion of the Kent Planning Area is estimated to the district drainage basins in the Kent Planning Area in 2030.
produce 10.5 MG of wastewater per day in 2031, an increase Under this alternative, the Soos Creek sewer service area
of approximately 3.8 MGD over estimates for the base year of would see an increase in approximately 1,830 households and
2006. 725 employees compared to existing conditions for a total of
Soos Creek Water and Sewer District: The Soos Creek approximately 16,000 households and 3,300 jobs.
Water and Sewer District provides sewer service to portions The districts 2005 Comprehensive Sewer Plan identifies a
of the Citys East Hill, including the Panther Lake Area and series of capital improvements for the 10-year and ultimate
the Panther Lake Activity Center. Under the build-out scenarios to address anticipated population and
ProposalProposal/FEIS Review Alternative, the Soos Creek employment growth and to maintain the sewer system. With
sewer service area would see an increase in approximately these projects in place, the district should be able to
4,600 households and 5,100 employees compared to existing accommodate the population and employment growth
conditions. anticipated in the Kent Planning Area portion of its service area
The 2005 Soos Creek Comprehensive Sewer Plan indicates under this alternative. The district will use the Citys updated
that the district is planning for approximately 18,200 population and employment projections for future sewer
households and 10,800 employees in its drainage basins in service planning.
the Kent Planning Area (Soos Creek Water and Sewer Lakehaven Utility District: The Lakehaven Utility District
District 2005). Under the ProposalProposal/FEIS Review serves a small single-family residential area on the
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Summary
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Alternative, the Soos Creek sewer service area portion of the southwestern portion of the Kent Planning Areas West Hill.
Kent Planning Area would include approximately 18,800 Under this alternative, this portion of the Lakehaven Utility
households and 7,700 jobs. These are slightly more Districts service area would serve approximately 40 more
households and fewer employees than the district is planning households and 20 more employees than under existing
for in 2030 for the drainage basins that contain Kent Planning conditions.
Area. The districts 2009 Comprehensive Wastewater System Plan
The districts 2005 Comprehensive Sewer Plan identifies a plans for a small population increase of approximately 40
series of capital improvements for the 10-year and ultimate people in the Kent portion of the district service area by 2030.
build-out scenarios to address anticipated population and This represents a similar population increase as anticipated
employment growth and to maintain the sewer system. The under this alternative. The Districts 2009 Comprehensive
district will consider the Citys updated population and Wastewater System Plan includes a project and other
employment projections in future sewer service planning. identified improvements to its wastewater treatment plants and
Lakehaven Utility District Sewer: The Lakehaven Utility to other parts of its distribution system which will allow the
District serves a small single-family residential area on the district to meet the growth anticipated under this alternative.
southwestern portion of the Kent Planning Areas West Hill. Midway Sewer District: The Midway Sewer District serves the
Under the ProposalProposal/FEIS Review Alternative, this Midway Subarea (except for the Kent Highlands property
portion of the Lakehaven Utility Districts service area would located east of I-5) and some surrounding residential
serve approximately 100 more households than under neighborhoods on the West Hill west of I-5. Because the
existing conditions. majority of the Midway Sewer District impacts are related to
As described above, the districts 2009 Comprehensive growth in the Midway Subarea, impact analysis for the district
Wastewater System Plan plans for a small population are found in Table 1-2, under the Midway Subarea below.
increase of approximately 40 people in the Kent portion of the
district service area by 2030. This represents a smaller
increase than anticipated under the ProposalProposal/FEIS
Review Alternative. With the districts planned infiltration and
inflow monitoring project, and other capital improvements
planned, it would likely be able to accommodate the
approximately 85 additional households anticipated under the
ProposalProposal/FEIS Review Alternative.
Midway Sewer District: The Midway Sewer District serves
the Midway Subarea (except for the Kent Highlands property
located east of I-5) and some surrounding residential
neighborhoods on the West Hill west of I-5. Because the
majority of the impacts to the Midway Sewer District occur
within the Midway Subarea, see the Midway Subarea section
for an assessment of the impacts of the
ProposalProposal/FEIS Review Alternative on the Midway
Sewer District.
Stormwater Stormwater
The Kent Stormwater Utility provides service to the City. The Kent Stormwater Utility provides service to the City.
Growth under the ProposalProposal/FEIS Review Alternative Growth under this alternative is expected to result in higher
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September 2011
Alternatives

is expected to result in higher levels of impervious surfaces levels of impervious surfaces than under existing conditions,
than under existing conditions, as vacant land is developed as vacant land is developed over the planning period. As
over the planning period. As impervious surface area impervious surface area increases, there would be a greater
increases, there would be a greater need for stormwater need for stormwater facilities.
facilities to convey and store stormwater flows. Under this alternative, growth would occur principally as
Under the ProposalProposal/FEIS Review Alternative, the commercial or residential development that transforms vacant
greater concentration of new development would occur as land to land covered by buildings, parking lots, and
mixed-use development in taller buildings than under either sidewalks/pedestrian pathways. A larger percentage of growth
existing conditions or the No Action Alternative; this would would occur as lower intensity, single-use development that
place a larger proportion of growth in already developed may occur in relatively less developed areas than the
areas compared to the No Action Alternative. Land use ProposalProposal/FEIS Review Alternative. In addition, larger
designations and zoning regulations are anticipated to areas would be devoted to surface parking lots.
change under the ProposalProposal/FEIS Review Alternative Because a smaller proportion of the development would be
to allow for greater site coverage in the five Activity Centers mixed-use, and because a larger amount of development in
than currently allowed. This would allow areas currently the centers and corridors would rely upon surface lots and
covered by surface parking in these centers and corridors to shorter buildings, it is expected that this alternative would have
be exchanged for areas covered by building, structured a similar, but smaller growth rate in impervious surfaces
parking, and pedestrian facilities such as sidewalks or other compared to the ProposalProposal/FEIS Review Alternative,
pedestrian gathering areas. while accommodating approximately 42% fewer households
New development is currently required to provide manage and 14% fewer jobs than the ProposalProposal/FEIS Review
stormwater conveyance to equivalent standards of the Citys Alternative.
2002 Surface Water Design Manual (a modified version of New development is required to provide manage stormwater
the 1998 King County Surface Water Design Manual). These conveyance to equivalent standards of the Citys 2002 Surface
standards are have been adjusted as needed to meet the Water Design Manual (a modified version of the 1998 King
equivalency requirements of the 2001Washington State County Surface Water Design Manual). These standards are
Department of Ecologys Stormwater Management Manual have been adjusted as needed to meet the equivalency
for Western Washington (2005). The City Stormwater Utility requirements of the 2001Washington State Department of
plans to adopt the Ecology Stormwater Manual in 2011late Ecologys Stormwater Management Manual for Western
2010. Washington (2005). Under this alternative, the Citys
Solid Waste Stormwater Utility would be required to adopt Ecology
The King County 2009 Comprehensive Solid Waste Stormwater Manual during the planning period.
Management Plan anticipates an increase in solid waste Solid Waste
generation, proportionate to the increase in regional Population and employment growth anticipated under this
population. The percentage of solid waste that is diverted to alternative is expected to result in an increase in solid waste
recyclables is expected to grow over the next 20 years as generation over the planning period compared to existing
well, reducing the amount of solid waste that is directed to conditions. However, this alternative anticipates 42% fewer
landfills through solid waste collection and transfer stations. households and 14% fewer employees compared to the
The greater population and employment growth anticipated ProposalProposal/FEIS Review Alternative during the planning
under the ProposalProposal/FEIS Review Alternative is period, resulting in a smaller amount of solid waste generated
expected to result in an increase in solid waste generation compared to the ProposalProposal/FEIS Review Alternative.
over the planning period. The Kent Planning Area under the Based on solid waste generation rate assumptions described
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Summary
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ProposalProposal/FEIS Review Alternative would produce above, the Kent Planning Area is estimated to produce
approximately 146,675 tons of solid waste per year compared approximately 111,898 tons of solid waste under this
to the 52,422 tons of solid waste estimated to be generated in alternative, approximately 34,777 tons less waste than the
the City in 2009. ProposalProposal/FEIS Review Alternative would generate.
3.7 Noise There would be more commercial and mixed use Under this alternative, population and employment growth, in
development in the centers and corridors under this the Kent Planning Area would generate noise from
alternative. Therefore, noise impacts from construction construction activities, commercial facilities, and traffic.
activities and commercial operations are expected to be Impacts would likely be as described under the Impacts
greater under the ProposalProposal/FEIS Review Alternative Common to Both All Alternatives.
than under the No Action Alternative in these areas. As
described under Impacts Common to Both All Alternatives,
the City noise ordinance would prevent the nighttime
construction activities and commercial operations from
causing noise impacts at the existing residences. However,
temporary daytime construction activity is exempt from the
City noise ordinance limits and could cause annoyance and
speech interference at outdoor locations adjacent to the
construction sites and could cause discernible noise for
several blocks from the construction site.
Under the ProposalProposal/FEIS Review Alternative, the
population and traffic volumes would increase more than
under No Action Alternative. Therefore, the number of homes
potentially exposed to traffic noise impacts would likely be
greater under the ProposalProposal/FEIS Review Alternative
than under the No Action Alternative. The potential traffic
noise impacts are described in detail under the Impacts
Common to Both All Alternatives section.
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Summary
Table 1-2. Summary Comparison of Impacts Unique to Each Alternative for Midway Subarea
Alternatives
Topics The Proposal No Action Alternative FEIS Review Alternative
3.1 Natural Environment Under the Proposal, there would be extensive Development under the No Action Impacts under the FEIS Review Alternative
redevelopment in the Midway Subarea. Alternative would occur to a lesser degree would be similar to those of the Proposal for
Development would likely be greater and more than under the Proposal, since there would the natural environment because both
intense under the Proposal than under the No be no additional incentives for alternatives would include the same amount
Action Alternative. Conversion of existing development. Impacts would be as of household and employment growth.
underdeveloped undeveloped land to described in the Impacts Common to Both Growth would be concentrated in the same
development would be greatest on the two All Alternatives section. TOC areas as described under the Proposal,
former landfill areas, since most other portions Midway Planned Action Area including the Midway Planned Action Area
of the Midway Subarea are already developed. (northern TOC) and the southern TOC area.
However, land use conversions in these areas Under this alternative, development or Since these TOC areas and the majority of
would not result in loss of habitat function. redevelopment would occur in the subarea, the remaining Midway Subarea would be
although at a slower rate and at less largely built out with buildings and
Additionally, while some vacant lands would see intensity, than under the Proposal.
new impervious surfaces, development under impervious surfaces dominating the
Development in the former Kent Highlands environment, it is likely that even with
Tthe Proposal would have minimal impacts on landfill site would have minimal impacts on
the limited natural resources of the Midway increases in site coverage standards under
the limited natural resources of the Midway the Proposal or FEIS Review Alternative,
Subarea; with implementation of the Citys Planned Action Area. Some grassy areas
stormwater standards, water quality would be redevelopment of the subarea would replace
of the former Kent Highlands landfill could one type of impervious surface with another,
protected with development of vacant sites and be converted to mixed-use developments,
water quality would improve on redevelopable resulting in little or no additional impervious
but with essentially no loss in habitat surfaces, stormwater volume, or runoff.
properties, since these were originally function since this area provides little
developed without such standards. The ecological function. Because most of the Similar to the Proposal, focus of new
Proposals focus of new development in remainder of this area is developed, there development in the largely built-out Planned
corridors and centers, including the Midway would be little if any other changes in Action Area and other developed areas of
Subarea, avoids impacts on most categories of natural resources associated with this the Midway Subarea would avoid impacts on
environmentally sensitive areas, and in the alternative. most categories of environmentally sensitive
locations where there are environmentally areas; in the locations where there are
sensitive features, critical area regulations environmentally sensitive features, critical
would apply. The Midway Subarea is a largely area regulations would apply.
built-out area with few environmentally sensitive Additionally, while some vacant lands would
areas within its boundaries. see new impervious surfaces, development
Since the Midway Subarea is largely built out in the Midway Subarea would likely have
with buildings, surface parking, and other minimal impacts on the limited natural
impervious surfaces dominating the resources within the Midway Subarea; with
environment, it is likely that even with increases the implementation of the Citys stormwater
in site coverage standards under the Proposal, standards, water quality would be protected
redevelopment of the subarea would replace with development of vacant sites and water
one type of impervious surface with another quality would improve on redevelopable
(i.e., smaller building footprint with surface properties since these were originally
parking replaced by larger building footprint with developed without such standards.
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Summary
Alternatives

much of the parking contained within a Therefore, the FEIS Review Alternative
structure), resulting in little or no additional would have similar or less impact than the
impervious surfaces, stormwater volume, or Proposal on the natural environment.
runoff. Some excavation for construction would
occur, but would not result in a significant loss of
vegetation or soil productivity.
Midway Planned Action Area
Similar to the remainder of the Midway Subarea,
the Proposal would have minimal impacts on the
limited natural resources of the Midway Planned
Action Area. As described above for the former
landfill sites, some grassy areas of the former
Kent Highlands landfill could be converted to
mixed-use developments, but with essentially no
loss in habitat function, and as the sites are
highly altered. Because most of the remainder
of this portion of the Midway Subarea is
currently developed, there would be little if any
other changes in natural resources associated
with the Proposal.
3.2 Air Quality Under the Proposal, the Midway Subarea is Under this alternative, the Midway Subarea Impacts under the FEIS Review Alternative
expected to experience greater population and would still experience gradual growth. would be similar to those under the Proposal
employment growth than under the No Action Development under this alternative would for air quality because both alternatives
Alternative, especially in the Midway Planned still lead to smaller increases in population would include the same amount of
Action Area. Development under this alternative and employment than under the Proposal, household and employment growth which
would result in a greater increase in localized air and could increase localized air pollutant would generate a similar level of air quality
pollutant emissions from construction activities emissions from construction activities and impact.
and commercial activities and regional tailpipe commercial activities, and increase regional
emissions from vehicle travel. Regardless, the vehicle travel and tailpipe emissions.
air quality impacts under the Proposal for the Therefore, the air quality impacts under this
Midway Subarea and the smaller Planned alternative for the Midway Subarea would
Action Area would be the similar to those be the same as those described for the
impacts described for the Kent Planning Area. Kent Planning Area.
Midway Planned Action Area Midway Planned Action Area
The Midway Planned Action Area makes up the Impacts on air quality would be the same
majority of the transit-oriented development for both the Midway Subarea and the
(TOD) found within the Midway Subarea under smaller Planned Action Area within it under
the Proposal. Therefore, net reductions in GHG the No Action Alternative.
emissions within the overall Midway Subarea
shown in Table 3.2-8 of the DEIS would mostly
be attributed to the Planned Action Area.
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Otherwise impacts on air quality would be the
same for both the Midway Subarea and the
smaller Planned Action Area within it.
3.3 Land Use/Plans and Land Use Patterns Land Use Patterns The FEIS Review Alternative would result in
Policies Under the Proposal, the Midway Subarea would Under this alternative, the Midway Subarea a similar, but less intense impact on land use
experience a transformation from a largely auto- would experience lower amounts of patterns and plans and policies as the
oriented commercial area with small amounts of development and redevelopment than Proposal for the Midway Subarea. Although
residential to a high intensity, mixed-use, under the Proposal. Development would the City was considering various options for
pedestrian-oriented center for housing and not be guided by the Midway Subarea Plan zoning maps and development regulations in
employment. This transformation would be and associated Comprehensive Plan and the Midway Subarea, the Proposal was
facilitated by high capacity transit investments zoning amendments, making the primarily based on draft Midway Subarea
along and in the vicinity of SR 99 from Seattle- development generally more auto-oriented Plan goals and policies and draft Midway
Tacoma International Airport south to Federal and/or single-use commercial than Design Guidelines. The FEIS Review
Way. anticipated under the Proposal. There Alternative would include updates of both of
would be very little residential development these documents, as well as a draft zoning
Under the Proposal the Midway Subarea would map and draft development regulations that
grow by approximately 9,640 more households under this alternative in the Midway
Subarea compared to the Proposal. implement the goals and policies contained
and 5,760 more jobs than anticipated under the in the draft Midway Subarea Plan. As such,
No Action Alternative. Under the Proposal, the Under the No Action Alternative, the the FEIS Review Alternative would provide a
Midway Subarea would have more households Midway Subarea would accommodate an more detailed review of potential land use
than Downtown and approximately 3,000 fewer estimated 1,540 additional jobs and 260 impacts in the Midway Subarea.
jobs than Downtown. households compared to base year
conditions, approximately 5,760 fewer jobs Land Use Patterns
New employment under the Proposal resulting
from redevelopment of the Midway Subarea is and 9,640 fewer households than The FEIS Review Alternative would provide
expected to be more transit- and pedestrian- anticipated under the Proposal. Although a greater flexibility for transitioning existing
oriented retail, services, and office. Commercial small amount of mixed use development land uses to those envisioned under the
light-industrial uses would be found outside the would occur under this alternative in the Midway Subarea Plan by allowing a slightly
TOCs within the Midway Subarea. This Kent Highlands, more of the new jobs wider range of uses within the zoning
transformation would be particularly noticeable would be single-use commercial districts that implement the TOC
in TOCs within the Midway Subarea. Existing developments that would tend to be more Comprehensive Plan designation in the
auto-oriented commercial development within auto-oriented than the Proposal. Midway Subarea, and by eliminating the
these areas would largely be replaced by mixed- Development form and intensity within the Proposals requirement for a minimum of two
use development and stand alone commercial Midway Subarea under this alternative stories in height for new development within
uses while a modest amount of new auto- would tend to be shorter buildings, and the TOC designation. The FEIS Review
oriented development would occur in the portion more auto-oriented development with a Alternative would also eliminate maximum
of the Midway Subarea designated for continued greater amount of surface parking lots. on-site parking standards included as part of
auto oriented commercial development. Overall, a smaller amount of existing the Proposal for the Midway Subarea. The
development would be transformed into net effect of these changes to land uses and
Under the Proposal, amendments to the Zoning development standards that allow for
Districts map would be made to rezone the new development under this alternative.
flexibility in uses would be that existing land
current mix of GC, M1, and O designated Midway Planned Action Area uses and development types in the TOC are
properties located along SR 99 to CM-2 in the Because of its proximity to the planned high likely to remain longer and provide a longer
subarea outside the Comprehensive Plan Land capacity transit stations and service along timeframe for transition to the more intense
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Summary
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Use Plan map designation of TOC. and in the vicinity ofon SR 99, Highline mixed-use development types envisioned for
Overall development within the Midway Subarea Community College, and the transformation the Midway Subarea.
under the Proposal would consist of taller potential of the Kent Highlands area, a The FEIS Review Alternative would also
buildings, particularly in the northern portion of larger portion of the Midway Planned Action provide a finer detail of implementing zoning
the subarea, north of S 246th Street, east of SR Area would be transformed by development for the Midway Subarea by specifying zones
99, and near SR 516 on both sides of I-5 and redevelopment under the this with lower heights along SR 99 in the north
compared to both existing conditions and the No alternative compared to the Midway and south TOC designations (MTC-1 zone).
Action Alternative. In addition, these same areas Subarea as a whole. The Midway Planned These lower maximum heights would
would be transformed with larger building Action Area grows far less under the No provide a transition to lower intensity
coverage as setbacks are reduced and parking Action Alternative than the Proposal (just residential zones to the west in Des Moines,
contained within structures rather than found in over 1,0001,100 more jobs and about 130 and would also allow for a more consistent
surface parking lots that currently separate more households than existing conditions). scale of development on both sides of SR 99
buildings from the street. Furthermore, However, the Midway Planned Action Area whether the development is in Kent or Des
development and redevelopment particularly in would accommodate approximately 72% of Moines. The zones with taller maximum
the TOCs north of S 246th Street and near the S the new commercial development and 49% heights (MTC-2 and MCR) would be located
272nd Street intersection, as well as the Kent of new residential development anticipated in areas where they have natural or human-
Highlands area would transform large auto- in the overall subarea under this created buffers to existing surrounding
oriented superblocks that currently characterize alternative. However, tThere would be development, such as topography (e.g., the
the Midway Subarea into a more circulation approximately 8,000 fewer households and hillside between Midway and the Green
system with smaller block sizes and/or 5,530 fewer jobs in the Midway Planned River Valley), wide right-of-way (e.g.,
pedestrian and bicycle linkages that break up Action Area under this alternative Interstate [I]-5 and SR 516), and
larger blocks. compared to the Proposal. undevelopable areas of former landfills. In
Midway Planned Action Area Development in the Midway Planned Action addition to the MTC-1 zone having a lower
Area would tend to be more auto -oriented maximum height, it includes provisions for
The Midway Planned Action Area would exclude and single-use commercial development transitional height limits for development
areas designated for continued auto-oriented than anticipated under the Proposal with located adjacent to residential zonesin this
development south of S 246th Street and the more area taken up by surface parking lots. case, residential zones located to the west in
small TOC near S 272nd Street. The Midway Residential development would tend to be the City of Des Moines, Kent residential
Planned Action Area is anticipated to be less dense and lower-scale than districts located east of the southern TOC,
transformed into an even more intensive, mixed- development under the Proposal. and at two locations abutting the MHP
use pedestrian-oriented center for housing and residential district.
employment under the Proposal than the
Midway Subarea as a whole, taking advantage In addition, the proposed Midway Design
of the subareas proximity to the planned high- Guidelines would be applicable to the TOC
capacity transit station location near the areas. The preliminary draft Midway Design
adjacent in the vicinity of Highline Community Guidelines used to review the Proposal
College. included guidelines that addressed the siting
of buildings and the transition between
The Midway Planned Action Area would residences, street, and adjacent sites under
accommodate approximately 82% of new the Site Design category, as well as height,
households anticipated in the Midway Subarea. bulk, and scale under the Architectural
The amount of concentrated multifamily and Design category. These guidelines have
mixed-use development in the Midway Planned been updated since the Proposal and the
Action Area would create a larger a residential guidelines addressing transition between
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September 2011
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population than that found in Downtown. The newer and taller buildings and existing, less
Midway Planned Action Area would intense uses and zones would help mitigate
accommodate about 90% of the new jobs some of the impacts of more intense uses
anticipated in the Midway Subarea under the and buildings on neighboring land uses. See
Proposal. Existing auto-oriented commercial the aesthetics analysis below for more
development in the Midway Planned Action description of the Midway Design
Area would almost entirely be replaced by Guidelines.
pedestrian oriented retail, service, and office The overall effect of the changes to zoning
commercial uses that support and are supported and development standards considered
by the intense concentration of households in under the Proposal, and implementation of
the area, and the high capacity transit more detailed zoning designations and
investments made along and in the vicinity of amended Midway Design Guidelines would
SR 99. Commercial or residential development be to provide for slightly less land use
would either be part of a mixed-use pattern impact under the FEIS Review
development, or stand alone development. Alternative than under the Proposal.
Development within the Midway Planned Action
Area under the Proposal would consist of taller
buildings with greater site coverage than found
in either existing conditions or the No Action
Alternative. With the notable exception of areas
in the Kent Highlands designated for passive
open space and less intense uses, the majority
of vacant, and surface parking areas, and auto-
oriented uses in the Midway Planned Action
Area would be transformed into compact
buildings or structured parking under the
Proposal. The Proposal would also include
smaller blocks and/or more frequent pedestrian
and/or bicycle connections throughout the
Midway Planned Action Area to facilitate use of
nonmotorized modes of transportation and
access to the planned transit light rail station
along in the vicinity of SR 99.
Under the Proposal, the Comprehensive Plan
Land Use Plan map designations would be
changed from the current mix of designations to
either a new or existing transit-oriented
Comprehensive Plan Land Use Plan map
designation. A subsequent Zoning Districts map
amendment would also be made to rezone the
Midway Planned Action Area to a transit-
oriented zoning district in keeping with the new
Comprehensive Plan Land Use Plan map
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Summary
Alternatives

designation.
Plans and Policies Plans and Policies Plans and Policies

Consistency with plans and policies for the Under this alternative, lower-intensity, With respect to plans and policies, the FEIS
Midway Subarea Plan would be similar to that of single-use commercial oriented Review Alternative would provide a phased
the Activity Centers described under the Kent development would be occurring in approach to implementing the Midway
Planning Area above. Under the Proposal, the proximity to the high capacity transit Subarea Plan. Because of changes to
Midway Subarea Plan (Appendix C) would be investments within the Midway Subarea economic conditions and the planned delay
adopted as part of the Citys Comprehensive rather than the more efficient development in implementing Sound Transits light rail
Plan. pattern supporting transit as included under service in the Midway Subarea, the City
Growth Management Act and King County the Proposal. The type of growth would plan for a lower level of growth within
Countywide Planning Policies: The Midway anticipated under this alternative would be the Midway Planned Action Area and the
Subarea Plan concentrates households and inconsistent with the Citys goals and Midway Subarea as a whole for the first 10-
employment into areas with facilities and policies related to growth of housing and year period (Phase 1). This level of growth is
services to serve the new development, and by jobs within Activity Centers and in proximity expected to be similar to that anticipated
contrast protects environmentally sensitive to high capacity transit investments. under the No Action Alternative. The higher
areas as called for in both the GMA and CPPs. Growth Management Act and King levels of growth anticipated under the
County Countywide Planning Policies: Proposal would occur under the second 10-
In particular, planning additional growth near year period (Phase 2). The same or similar
future high-capacity transit investments in the Although development anticipated under
this alternative would contribute to growth amendments to the Comprehensive Plan
subarea is consistent with GMA and CPP goals and implementing zoning and development
relating to focusing growth in urban areas with in urban areas and areas where
infrastructure is available to meet standards required under the Proposal
adequate services, encouraging efficient would be required as part of the FEIS
multimodal transportation systems, and development, the No Action Alternative
would provide a small fraction of Review Alternative. However, amendments
requiring adequate public infrastructure to to implement these changes would occur
support planned development. development in proximity to high capacity
transit investments along and in the vicinity over a longer period, and would likely be
The Proposal would support the Citys overall of SR 99, resulting in a lost opportunity to coordinated with the next update to the
plan to accommodate growth targets for 2031, concentrate growth as described in state Transportation Master Plan and complete
consistent with both the GMA and CPPs. In and county policies. Comprehensive Plan update required by the
addition, the Proposal for the Midway Subarea GMA.
includes goals and policies intended to Comprehensive Plan
encourage housing that supports a full range of Land Use Element. The No Action
incomes, including promotion of affordable Alternative is inconsistent with the Citys
workforce housing. goals and policies as relates to future
The Proposal would be consistent with the development in commercial areas located
CPPs relating to community character and open in proximity to high capacity transit. In
space since the Midway Subarea Plan includes particular, this alternative does not adopt
goals and policies addressing site and building the Midway Subarea Plan, inconsistent with
design, as well as implementing design Policy LU-14.1 calling for development of
guidelines. subareas for Activity Centers. The No
Action Alternative also retains the
Comprehensive Plan predominately single use commercial land
The Proposal for the Midway Subarea would be use designations and zoning along the
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September 2011
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generally consistent with the Citys majority of the Midway Subarea including
Comprehensive Plan goals and policies. areas proximate to future high capacity
Land Use Element. The Proposal for the transit investments. This is inconsistent
Midway Subarea is consistent with City Land with Goals LU-6 and LU-7 and associated
Use goals and policies particularly related to policies relating to identifying and
designation of Activity Centers in commercial designating Activity Centers in areas that
areas of the City to allow a mix of retail, office, currently contain concentrations of
and residential development (Goal LU-6) and to commercial development and intensifying
facilitate pedestrian, public transit, and vehicular them to support public transit and increase
circulation (Goal LU-7). Because the Midway housing opportunities.
Subarea is also slated for high capacity transit Housing Element. This alternative is
investments, the Midway Subarea Plan and inconsistent with housing goals and policies
implementation is also consistent with Activity relating to supporting development of new
Center policies that promote development housing near transportation hubs (Policy H-
proximate to transit, and development types that 2.4), and housing opportunities including
support transit investments. Examples of these affordable housing opportunities in mixed-
policies are found in Section 3.3, Land use settings throughout the City (Policy H-
Use/Plans and Policies of the DEIS. 5.4).
Under the Proposal, the City would adopt the Transportation Element. Although growth
Midway Subarea Plan, incorporating it as part of under this alternative is expected to be
the Citys Comprehensive Plan, consistent with consistent with transportation
Policy LU-14.1, calling for development of improvements needed under the Citys
subarea plans for Activity Centers. existing Transportation Master Plan (and
The Proposal includes adoption of policies existing Transportation Element), this
supportive of creating high quality aesthetics alternative is inconsistent with City
and designing a quality pedestrian environment transportation goals and policies that
consistent with Comprehensive Plan Goal LU-8. promote multimodal transportation facilities
The Midway Subarea Plan also provides and services, as well as nonmotorized
opportunities for residential development to connections and improvements in proximity
occur within an existing business district that will to transit facilities. Despite implementation
provide support for shops, services, and of high capacity transit improvements on
employment within walking distance, consistent and in the vicinity of the SR 99 corridor, the
with Comprehensive Plan Policy LU-14.2. land use under this alternative for the
Midway Subarea does not encourage
The Midway Subarea Plan goals and policies development and use of alternatives to the
(Appendix C) are consistent with the Citys single-occupancy vehicle.
Comprehensive Plan goals and policies. In
particular, the Proposals Midway Subarea Plan Economic Development Element. The No
includes goals and policies to address parking Action Alternative does not promote new
policies in areas with high capacity transit housing development in proximity to
consistent with Policy LU-20.5. planned high capacity transit services (ED-
2.3), nor does it encourage mixed-use
Housing Element. The Proposal is consistent zoning to provide opportunities for
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Summary
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with housing goals and policies of the City residential use in commercial areas as
Comprehensive Plan, particularly those described in Policy ED-3.5. Although this
supporting development of housing near alternative does anticipate growth in the
transportation hubs and employment centers. Midway Subarea, it does not provide as
The Proposal is also consistent with goals and much growth or mix of uses as found in the
policies encouraging housing, including Proposal, and thus, provides less
affordable housing, in mixed-use development opportunity for economic development
in and commercial settings throughout the City. along the anticipated high-capacity transit
Transportation Element. The Proposal is light rail line on in the vicinity of SR 99.
consistent with City goals and polices of the Midway Planned Action Area
Transportation Element. In particular, the The Midway Planned Action Area is the
Proposals focus on providing a concentrated area with the most vacant and
mix of residential and commercial development redevelopable land closest to planned high
in proximity to planned high capacity transit capacity transit improvements and a nearby
stations is consistent with a number of regional institution (Highline Community
Transportation goals and policies. College) within the overall Midway
However, the Citys Transportation Element Subarea. As such, the Midway Planned
would need to be amended as described in Action Area would have a higher level of
Section 3.5, Transportation of the DEIS, to inconsistency with City Comprehensive
account for additional transportation Plan goals and policies related to growth of
improvements necessary to meet City housing and jobs within Activity Centers
concurrency standards. and in proximity to transit. It would also
Economic Development Element. The have a higher level of inconsistency with
Proposal for the Midway Subarea would be City Comprehensive Plan goals and
consistent with the Citys Economic policies related to protection of existing
Development Element since the Proposal would single-family residential neighborhoods and
encourage additional housing and job growth in preservation of environmentally sensitive
concentrated areas proximate to future high areas than other parts of the Midway
capacity transit investments. Subarea.

The Midway Planned Action Area focuses
household and job growth in a transit oriented
node and an area that has been identified as a
redevelopment opportunity proximate to the new
transit investments along and in the vicinity of
SR 99. The Midway Subarea Plan includes
goals and policies that are consistent with and
supportive of the Citys Comprehensive Plan
and the more general goals of GMA and the
CPPs.
Transit investments along and in the vicinity of
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the SR 99 corridor and the completion of reuse
land use plans for the Kent Highlands Landfill
provide the basis for the Citys plans for the
Midway Planned Action Area. These actions
allow the City to develop revisions to the
Comprehensive Plan Land Use Plan map,
Zoning Districts map, and policies and zoning
regulations that will expand capacity in the
Midway Planned Action Area in particular. In
addition, the Midway Planned Action Area is
consistent with Policies LU-6.1 and LU-9.4, and
Goal LU-7 related to encouraging high-intensity
development in centers located close to high-
capacity transit noted above. This concentration
of growth also supports Policy H-2.4 related to
developing housing near transportation hubs,
and policies ED 2.3 and ED-3.3 related to
investment of a mix of housing and employment
opportunities in proximity to transit.
The Midway Planned Action Area would also be
the most consistent with Policy LU 20.5 for an
area that would include reduced parking ratios
in proximity to intermodal transit/commuter
facilities, given the geographic location in the
vicinity of high capacity transit investments.
By concentrating approximately 32% of new
housing and 19% of new jobs from the overall
planned growth for the Kent Planning Area in
the Planned Action Area within proximity to high
capacity transit investments, this allows the City
to accomplish other Comprehensive Plan goals
of preserving existing residential neighborhoods
(Policy H-2.1) and protecting environmentally
sensitive areas (Goal LU-23) in other parts of
the Kent Planning Area.
3.4 Aesthetics Visual Character Visual Character: Future development The FEIS Review Alternative relies on drafts
Under the Proposal, the portion of the Midway under this alternative is likely to continue to of implementing zoning maps and
Subarea south of the Midway Planned Action be auto-oriented, with a proliferation of big- development regulations, as well as updated
Area would primarily redevelop as an auto- box retail and strip-style shopping centers. drafts of the Midway Subarea goals and
oriented commercial and light industrial corridor, While infill development would eventually policies and Midway Design Guidelines used
which would continue the traditional function of convert most of the vacant parcels within to create the Proposal. Overall,
the subarea, density would remain implementation of the FEIS Review
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commercial development along SR 99. The relatively low, changing little from the Alternative would have less impact on height
uses in this portion of the subarea would be current visual character. and bulk and solar access/shading condition
similar to existing conditions, though density is Height and Bulk: Maximum building issues than the Proposal, in which a
anticipated to increase as properties redevelop heights would remain the same as current maximum height of 200 feet was considered
to accommodate future growth. The primary regulations under this alternative. At throughout the TOC designations for the
change that would occur to visual character present, maximum heights range from 30 Midway Subarea.
under the Proposal is the implementation of feet to 40 feet in the subarea. Development The FEIS Review Alternative would include
urban design policies and design guidelines that in the Midway Subarea is generally lower three Midway Subarea zones to implement
would require more human-scaled architectural than these allowed maximums, with the the Midway Subarea Plan. One zone, the
design. exception of the intersection of SR 99 and MTC-1, applied on both sides of SR 99 in
This alternative would also integrate portions of SR 516, which features several three-story the northern TOC and throughout the
the area between S 260th Street and S 268th buildings, though these are located southern TOC, would provide a lower
Street as part of the subareas open space adjacent to the subarea in Des Moines. maximum height than considered in the
framework, incorporating the wetlands and other Over time, redevelopment in the subarea DEIS. The MTC-1 zone would allow a
critical areas outside the subarea boundaries on would result in a greater number of maximum height of 55 feet per five stories
the east side of SR 99 as open space elements buildings achieving the maximum allowed rather than the 200 feet per 16 stories
and providing a link between development building height, but this would constitute a maximum height considered in the DEIS.
inside the subarea and the West Hill relatively minor increase over existing This would provide a transition between
neighborhood immediately to the east. As this conditions. Under this alternative, no sensitive uses, such as between lower
portion of the subarea is currently minimally significant height or bulk impacts are intensity residential uses found west of the
developed because of the presence of these anticipated. Midway Subarea in the City of Des Moines
critical areas, changes in visual character in this Pedestrian Environment: Under this and the MTC-2 zone, as well as provide for
portion of the subarea are anticipated to be alternative, the current auto-oriented lower maximum heights in the southern TOC
minimal. development pattern would continue. This than considered under the Proposal. In
The southern end of the subarea, centered on alternative would likely see a further decline addition to the lower maximum height, the
the intersection of SR 99 and S 272nd Street, in the quality of the pedestrian experience development regulations for the MTC-1 zone
would redevelop as a secondary TOC, similar to as growth generates additional vehicular would include provisions for transitional
the one proposed for the intersection of SR 99 traffic along SR 99 without providing height limits for development located
and SR 516, though covering less area. Visual additional pedestrian buffers or amenities. adjacent to residential zones. The stepped
character is anticipated to be similar to the TOC height limits create a more gradual transition
Scenic Views: Views from public rights-of- between the SR 99 corridor and the lower
in the Midway Planned Action Area, though way in the Midway Planned Action Area are
slightly less intense. As discussed in the intensity residential zones located along the
mostly fragmentary, often screened by western boundary of the Midway Subarea
analysis of the Midway Planned Action Area, intervening topography, vegetation, or
compared to the current visual character of the where the MTC-1 abuts Des Moines
existing development. However, strong residential zones, as well as adjacent to
intersection, implementation of the Midway views of the Cascades are available in the
Subarea Plan would create a more aesthetically residential districts east of the southern TOC
former Kent Highlands Landfill area, and area, and at two locations abutting the MHP
pleasing visual character, and with the views of Mount Rainier and Puget Sound
implementation of mitigation in the form of the residential district. Overall, aesthetic impacts
are available at topographically high points related to height and bulk and shade and
Subarea Plans incorporated design guidelines, along SR 99 north of S 240th Street
no significant impacts on visual character are shadow would be less intense than those
resulting from the presence of vacant land described under the Proposal for the MTC-1
anticipated. and surface parking lots. Building heights zone.
Midway Planned Action Area: Under this and site coverage would not increase over
The other implementing zones within the
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alternative, future development along SR 99 current limits under this alternative, and Midway Subareas northern TOC, the MTC-
would be designated a TOC, while the area heights would increase by no more than 2, and the MCR zones, would retain a
northeast of the intersection of SR 99 and SR one story over existing conditions. While maximum height of 200 feet per 16 stories,
516 would be designated with a mixed use future development in the area would have which is similar to what was considered
designation. Over time, the TOC would the potential to block these existing views, under the Proposal in the DEIS. Topographic
redevelop as a high-intensity center combining future uses would be commercial in nature (e.g., slopes) and built environment (e.g.,
residences and a mix of commercial, office, and and similar to the current businesses, interstate and state highways) features
neighborhood service uses. Large areas of which are surrounded by large parking would provide transitions between the MTC-
surface parking would be discouraged in favor areas. As such, no impacts on scenic views 2 and MCR zones and most areas abutting
of transit connections, and block sizes would be are anticipated. less intense zones.
reduced to facilitate walking. The Midway Light and Glare: Additional growth in the The FEIS Review Alternative would also
Subarea Plan contains a collection of urban Midway Subarea would introduce new maintain the existing MHP zone on mobile
design goals and policies that call for sources of light and glare, such as home parks in the Midway Subarea. These
implementation of human-scaled architectural increased numbers of automobiles, and include existing sites abutting or surrounded
design to maintain the TOC as a desirable place additional exterior illumination for buildings. by the MTC-1, MTC-2 and CM-2 zones.
for pedestrians. The plan also calls for the The Kent Highlands area would be MHP property owners that are within the
inclusion of a network of parks, plazas, and particularly impacted by increases in TOC Comprehensive Plan designation
open spaces to provide opportunities for illumination, as this area is currently would be able to request a rezone to another
exercise, relaxation, and social interaction. developed at a very low intensity. However, zoning designation applied within that
Compared to the current visual character of SR given lower level of redevelopment Comprehensive Plan designation. It is likely
99, which lacks human-scaled architectural anticipated under this alternative, there that existing mobile home parks located
design, parks and recreation space, or block would be little increase in illumination. As within or adjacent to the MTC-1 zone would
sizes that allow for a comfortable pedestrian such, light and glare impacts under this be able to rezone to that designation, and
experience, implementation of the Midway alternative are anticipated to be less than those located within or adjacent to the
Subarea Plan would create a more aesthetically significant. MTC-2 zone would be able to rezone to that
pleasing visual character for this portion of the zoning designation, resulting in similar height
Midway Planned Action Area. Solar Access/Shading Conditions: As
building heights under this alternative and bulk, and solar access and shading
In contrast to the TOCs residential/employment would increase only slightly over existing impacts as described for the MTC-1 and
focus, the Kent Highlands mixed-use area would conditions, no significant impacts MTC-2 zones.
be slightly more accommodating of auto- associated with shading or solar access are Midway Design Guidelines are applicable to
oriented uses and a mix of residential and anticipated over the long term. all zones within the Midway Subarea TOC
community retail. While still a primarily designation. The FEIS Review Alternative
pedestrian-oriented district, this area would not would provide amendments to some of these
have such strong transit connections, though design guidelines that would further
the same urban design, parks, and streetscape encourage transitions from lower intensity
policies and guidelines would apply, producing a uses and residential zones to new
similar visual character as seen in the TOC. development within the Midway TOC zones
Existing conditions in this portion of the Midway (MTC-1, MTC-2, and MCR). These design
Planned Action Area, however, are far less guidelines call for building design that
commercially oriented than along SR 99. The considers adjacent, lower-intensity zoning
Kent Highlands area is currently far less districts that may be affected by high-
developed than the SR 99 corridor and provides intensity development. Design guidelines
for some open space, though the area is excerpted in Chapter 3 of the FEIS are
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alteredretains far more of its natural character. applicable to height and bulk and solar
As such, high intensity development of the kind access/shading impacts. Implementation of
proposed under the Midway Subarea Plan these design guidelines within the MTC-1,
would have the potential to significantly MTC-2, and MCR zones would help provide
transform the visual character of this area. transitions between proposed tall buildings,
Height and Bulk adjacent lower intensity residential zones,
and, to a lesser extent, adjacent and nearby
In the portion of the Midway Subarea south of lower intensity residential uses. Application
the Midway Planned Action Area and north of S of these Midway Design Guidelines,
268th Street, maximum building heights would including in zones within the TOC with a
increase to approximately 50 feet, which is a 200-foot maximum height, would make the
moderate increase over the current limit of aesthetics impacts associated with height
remain at 35 feet. With the implementation of and bulk and solar access and shading
design guidelines, no height and bulk impacts conditions slightly less intense than those
are anticipated. Furthermore, administrative anticipated under the Proposal for the
approval of one additional story above the 35- Midway Subarea.
foot height limit would still be allowed.
Therefore, no height and bulk impacts are Under the FEIS Review Alternative, impacts
anticipated under the Proposal as compared to on other aesthetic elements including visual
the No Action Alternative. character, pedestrian environment, scenic
views, and light and glare would be similar to
Maximum heights at the secondary TOC at the the Proposal.
intersection of SR 99 and S 272nd Street would
increase to approximately 200 feet, which is a
substantial increase over the current limits.
However, the Midway Subarea Plan includes a
set of integrated design guidelines focused on
the reduction of visual bulk at street level and
compatibility between the subarea and less
intense adjacent development such as single-
family residences. With mitigation incorporated,
height and bulk impacts are anticipated to be
less than significant.
Midway Planned Action Area: Under the
Proposal, building heights in the Midway
Planned Action Area would be a minimum of
two stories, upincrease to a maximum of
approximately 200 feet, which is a substantial
increase over the current maximum heights.
According to City staff, the tallest buildings (up
to 15 stories) would be found in the area
between S 240th Street and S 246th Street and
in the Kent Highlands area east of I-5 (Gould-
Wessen pers. comm.). The remainder of the
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Midway Planned Action Area would consist of a
mix of building heights in the five- to six-story
range with taller buildings interspersed
throughout. Such an increase in heights has the
potential to introduce a canyon effect for
pedestrians at street level without mitigation.
The Proposal uses areas of lower height to
provide buffers between tall buildings and
sensitive areas, such as parks, open space, and
defined pedestrian corridors (Gould-Wessen
pers. comm.). The Midway Subarea Plan
includes a set of integrated design guidelines
focused on the reduction of visual bulk at street
level and compatibility between the subarea and
less intense adjacent development such as
single-family residences. With mitigation
incorporated, height and bulk impacts are
anticipated to be less than significant.
Under the Proposal, pedestrian environment
conditions in the Midway Subarea are
anticipated to be similar to the Midway Planned
Action Area. No significant adverse impacts
would occur.
Midway Planned Action Area: Under the
Proposal, no significant adverse impacts are
anticipated to the pedestrian environment. At
present, the Midway Planned Action Area
provides minimal pedestrian infrastructure;
blocks are large, sidewalks are frequently
interrupted by curb cuts, transit stops are not
sheltered from the elements and no on- street
parking or landscaping isare present to buffer
pedestrians from the adjacent highway. There
are no curbs, gutters, or sidewalks along 30th
Avenue. Under the Proposal, a set of design
guidelines focused on enhancement of the
pedestrian experience would be implemented,
which would encourage new development to
provide pedestrian amenities such as seating,
weather protection, and human-scaled lighting.
Over time, this would result in a pedestrian
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environment in the Midway Planned Action Area
that is more similar to the historic core of
Downtown, focused on social interaction and
use of public transit.
Scenic Views
As fewer views are available in the portion of the
Midway Subarea south of the Midway Planned
Action Area, and building heights would not
increase as dramatically differ from what is
allowed by existing regulations, impacts on
scenic views under the Proposal are anticipated
to be less than significant with the application of
proposed design guidelines. Impacts on views
would be greater in the secondary TOC at S
272nd Street, though the increase in building
heights would create territorial views that are not
currently available at this location.
Midway Planned Action Area: Views from
public rightsof-way in the Midway Planned
Action Area are mostly fragmentary, often
screened by intervening topography, vegetation,
or existing development. However, strong views
of the Cascades are available in the former Kent
Highlands Landfill area, and views of Mount
Rainier and Puget Sound are available at
topographically high points along SR 99 north of
S 240th Street. The large increase in heights
under the Proposal has a high potential to block
these public views, though such development
would increase the availability of private views.
The Community Design Element of the
comprehensive plan calls for the preservation of
views from public rights-of-way and public areas
to the greatest extent practicable. Though the
Midway Subarea Plan contains design
guidelines that call for upper-story setbacks to
take advantage of views, it does not address
view preservation in the same detail as it does
architectural design or pedestrian amenities. As
a result, additional mitigation should be
considered to prevent significant impacts on
scenic views in the Midway Planned Action
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Area, such as the definition of protected public
view corridors and the implementation of
measures to provide viewpoints from public
areas reduced height limits in locations where
higher topography provides views of scenic
visual resources.
Light and Glare
Additional growth in the Midway Planned Action
Area would introduce new sources of light and
glare, such as increased numbers of
automobiles, additional exterior illumination for
buildings, and new street lighting. The Kent
Highlands area would be particularly impacted
by increases in illumination, as this area is
currently developed at a very low intensity. The
Midway Subarea Plan includes a set of design
guidelines focused on limiting glare and light
pollution in the TOC areas. With the
implementation of these guidelines, light and
glare impacts are anticipated to be less than
significant in the TOC areas.
Lighting conditions in the remainder of the
Midway Subarea are anticipated to be similar to
the Midway Planned Action Area what presently
exists. Furthermore, Kent City Code
(15.08.050.A. and D.4 and 15.05.090.E.)
regulates impacts from lighting and glare.
Therefore With mitigation, light and glare
impacts are anticipated to be less than
significant in this area under the Proposal.
As heights along the highway commercial
corridor portion of SR 99 would only moderately
not increase over current limits, the application
of design standards included in the Midway
Subarea Plan should be sufficient to reduce
shading impacts to less than significant levels
and from the No Action Alternative, no
significant impacts associated with shading or
solar access are anticipated over the long term
in this area.
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The S 272nd Street TOC would experience an
increase in shading conditions due to
anticipated increases in building heights. Side
streets and pedestrian pathways that form
connections between developments are most
likely to be adversely affected by this increase.
To mitigate these impacts, the City should
consider the implementation of additional design
guidelines focused on the preservation of solar
access, as discussed under the Midway
Planned Action Area.
Midway Planned Action Area: In urban
environments, solar access and shading
conditions are intrinsically linked to building
height and bulk. As building heights in the
Midway Planned Action Area would be greatly
increased over current limits, the potential for
shading impacts is high. The areas of greatest
concern for shading impacts in the Midway
Planned Action Area are south of S 240th
Street, where buildings up to 15-stories in height
are planned in close proximity to areas depicted
as open space and pedestrian pathways in the
Midway Subarea Plan. Additionally, 15-story
construction planned immediately north of S
240th Street could potentially shade elements of
the open space framework, including a
proposed park.
The Proposal includes draft design guidelines
for the Midway Subarea TOC areas that require
upper story setbacks after the third and sixth
floors of a building, which will reduce shading
impacts at street level, but even with the
application of these standards guidelines, solar
access will be reduced compared to the No
Action Alternative. SR 99 will be the least
affected street frontage, due to its width and
north-south orientation, as well as lower
proposed height limits, but side streets and
pedestrian/bicycle pathways have a high
potential to be impacted, particularly during
winter months, when the sun in lower in the sky
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and casts longer shadows.
To ensure that solar access is preserved in
public gathering spaces, such as parks and
plazas, and that high-intensity development in
the Midway Planned Action Area does not
adversely affect adjacent lower-intensity
residential neighborhoods and public spaces,
including that anticipated within the subarea, as
well as any areas on the edges (including the
City of Des Moines) the City should consider the
implementation of additional design guidelines
related specifically to parks, public gathering
spaces, pedestrian/bicycle paths, and complete
streets.
3.5 Transportation Street System Impacts Street System Transportation impacts of the FEIS Review
The Transportation section projected 2031 LOS The No Action Alternative reflects the TMP, Alternative would be similar to those of the
for the following five key intersections along the which assumes a transportation network Proposal because both alternatives would
SR 99 corridor under the Proposal, with the that meets the Citys roadway LOS criteria include the same amount of household and
TMP projects assumed in the No Action under its existing population and employment growth. Amendments to
Alternative in place: employment growth assumptions for all Midway Subarea goals and policies related
intersections along SR 99. The results of to transportation would also provide further
SR 99/SR 516 refinement of the policy direction that the
an operations analysis of the five key
SR 99/S 240th Street intersections along this corridor under the City is moving toward in the Midway
SR 99/S 252nd Street No Action Alternative are summarized in Subarea, supporting the transportation
analysis and impacts described under the
SR 99/S 260th Street Table 3.5-10 found in Section 3.5,
Transportation of the DEIS. Proposal. Although the proposed
SR 99/S 272nd Street transportation improvements needed for
Analysis shows that all five of the key Bicycle, Pedestrian, and Transit mitigation under the FEIS Review Alternative
intersections along the SR 99 corridor would Facilities are the same as considered under the
have LOS F operations with greater overall The TMP identifies a system that would Proposal, the phased growth under the FEIS
delays than No Action Alternative. help meet future bicycle, pedestrian, and Review Alternative would allow the City time
transit demands. Moreover, the Citys to phase in these projects. The delay of light
While many of these intersections would
development guidelines require that the rail service and the economic recession
operate at LOS F under the No Action
increased demands for parking, bicycle, result in the City anticipating a lower level of
Alternative and the City has established an LOS
pedestrian, and transit facilities are growth and transportation improvements
F standard for this corridor, introducing the
addressed. Therefore, with implementation similar to those described in the No Action
Proposal without transportation network
of TMP projects, no additional impacts on Alternative for the first 10 years, with the
enhancements to support the proposed land
parking, bicycle, pedestrian and transit higher level of growth anticipated under the
uses would result in diminished mobility
system are identified. Proposal and the transportation projects
throughout the corridor. Given the substantial
needed for mitigation of that level of growth
increase in delay and reduction in mobility that
(similar to that found in the Proposal)
are projected to result from the Proposal, LOS
needed in the second 10 years of the
impacts are identified at all five of these key
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intersections. planning period. This change would also
Pedestrian, Bicycle, and Transit Facilities allow the phasing of transportation and
capital facilities amendments needed to the
By introducing substantial new residential and Citys Transportation Master Plan and
employment capacity compared to the No Comprehensive Plan in coordination with the
Action Alternative into the Midway Subarea, the Citys next complete comprehensive plan
Proposal would increase demands for parking, update, tentatively scheduled for December
pedestrian, bicycle, and transit facilities. 1, 2014, or as otherwise allowed by GMA
The Proposal includes a number of goals and legislative amendments.
policies that support development of parking,
pedestrian, bicycle, and transit facilities (see
Appendix C for the Midway Subarea Plan):
Parking: In addition to the Citys policies
regarding parking provision, the Proposal
includes a goal (MUD-4) and related
policies (MUD-4.1, 4.2, and 4.3, 4.4, MT-
3.3 and 3.5) that would reduce its impact
on parking facilities and/or facilitate the use
of nearby park and ride facilities.
Pedestrian facilities: The Midway
Subarea Plan includes a number of goals
(MLU-3, MT-2) and policies (MLU-3.1, 3.2,
and 3.3, and 3.4, MUD-3.1, 3.2, 3.4, 3.5,
and 3.63.8, MT-2.4, 3.2, and 4.1) that
would guide the development to provide a
pedestrian-friendly atmosphere and to
enhance pedestrian facilities beyond what
exists today (including the addition of a
grade-separated crossing of SR 99 near
Highline Community College).
Bicycle facilities: The Midway Subarea
Plan includes goals (MLU-3, MT-1) and
policies (MT-1.5 and 1.6) that would guide
the development to provide a bicycle-
friendly atmosphere and to enhance bicycle
facilities beyond what exists today.
Transit services and facilities: The
Midway Subarea Plan includes a number of
goals (MLU-1 and 3, MUD-4, MT-1 and 3)
and policies (MLU-1.1, 1.3, 3.1, and 3.3,
MUD-3.4 and 4.1, MT-1.1, 3.1, 3.2, 3.4,
3.5, and 3.6) that would reserve right-of-
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way for planned expansions to local and
regional transit services, facilitate
coordination with Sound Transit and other
transit agencies, facilitate transit use by
making transit stops accessible and
pleasant, and which would create
development opportunities for uses that are
compatible with transit ridership.
With these policies in place, no adverse impacts
on parking, pedestrian, bicycle, and transit
facilities are identified.
3.6 Public Police Police Impacts under the FEIS Review Alternative
Services/Utilities The Police Departments adopted LOS standard The Police Departments adopted LOS would be similar to those under the Proposal
is a response time of 6 minutes or less to the standard is a response time of 6 minutes or for public services and utilities because both
scene from receipt of an emergency call. It is less to the scene from receipt of an alternatives would include the same amount
difficult to quantify how growth in population and emergency call. It is difficult to quantify how of household and employment growth.
employment in the Kent Planning Area would growth in population and employment in the Similar to transportation impacts noted
affect response time. However, this large growth Kent Planning Area would affect response above, phasing of growth anticipated under
in population and employment in a concentrated time. However, this alternative represents a the FEIS Review Alternative would allow the
area in the Midway Subarea is expected to population and employment growth rate of City to phase its capital facility amendments
result in greater traffic congestion, particularly in a slight fraction of that of the Proposal. needed to incorporate public service and
the Midway Planned Action Area and on routes Although growth under this alternative is utility amendments into the Capital Facilities
identified in Section 3.5, Transportation of the expected to result in greater traffic Element, and to update associated
DEIS. The City may need to expand the existing congestion over existing conditions, functional plans.
police facilities located in and near the Midway particularly on routes identified in Section
Subarea to provide a faster response time. 3.5, Transportation of the DEIS for the No
Midway Subarea Plan policies that encourage Action Alternative, it would result in less
mixed-use development in the TOCs could overall traffic congestion than anticipated
result in more eyes on the street, thus helping under the Proposal.
create a more secure environment. Compared to the Proposal, it is unlikely that
While the City does not define its operational the City would need additional police
LOS in terms of employed police officers and service facilities for the Midway Subarea
support staff, it can be reasonably assumed that under this alternative. Still, the City may
the number of calls for police services would need to construct new facilities or expand
increase in conjunction with the Citys increase current facilities to provide faster response
in population. To maintain the ability to respond time in light of additional congestion
to emergency calls in a timely manner, it may be experienced in the Midway Subarea.
necessary for the Police Department to hire Fire and Emergency Medical Services
additional officers and support staff for a new or Similar to Police, the Kent Fire Department
expanded police facility located in or proximate RFAs LOS standards are related to
to the Midway Subarea during the planning response time. Although the Midway
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period. Subarea represents a small portion of the
Because the City has a mutual aid agreement Kent Fire Department RFAs service area,
with Des Moines and Federal Way for police the smaller increase in population and
services in the Midway Subarea, increases in employment expected under this alternative
population and employment in the Subarea would have an effect of increasing traffic
would also result in an increase in calls for congestion, particularly on the already
service that could affect the City of Des Moines congested SR 99, which would slow
and the City of Federal Way Police response time compared to existing
Departments. conditions, though not to the extent as
under the Proposal. Traffic Ccongestion
Fire and Emergency Medical Services would vary based upon location, and in
As noted in the discussion of impacts on police some cases, with improvements assumed
protection, tThe Midway Subareas population is in the Kent Transportation Master Plan in
anticipated to increase to a total of place, congestion would decrease. This is
approximately 11,800 households by 2031. particularly true of the S 272nd Street
Similar to the Police Department, the Kent Fire corridor at the south end of the Midway
Department RFAs LOS standards are related to Subarea However, previously planned
response time. Although the Midway Subarea improvements to S 272nd Street have been
represents a small portion of the Kent Fire dropped from the Citys TMP list, and it is
Department RFAs service area, (it also serves likely that unacceptable corridor LOS would
the City of Covington and areas of be experienced along this corridor. See
unincorporated King County served by Fire Section 3.5, Transportation, of the DEIS for
District 37), and an even smaller percentage of more information on changes to congestion
the overall fire service area population, a six-fold levels under this alternative. However, the
increase in population and four-fold increase in already congested Pacific Highway South
employment in the Midway Subarea would have corridor is expected to worsen as a result of
an effect of increasing traffic congestion which the No Action Alternative, though not to the
would slow response time. Congestion will vary extent as under the Proposal. Increases in
based upon location. However, the Pacific congestion would also have a similar effect
Highway South, S 272nd Street, and S 260th of slowing response time to emergency
Street corridors all become more congested medical calls. Therefore However, growth
compared to existing conditions. The Pacific anticipated under this alternative is less
Highway South corridor is expected to worsen to likely to result in the need for additional fire
LOS F for both the Proposal and the No Action and emergency response facilities,
Alternative, although the corridor includes high- expansion of existing facilities, relocation of
occupancy vehicle (HOV)/transit-only lanes fire and emergency response facilities, or a
which could be used by fire and emergency combination of these measures than under
response services, as needed. More information the Proposal. Although gGrowth in the
on future traffic conditions can be found in Midway Subarea in combination with
Section 3.5, Transportation of the DEIS. growth in surrounding parts of the Kent
However, the already congested Pacific Planning Area under this alternative may
Highway South corridor is expected to worsen result in the need for additional fire and
as a result of the Proposal. Increases in traffic emergency medical facilities.
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congestion would also have a similar effect of As noted for the proposal, tThe Kent Fire
slowing response time to emergency medical Department RFA uses geographic
calls. In addition to increased traffic congestion, information systema (GIS)-based system to
population and workforce increases would erode assess impact of future population and
existing service capacity. Therefore growth employment growth upon fire services. The
anticipated under the Proposal can be expected RFA plans to analyze the Citys updated
to result in a need for additional fire and population and employment projections,
emergency response facilities, expansion of update its Concurrency Management Plan,
existing facilities, relocation of fire and and assess potential impacts and facility
emergency response facilities, or a combination needs using its Mitigation and Level of
of these measures to serve the larger mixed-use Service Contribution policy as it plans for
population anticipated under the Proposal future facilities and resources. and facility
without reducing existing LOS. needs using this tool (Rabel pers. comm.).
The Kent Fire Department RFA uses Even though the City does not define its
ageographic information system (GIS)-based operational LOS in terms of employed fire
system to assess impact of future population and emergency response staff, it can be
and employment growth upon fire services. and reasonably assumed that the number of
facility needs using this toolThe RFA plans to calls for fire and emergency response
analyze the Citys updated population and services would increase in conjunction with
employment projections, update its Concurrency the Citys increase in population. In order to
Management Plan, and assess potential maintain the ability to respond to
impacts and facility needs using its Mitigation emergency calls in a timely manner, it may
and Level of Service Contribution policy as it will be necessary for the Kent Fire
plans for future facilities and resources. (Rabel Department RFA to hire additional
pers. comm.). firefighters, EMTs, and support staff during
Even though the City does not define its the planning period.
operational LOS in terms of employed fire and Because the Kent Fire Department
emergency response staff, it may be necessary RFACity has a mutual aid agreement with
for the Kent Fire Department RFA to hire nearby fire service and emergency medical
additional firefighters, EMTs, and support staff service providers in the Midway Subarea,
during the planning period. increases in population and employment in
Because the Kent Fire Department RFACity has the subarea would also result in an
a mutual aid agreement with nearby fire service increase in calls for service that could
and emergency medical service providers in the impact other fire and emergency medical
Midway Subarea, increases in population and response providers.
employment in the subarea would also result in Parks, Recreation, and Community
an increase in calls for service that could impact Services
other fire and emergency medical response Growth in households in the Midway
providers. Subarea under this alternative is
Parks, Recreation, and Community Services considerably smaller than under the
Under the Proposal, the Midway Subarea, and Proposal. Under the No Action Alternative,
only approximately 2,180 households
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Summary
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the Midway Planned Action Area in particular would be located in the Midway Subarea,
would see the largest concentrated increase in 425 of which would be located in the
households in the entire Kent Planning Area. Midway Planned Action Area. Under this
Under the Proposal, more than six times the alternative, only 83 acres of park land
existing number of households would be located would be needed to meet City parks LOS
in the Midway Subarea boundaries compared to standards in the subarea compared to 449
existing conditions. The Midway Planned Action acres under the Proposal, and only 10,093
Area itself, an area where the City anticipates square feet of recreation facility would be
locating a high-density TOC, is expected to needed compared to 54,748 square feet
include 82% of the new households in the under the Proposal.
Subarea. Only 16 acres of park land would be
Although City Parks and Recreation LOS required to meet LOS standards within the
standards are intended to be applied at a anticipated Planned Action Area under this
citywide or planning area level, for purposes of alternative, compared to 321 acres under
this DEIS, when projected households were the Proposal, and only 1,967 square feet of
translated to population and the City parks and recreation facility would be needed in the
recreation LOS standard applied on a Midway Planned Action Area compared to 39,131
Subarea basis, approximately 449 acres of park square feet needed under the Proposal.
land and 54,748 square feet of recreation As described above, there are no formal
facilities are needed in the Midway Subarea to parks or recreation facilities found in the
meet the Citys LOS standards for parks and Midway Subarea under existing conditions,
recreation. although there are several City facilities
When applied to the Midway Planned Action located a short distance outside the
Area, 321 acres of park land and 39,131 square subarea boundaries. In addition, the
feet of recreation facilities would be needed in subarea benefits from proximity to several
that northern TOC to meet City parks and City of Des Moines and City of SeaTac
recreation LOS standards. park facilities. Under this alternative, the
Many of the City recreation programs and larger Midway Subarea would still be deficient of
parks and open spaces are intended to serve a parks and recreation facilities. The 2010
larger population. In addition, although there are Park & Open Space Plan identifies the
no formal parks or recreation spaces in the acquisition of a new park on the Kent West
Midway Subarea, several parks are located Hill as a short-term priority to be met in the
nearby, both in the City, and the City of Des 2010 to 2020 timeframe. This acquisition
Moines and the City of SeaTac. The Draft may occur within the subarea boundaries,
Midway Subarea Plan itself recognizes that not or in a portion of the Kent West Hill nearby,
all parks and recreation needs would be met in and would help meet parks and recreation
the subarea. needs of the subarea.
The Midway Subarea Plan includes a number of Under this alternative, anticipated growth in
parks and open space goals and policies which the Planned Action Area is much less than
could be incorporated into and otherwise under the Proposal. Only 49% of
expand upon the 2010 Park & Open Space anticipated residential growth occurs in the
Plans CIP West Hill park acquisition. Midway Midway Planned Action Area under this
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Subarea parks and recreation goals and policies alternative, compared to 82% of the growth
are oriented towards acquiring, designing and under the Proposal. Therefore, locating
constructing civic plazas, parks, and other park and recreation facilities in the Midway
recreation facilities appropriate to development Planned Action Area is less important
of a high density TOC. Furthermore, Policies under this alternative than under the
MP&OS 1.6 and 1.7 support sharing existing Proposal.
facilities with neighboring jurisdictions, school
districts, and other entities through joint use
agreements, and considering options for use of
other City park facilities as a means of
expanding recreational access for the Midway
Subarea.
Schools Schools Impacts under the FEIS Review Alternative

Highline School District: Under this Highline School District: Under this would be similar to those under the Proposal
alternative, the Highline School Districts portion alternative, the Highline School Districts for public services and utilities because both
of the Midway Subarea can expect an increase portion of the Midway Subarea would alternatives would include the same amount
of approximately 5,000 new households over increase by approximately 120 new of household and employment growth.
the planning period. All of the new households households over the planning period, Similar to transportation impacts noted
would be multifamily dwellings located in the approximately 4,880 fewer households than above, phasing of growth anticipated under
Midway Subarea, principally in the Midway under the Proposal for this portion of the the FEIS Review Alternative would allow the
Planned Action Area in the northern part of the Midway Subarea. The majority of the new City to phase its capital facility amendments
Subarea. households under this alternative would be needed to incorporate public service and
multifamily households located in the utility amendments into the Capital Facilities
The portion of the Highline School District Element, and to update associated
located in Kent would experience an increase of Midway Subarea, principally in the Midway
Planned Action Area in the northern part of functional plans.
more than 2,000 students over the planning
period. This large of an increase in students, in the Subarea.
a concentrated area, is likely to have an impact The portion of the Highline School District
upon Highline School District facilities, located in the City would increase of by
particularly at the middle and high school levels more than 50 students over the planning
where existing facilities are already over period under this alternative, a small
capacity. Based on recent student projections fraction of the more than 2,000 students
and demographic studies that account for the anticipated under the Proposal. It is unlikely
City of Des Moines Pacific Ridge development that an increase in student generation of
located north of the Midway Subarea, the school around 50 students over the 20-year
district found that it was barely within the planning period would have a significant
permanent school capacity of facilities in this impact on the Highline School District
part of the Highline School District. With the schools serving the subarea. It should be
additional development considered under the noted that the district has existing
Proposal, the school district has reason to permanent facility deficits in this area at
believe it will exceed capacity of one or more of both the middle school and high school
its facilities (Fain pers. comm.). levels (Sheffer pers. comm.). Although,
pPlanned capital facility improvements,
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Summary
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The district has plans for capital facility including improvements to Pacific Middle
improvements in place over the 6-year planning School, would accommodate existing
period to address existing deficiencies, enrollment deficits and could help alleviate
particularly as relates to the subarea, at the some of the future enrollment deficits
middle school level. However, the school district anticipated under this alternative (Highline
will need to address additional capacity needs Public Schools 2009). However, based on
due to the large projected increase in students recent student projections and
living in the subarea under the Proposal. demographic studies that account for the
Federal Way School District: The Federal Des Moines Pacific Ridge development
Way School District encompasses a larger located north of the Midway Subarea, the
portion of the City limits than the Highline school district found that it was barely
School District. Under this alternative, the within the permanent school capacity of
Federal Way School District can expect an facilities in this part of the Highline School
increase of approximately 5,400 households in District (Fain pers. comm.). Therefore, the
the Kent portion of the school district over the additional students generated under this
planning period. More than 89% of the new alternative, in combination with an increase
households would be multifamily dwellings in students in other portions of the Highline
located in the Midway Subarea. Approximately, School District, may result in a need to
3,925 2,950 of the new multifamily households develop new facilities and/or use
would be located in the Kent Highlands as part relocatable classrooms to accommodate
of a mixed-use development under the the number of new students expected
Proposal. There would be a smaller increase under this alternative.
(approximately 19%) in single-family housing in Federal Way School District: The Federal
residential neighborhoods located outside the Way School District encompasses a larger
Midway Subarea. portion of the City limits than the Highline
The portion of the Federal Way School District School District. Under this alternative, the
located in Kent would experience an increase of district would see an increase of
2,400 students over the planning period. More approximately 320 households in the Kent
than 1,500 Approximately 1,180 of these portion of the school district over the
students would be located in the Kent planning period, most of which would be
Highlands, part of the Midway Planned Action single-family dwellings located outside the
Area. Midway Subarea. Only about 2615 of the
new households would be located in the
The Federal Way School Districts 2010 Capital Kent Highlands portion of the Midway
Facilities Plan identifies some infrastructure Planned Action Area under this alternative.
projects that would add capacity in the vicinity of
the Midway Subarea, including the replacement The portion of the Federal Way School
of Sunnycrest Elementary School. These District located in Kent West Hill would
improvements would help address school experience an increase of approximately
capacity needs, at least in part. The large 224 students over the planning period. The
increase in population, particularly in majority of these students would come from
concentrated areas and areas with little or no areas of the Kent West Hill outside the
existing residential development, such as Kent Midway Subarea. Only about 1810 of these
students would be found living in the Kent
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Highlands, makes it likely that additional Highlands portion of the Midway Planned
capacity would be needed at one or more level Action Area.
of school facilities in this portion of the Federal The Federal Way School Districts 2010
Way School District. The school district may Capital Facilities Plan identifies some
also make use of relocatables, attendance infrastructure projects that would add
boundary adjustments, or similar measures to capacity in the vicinity of the Midway
ensure student capacity is available at the time Subarea, including the replacement of
it is needed. Sunnycrest Elementary School. These
Kent School District: Under the Proposal, the improvements would help address any
portion of the Kent School District within the potential school capacity needs, at least in
Kent Highlands would likely include mixed-use part. However, it is less likely that the
development, including multifamily residential increase in population anticipated under
development. Under the Proposal, the schools this alternative would result in capacity
in the Kent School District serving this portion of deficits for Federal Way school facilities.
the Kent Highlands could see an increase of The school district may also make use of
200 to 300approximately 400 students given the relocatables, attendance boundary
magnitude of new development anticipated in adjustments, or similar measures to ensure
the Kent Highlands. student capacity is available at the time it is
needed.
Kent School District: Under this
alternative, the portion of the Kent School
District within the Kent Highlands would
likely include a small amount of
development, including residential
development. Development in this portion
of the Midway Planned Action Area would
be a fraction of the development
anticipated under the Proposal, and is
unlikely to generate more than a handful of
new students attending Kent schools.
Water Water Impacts under the FEIS Review Alternative

Highline Water District: Under this alternative, Highline Water District: According to the would be similar to those under the Proposal
the Highline Water District would see growth in Highline Water District 2008 for public services and utilities because both
the Kent portion of its service area of Comprehensive Water System Plan, with alternatives would include the same amount
approximately 10,500 households and 7,700 completion of the improvements identified of household and employment growth.
jobs, representing an increase of 9,800 in the districts Capital Improvement Plan, Similar to transportation impacts noted
households and 5,800 jobs compared to the No the district is projected to be able to provide above, phasing of growth anticipated under
Action Alternative. The vast majority of this water in its service area well beyond the the FEIS Review Alternative would allow the
growth is expected to occur in the Midway required 20-year planning horizon (2028). City to phase its capital facility amendments
Planned Action Area portion of the Midway The 2008 Comprehensive Water System needed to incorporate public service and
Subarea. Plan identifies a district wide population of utility amendments into the Capital Facilities
Element, and to update associated
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Summary
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Based upon historic water demand by 74,896 and employment of 30,360 by 2028. functional plans.
residential and non-residential users, under the The plan projects total water demand of
Proposal, the Kent portion of the Highline Water 7.76 MGD by 2028, an increase of 1.06
District would increase water consumption from MGD compared to the Plans 2008 base
0.4 to 1.7 MGD during the planning period. year (Highline Water District 2008).
The 2008 Highline Water District Plan plans for Applying per capita water usage rates to
district-wide population and employment to a this alternatives population and
2058 planning horizon. The districts plan employment projections indicate that the
indicates that in all cases, the population City portion of the Highline Water District
projections that it used for its water system service area would see an increase from
planning can be met by the districts water 0.4 to 0.6 MGD under this alternative. This
supply and other infrastructure, particularly with is approximately 1.1 MGD less than
improvements identified in the plan (Highline anticipated under the Proposal.
Water District 2008). Although the 2008 Comprehensive Water
During preparation of the 2008 Comprehensive System Plan does not identify any specific
Water System Plan, the Highline Water District capital improvements within the subarea,
discussed City plans arising from the Envision capital improvements described in the plan
Midway planning process. The district indicated would enhance system-wide performance
that it would have sufficient capacity to serve and ensure that the district can meet its
future development that may be associated with water supply needs to its 2028 planning
the Envision Midway planned action ordinance horizon. With capital improvements
(Osborne pers. comm.). anticipated in the 2008 Comprehensive
Water System Plan in place, the Highline
Water District would be able to
accommodate the growth anticipated in the
subarea under this alternative.
Sewer Sewer Impacts under the FEIS Review Alternative

Midway Sewer District: Under this Alternative, Midway Sewer District: Under this would be similar to those under the Proposal
the Midway Sewer Districts portion of the alternative, the Midway Sewer Districts for public services and utilities because both
Midway Subarea would see an increase in portion of the Midway Subarea would see a alternatives would include the same amount
development, particularly in the Midway Planned smaller increase in development compared of household and employment growth.
Action Area portion of the service area, similar to the Proposal. Under this alternative, the Similar to transportation impacts noted
to that anticipated for the Pacific Ridge district would need to serve 2,150 above, phasing of growth anticipated under
development in the City of Des Moines. Under households and almost 3,500 employees in the FEIS Review Alternative would allow the
the Proposal, the Midway Sewer District would the Midway Subarea portion of its district. City to phase its capital facility amendments
need to serve 7,900 households and 8,900 This is a 65% increase in employment, but needed to incorporate public service and
employees in the Midway Subarea portion of its only a 13% increase in population over utility amendments into the Capital Facilities
district. Using flow rates described in the 2008 existing conditions. Using flow rates Element, and to update associated
Midway Comprehensive Sewer District System described in the 2008 Midway functional plans.
Plan of 70 gallons/capita/day for residential and Comprehensive Sewer District System Plan
40 gallons/employee/day for employment, this of 70 gallons/capita/day for residential and
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September 2011
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would increase wastewater flows to the Midway 40 gallons/employee/day for employment,
Sewer system from approximately 0.42 MGD this would increase wastewater flows to the
under existing conditions to 1.76 MGD in 2030. Midway Sewer system from approximately
The Midway Sewer Districts consultant 0.42 MGD under existing conditions to 0.52
modeled the new growth anticipated in Kents MGD in 2030.
portion of the Midway Subarea. Based upon this The Midway Sewer District appears to have
analysis, the Midway Sewer Districts modeled a similar future growth as that
infrastructure is capable of handling the anticipated under this alternative in its 2008
increased flows resulting from the Proposal. Comprehensive Sewer System Plan.
However, the model showed one area along Although the Midway Sewer District would
20th Avenue S, between S 244th Street and S review the population and employment
244th Place (located west of the Midway projections of this alternative as well as the
Subarea boundary) that would be at or a little Proposal, it appears that existing upgrades
over capacity with new flows. The district will to sewer collection system and pump
monitor as development occurs to see if the stations contained in the 2008
capacity issues actually do develop as predicted Comprehensive Sewer System Plan would
in the model, and implement facility be adequate to accommodate anticipated
improvements as needed for this 400-foot future flows in the subarea under this
section of an18-inch pipe (Kase pers. comm.). alternative.
The 2008 Comprehensive Sewer System Plan The 2008 Comprehensive Sewer System
indicates that by 2030, with development and Plan indicates that by 2030, with
improvements anticipated during the 2008 to development and improvements anticipated
2030 planning period, the Des Moines Creek during the 2008 to 2030 planning period,
Wastewater treatment plant will operate at 6.89 the Des Moines Creek Wastewater
MGD of its 9.0 MGD capacity (Midway Sewer treatment plant would operate at 6.89 MGD
District 2008). Adding in the additional 1.34 of its 9.0 MGD capacity (Midway Sewer
MGD of sewage flow anticipated under the District 2008). From a review of the 2008
Proposal would bring the Wastewater treatment Comprehensive Sewer System Plan, it
plant up to 8.23 MGD in 2031. Although under appears that the additional 0.1 MGD of
the 9.0 MGD treatment plant capacity, this sewage flow anticipated under this
amount of sewage flow would trigger the need alternative for the Midway Subarea is
for wastewater treatment plant upgrades that included in the 6.89 MGD anticipated by
occur when a treatment plant reaches 85% of its 2030 in the 2008 Comprehensive Sewer
capacity. System Plan. Therefore, it is unlikely that
City of Kent Sewer additional wastewater treatment plant
upgrades or improvements would be
The City provides sewer service to the area in needed other than those already
and around the Kent Highlands property. anticipated in the 2008 Comprehensive
Because the bulk of this property is an Sewer System Plan under this alternative.
undeveloped former landfill site, it is likely that
sewer lines would need to be extended to serve City of Kent Sewer
portions of the anticipated development. The City provides sewer service to the area
in and around the Kent Highlands property.
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Summary
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Under the Proposal, the Kent Highlands part of Because the bulk of this property is an
the Midway Planned Action Area is expected to undeveloped former landfill site, it is likely
have more than 3,900 households and 550 jobs that sewer lines would need to be extended
located on it, in comparison to 6 households and to serve portions of the property that are
70 jobs under existing conditions. The City did anticipated to develop.
not anticipate this level of future development Under this alternative, the Kent Highlands
when planning for sewer infrastructure that part of the Midway Planned Action Area is
would serve the Kent Highlands portion of the expected to have only about 26 households
Midway Subarea. Sewer pipe sizes and pump and 235 jobs located on it, in comparison to
station capacity will probably be affected by this 6 households and 70 jobs under existing
level of increase. Depending on how much of conditions. This is only a fraction of the
future development is served by the S 231st housing and employment anticipated under
Way or the Kent-Des Moines Road sewers, the the Proposal and is not expected to result
amount of development anticipated in the Kent in a significant impact. The City will review
Highlands under the Proposal could impact pipe development proposals for consistency with
size for the sewer line along S 231st Way that its service requirements.
flows north on Riverview Boulevard as well as
the pump station capacity for the pump station
located at the Green River at about S 221st, and
the pipe size for the sewer pipe in Kent-Des
Moines Road that flows south to Reith Road
where it connects to the King County
interceptor. In addition, since sewer in Kent-Des
Moines Road is located in the south side of the
road, any sewer flows from the Kent Highlands
site to this sewer would require a new sewer
crossing under the Kent-Des Moines road to
connect flows from Kent Highlands to the north
to the Kent-Des Moines/Reith Road sewer lines
(Vesper pers. comm.). Since this large of an
increase in population and employment was not
anticipated in developing existing infrastructure,
it will result in the need to extend sewer facilities
and provide upgrades to existing sewer facilities
in the vicinity of the Kent Highlands.
Stormwater Stormwater Impacts under the FEIS Review Alternative

The Kent Stormwater Utility provides service to The Kent Stormwater Utility provides would be similar to those under the Proposal
the Midway Subarea. Growth under the service to the Midway Subarea. Growth for public services and utilities because both
Proposal is expected to result in higher levels of under this alternative would result in slightly alternatives would include the same amount
impervious surfaces compared to existing higher levels of impervious surfaces of household and employment growth.
conditions, as vacant land is developed over the compared to existing conditions, as small Similar to transportation impacts noted
planning period. As impervious surface area amounts of existing vacant land is are above, phasing of growth anticipated under
the FEIS Review Alternative would allow the
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increases, there would be a greater need for developed over the planning period. As City to phase its capital facility amendments
stormwater facilities to convey and store impervious surface area increases, there needed to incorporate public service and
stormwater flows. would be a greater need for stormwater utility amendments into the Capital Facilities
Under the Proposal, a greater concentration of facilities to convey and store stormwater Element, and to update associated
new development would occur as mixed-use flows. functional plans.
development in taller buildings than under either Under this alternative, much of the new
existing conditions or the No Action Alternative. development in the Midway Subarea would
This is particularly true for the Midway Planned occur as single-use commercial, with a
Action Area located in the northern portion of smaller amount of multifamily residential
the Midway Subarea. Land use designations development. Land development would
and zoning regulations are anticipated to likely be in single-story or 2-story buildings
change under the Proposal to allow for greater and would rely upon surface parking rather
site coverage and more impervious surface than structured or underground parking
coverage in the Midway Subarea than currently areas. Essentially, development patterns
allowed. This would allow a more urban form of would be similar to those found in existing
development needed for transit-oriented mixed- conditions. Zoning designations would
use development. In addition, areas currently remain the same as they are today,
covered by surface parking in the Midway allowing a smaller percentage of site
Subarea would be exchanged for areas covered coverage than anticipated under the
by building, structured parking, and pedestrian Proposal.
facilities such as sidewalks or other pedestrian The same stormwater manuals, the
gathering areas under the Proposal. potential for new stormwater standards,
New development would be subject to similar and increased detention standards all apply
manuals and forthcoming detention standards as is the case under the Kent Planning
as described under Kent Planning Area. Area.
Solid Waste Solid Waste
Under this alternative, the Midway Subarea is Under this alternative, the Midway Subarea
expected to experience a six-fold increase in is expected to experience a 14% increase
households and more than four times the in households and a 70% increase in
amount of employment over the planning period, employment over the planning period, with
with a consequent increase in solid waste a consequent increase in solid waste
generation. Using the 3 pounds per capita per generation compared to existing conditions.
day solid waste generation rate used by City Solid waste generation under this
and regional entities, the Midway Subarea is alternative would be less than that
estimated to produce approximately 21,565 tons anticipated under the Proposal. Using the 3
of solid waste per year under this alternative pounds per capita per day solid waste
compared to an estimated 3,850 tons of solid generation rate used by City and regional
waste per year in the 2006 base year. entities, the Midway Subarea would
produce approximately 5,055 tons of solid
waste per year under this alternative
compared to an estimated 3,850 tons of
solid waste per year in the 2006 base year.
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Summary
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This is roughly 16,500 fewer tons per year
than anticipated under the Proposal.
3.7 Noise Noise impacts from construction activities, Under this alternative, the Midway Subarea Noise impacts under the FEIS Review
commercial operations, and vehicle travel are would still experience gradual growth. Alternative would be similar to those under
expected to be greater under the Proposal Development under this alternative would the Proposal because both alternatives
compared to the No Action Alternative in this still lead to small increases in population would include the same amount of
area. and employment that would likely increase household and employment growth.
The Midway Planned Action Area is anticipated noise generated by construction activities,
to experience the highest increase in housing, commercial facilities, and traffic in the
commercial, and mixed-use developments, subarea. Therefore, noise impacts would
which would result in the greatest noise impacts be similar for construction noise,
from construction activities and commercial commercial operation noise, and traffic
operations. The City noise ordinance would noise described under Impacts Common to
prevent the nighttime construction activities and Both All Alternatives for the Kent Planning
commercial operations from causing noise Area. Noise impacts from increased traffic
impacts at existing residences. However, and buses on SR 99 and the future light rail
temporary daytime construction activity is are described under Impacts Common to
exempt from the City noise ordinance limits and Both All Alternatives for the Midway
could cause annoyance and speech Subarea.
interference at outdoor locations adjacent to the
construction sites and could cause discernible
noise for several blocks away from the
development site.
The Proposal for the Midway Planned Action
Area would also result in greater traffic increase
on City streets and SR 99 compared to the No
Action Alternative. In addition, RapidRide
service, future light rail service, and the
proposed growth may result in increased
demand of bus service in the subarea.
Therefore, the proposed mixed-used residents
and existing homes adjacent to SR 99 and the
future light rail station would potentially be
affected by the noise generated from increased
traffic, and buses, and the future light rail.
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September 2011
1.4. Mitigation Measures

4B
Incorporated plan features and applicable regulations and commitments are included for
each topic covered in Chapter 3 of thethis DEIS and as amended in the FEIS. In
addition,Only other mitigation measures are proposed that are summarized in Table 1-3
for the Kent Planning Area and Table 1-4 for the Midway Subarea.
Table 1-3. Summary of Mitigation Measures for the Kent Planning Area
Topics Other Mitigation Measures
3.1Natural LID strategies could be used to improve stormwater runoff conditions

Environment by reducing stormwater runoff volume and improving the timing of
runoff, as well as potentially reducing stormwater pollutant loading. If
effective LID strategies are implemented over a large enough area,
drainage conditions could be maintained with new development and,
in some cases, improved with redevelopment where there is
currently inadequate stormwater management. Improved drainage
conditions could, in turn, have an incremental beneficial impact on
water quality and aquatic habitat downstream.
3.2AirQuality Construction Emissions Reduction Measures
The City should require all construction contractors to implement air
quality control plans for construction activities in the Kent Planning
Area as part of plan features of the Proposal. The air quality control
plans will include best management practices (BMPs) to control
fugitive dust and odors emitted by diesel construction equipment.
Develop a fugitive dust control plan.
Use water sprays or other non-toxic dust control methods on
unpaved roadways.
Minimize vehicle speed while traveling on unpaved surfaces.
Prevent track out of mud onto public streets.
Cover soil piles when practical.
Minimize work during periods of high winds when practical.
Maintain the engines of construction equipment according to
manufacturers specifications.
Minimize idling of equipment while the equipment is not in use.
Burning of slash or demolition debris will not be permitted without
express approval from PSCAA. No slash burning is anticipated for
any construction projects in the study area.
Greenhouse Gas Reduction Measures
Neither Washington State Department of Ecology nor the
Environmental Protection Agency is likely to adopt any greenhouse
gas (GHG) emissions standards or GHG reduction requirements in
the near future. It is the Citys responsibility to implement its GHG
reduction requirements for new developments.
GHG emissions reductions could be provided effected by using
prudent building design and construction methods to use recycled
construction materials, reduce space heating and electricity usage,
and reduce water consumption and waste generation.
The City could require development applicants to identify the
reduction measures shown in Table 3.2-9 of the DEIS in their
projects, and explain why other measures found in the table are not
included or are not applicable.
Incorporate potential GHG reduction measures found in through the
Citys goals, policies, or regulations.
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Summary
3.3LandUse/Plans Update Goal LU-9 of the Comprehensive Plan with 2031 household
andPolicies and employment growth targets consistent with the anticipated
update of the CPPs in 2010.
Update the Transportation and Capital Facilities elements to be
consistent with revised household and employment plans to ensure
that adequate facilities are in place in time to accommodate growth,
or revisit the Land Use Element as called for in Policy CF-1.4 of the
Comprehensive Plan.
Update other elements of the Comprehensive Plan, including the
Design, Housing, Economic Development, Land Use, and possibly
other elements to account for increased focus on Activity Centers
and to meet GMA requirements for periodic updates to
Comprehensive Plans.
Consider amending the implementing regulations to address issues
related to design and aesthetics found in Goal LU-8, and regulatory
incentives for mixed-use development found in Policy LU-13.3.
Develop subarea plans for City-designated and mapped Activity
Centers consistent with Goal LU-14.1, and subsequent
Comprehensive Plan Land Use Map and Zoning Districts Map
amendments that would implement each subarea plan.
3.4Aesthetics Incorporate sections of the Downtown Design Review Guidelines into
the revised Activity Center development regulations (City of Kent
2003)Incorporate appropriate design elements into the revised
Activity Center development regulations, e.g., sections of Downtown
Design Review Guidelines (City of Kent 2003).
Shield exterior light fixtures to minimize glare and up-lighting. Lights
should be screened and directed away from residences to the
highest degree possible. Lighting restrictions should be adopted to
control faade illumination and excessive lighting. The number of
nighttime lights installed should be minimized to the greatest degree
possible. Light fixtures and poles should be painted; no reflective
surfaces should be used that would contribute to reflective daytime
glare.
Preserve solar access for public pedestrian spaces,
pedestrian/bicycle pathways, parks, schools and other areas
sensitive to shading by requiring upper-story and/or ground-level
setbacks for adjacent development. To the greatest extent possible
for new development, seek to minimize casting shadows on public
spaces during their primary hours of daytime use.
Establish Citywide public view corridors along major public rights-of-
way and from primary vantage points within the City, such as the
Kent Highlands, to ensure that visual resources identified in the
Comprehensive Plan are adequately protected as future
development occurs. Impose height limitations and/or limitations on
footprint size for upper stories or similar measures for development
occurring within these designated corridors.
3.5Transportation With TMP projects implemented, no additional mitigation is required
for the Kent Planning Area through 2031.
3.6PublicServices Police
andUtilities Development using crime prevention through environmental design
(CPTED) principles would help mitigate the need for additional police
facilities and services in the Kent Planning Area.
Monitor growth and demand through regular Comprehensive Plan
reviews, capital facility plan preparation, and budget process.
Revenues from increased employment activity and increased
property values could help offset some of the additional expenditures
for providing additional officers and responses to incidents.
The Kent Fire Department RFA will Aadd fire facilities and staff as
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September 2011

budget allows to serve the growing population andin an effort to
maintain service level capacity and LOS. Service providers
shouldThe RFA will monitor growth and demand for service through
its regular planning and budgeting processes and implementation of
its Mitigation and Level of Service Contribution policy. Revenues
from increased employment activity and increased property values
could help offset some of the additional expenditures for providing
additional responses to incidents as a result of growth.
The Kent Fire Department RFA is in the process of
updatingdeveloping aits cConcurrency mManagement system Plan,
which, when completed will be used in conjunction with its Mitigation
and Level of Service Contribution policy to help assess and mitigate
the impacts of new development on fire facilities and resources
(Rabel pers. comm.).
Based on an analysis of future population projections under both the
No Action Alternative and Proposal, the City would need between
296 and 1,073 acres of park land, and up to 3,173 square feet of
recreation space to meet 2009 City parks and recreation LOS
standards. Alternately, the City could reduce its LOS standards or
modify its growth levels.
Schools
Based on an analysis of the Kent School Districts 2008 Capital
Facilities Plan, it is likely that growth anticipated under either the
Proposal/FEIS Review Alternative or the No Action Alternative would
exceed school capacity anticipated in the school districts 2008 plan.
The school district will continue to monitor population growth over
time, and will make use of updated City population projections in its
future planning to ensure that adequate school facilities are in place
to meet future population growth in the Kent Planning Area.
The school district may make use of relocatable facilities and/or
make future adjustments to attendance areas to ensure adequate
capacity for school facilities are in place in when needed for student
population growth.
Water
There are no identified mitigation measures for City or other water
providers outside of the Midway Subarea.
Sewer
There are no identified mitigation measures for City or other sewer
providers outside of the Midway Subarea.
Stormwater
The standards in the Citys Stormwater Utility is in the process of
revising its Stormwater Manual, and anticipates that by the end of
20112010, it will have adopted a Stormwater Manual equivalent to
2002 Surface Water Design Manual have been adjusted to meet the
equivalency requirements of the Washington State Department of
Ecologys Stormwater Management Manual for Western Washington
(2005).
Solid Waste
The City has a new contract for garbage, recycling, and yard/food
waste collection effective April 1, 2011, which allows for more items
to be recycled and also provides a yard and food waste cart for all
customers. In terms of long-range planning, the 2006 King County
Solid Waste Transfer and Waste Management Plan (King County
Solid Waste Division 2007) is being updated with the latest draft
dated October 2009. Except for the cities of Seattle and Milton, all of
King County is covered by this plan and its update. The 2009 Draft
King County Solid Waste Management Plan includes measures to
help facilitate and increase the amount of recyclable materials being
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Summary

diverted from the waste stream. These measures should reduce the
amount of waste going to landfills via transfer stations and
residential/commercial collection.
3.7Noise Construction Noise Abatement
If nighttime construction operations are required, then noise
abatement would be considered on a case-by-case basis to ensure
that noise levels at the nearest residences would be within the Citys
nighttime noise limits. According to the City code, temporary daytime
construction activities are exempt. Regardless, based on site-specific
considerations at the time of construction permit review, the City may
at its discretion require all construction contractors to implement
noise control plans for construction activities in the Kent Planning
Area for daytime activities.
Construction noise could be reduced by using enclosures or walls to
surround noisy stationary equipment, installing mufflers on engines,
substituting quieter equipment or construction methods, minimizing
time of operation, and locating equipment as far as practical from
sensitive receptors. To reduce construction noise at nearby
receptors, the following mitigation measures will be incorporated into
construction plans and contractor specifications:
o Locating stationary equipment away from receiving properties
will decrease noise from that equipment.
o Erecting portable noise barriers around loud stationary
equipment located near sensitive receivers will reduce noise.
o Limiting construction activities to between 7:00 a.m. and 10:00
p.m. will avoid sensitive nighttime hours.
o Turning off idling construction equipment will eliminate
unnecessary noise.
o Requiring contractors to rigorously maintain all equipment will
potentially reduce noise effects.
o Training construction crews to avoid unnecessarily loud actions
(e.g., dropping bundles of rebar onto the ground or dragging
steel plates across pavement) near noise-sensitive areas will
reduce noise effects.
New Commercial Operation Noise
The City may require all prospective developers to use low-noise
mechanical equipment adequate to ensure compliance with the
Citys daytime and nighttime noise ordinance limits. Depending on
the nature of the proposed development, the City may require the
developer to conduct a noise impact study to forecast future noise
levels and to specify appropriate noise control measures.
Compliance with the noise ordinance would ensure this potential
impact would not be significant.
Traffic Noise Mitigation
Although traffic noise is exempt from the Citys noise ordinance,
based on site-specific considerations, the City may at its discretion
require new residential development to install triple-pane glass
windows or other building insulation measures using its authority
under the Washington State Energy Code (KCC 14.01.010).
Bus Stop Noise Mitigation
Buses decelerating, accelerating, and idling at bus stops would
increase ambient noise and could impact existing and future homes
immediately adjacent to these bus stops. The City could mitigate the
impacts by not locating bus stops near residential land uses. If bus
stops have to be installed in front of residential land uses, the City
could mitigate the impacts by requiring installation of triple-pane
windows at these residential developments.
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September 2011
Table 1-4. Summary of Potential Mitigation Measures for Midway Subarea

3.1Natural The City will require that Planned Action applicants identify any LID
Environment techniques described in currently available manuals (Washington
State Department of Ecology 2005 4, Puget Sound Action Team and
3F
Washington State University Pierce County Extension 2005 5 or 4F
equivalent manuals) proposed for incorporation into the planned

action and demonstrate why unincorporated LID techniques are not
feasible. Flow reduction credits provided in the Ecology stormwater
manual for use in LID facilities will translate into smaller stormwater
treatment and flow-control facilities over those which use
conventional methods. In certain cases, use of various LID
techniques can result in elimination of stormwater mitigation facilities
entirely. As part of required land use, building, or construction
permits, the City should, as appropriate, condition planned actions to
incorporate feasible and site-appropriate LID techniques.Other
mitigation measures for the Midway Subarea are the same as found
in the Kent Planning Area, relating to LID strategies.
3.2AirQuality Other mitigation measures for air quality applied to the Midway
Subarea are the same as described in the Other Mitigation Measures
under Kent Planning Area above.
3.3LandUse/Plans As part of the adoption of the Midway Subarea Plan, Comprehensive
andPolicies Plan Land Use Plan map and text amendments would be adopted
within the Midway Subarea in support of the future land use
framework outlined in the Midway Subarea Plan.
Subsequent amendments to the Zoning Districts map and
development regulations would be adopted that implement a future
land use framework outlined in the Midway Subarea Plan and are
consistent with amendments to the Comprehensive Plan Land Use
Plan map noted above.
The Midway Design Guidelines would be adopted in support of
aesthetic goals and policies of the Community Design Element and
the Midway Subarea Plans Urban Design goals and policies.
3.4Aesthetics The City should identify significant should establish defined view
corridors from public areasrights-of-way within the Midway Subarea,
which may include but is are not limited to the intersection of SR 99
and S 240th Street, looking southeast (Mount Rainier), to provide a
framework for preservation of important views to Mount Rainier, the
Cascades, and Puget Sound. Primary locations shall include the
intersection of SR 99 and S 240th Street, looking southeast (Mount
Rainier). Site design measures from the Midway Design Guidelines
should be applied to development within these view corridors to
prevent the obstruction of public views.
To minimize shading impacts within the Midway Planned Action
Area, the City should require, to the greatest extent feasible, that the
tallest portions of new buildings or the tallest buildings on a
development site will be located central to the property to maximize
the distance from any adjacent sensitive development that may exist,
such as single-family residences. This may be accomplished by
application of transitional height standards and through
implementation of Midway Design Guidelines relating to Site
4Washington State Department of Ecology. 2005. Stormwater Management Manual for Western Washington. April.
Available: < http://www.ecy.wa.gov/programs/wq/stormwater/manual.html>. Accessed: March 12, 2011.
Olympia, WA.
5Puget Sound Action Team and Washington State University Pierce County Extension. 2005. Low Impact
Development Technical Guidance Manual for Puget Sound. January. Available:
<http://www.psparchives.com/publications/our_work/stormwater/lid/lid_tech_manual05/LID_manual2005.pdf>.
Accessed: March 12, 2011.
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Summary

Characteristics, Transition Between Residence, Street, and
Adjacent Sites, and Height Bulk and Scale, or equivalent action.
The City should also implement the following mitigation measures
regarding shading conditions:
o Solar access for public pedestrian spaces, pedestrian/bicycle
pathways, parks, schools and other areas sensitive to shading
should be preserved by requiring upper-story and/or ground-
level setbacks for adjacent development.
o Development should include upper story step-backs at the third
story and again at the seventh story to increase sunlight at
street level when adjacent to should not exceed four stories in
height within 50 feet of any component of the Open Space
Framework illustrated in the Midway Subarea Plan, including
multi-modal streets, pedestrian/bicycle pathways, and parks.
o Coordinated design should be encouraged between properties
in the area south of S 240th Street and north of S 246th Street
to ensure that the high-intensity development anticipated in this
location preserves solar access to interior spaces and private
pedestrian connections.
3.5Transportation Level of Service Mitigation MeasuresMidway Subarea
The impacts of the Midway project to operations along SR 99, as well
as to Kent-Des Moines Road and the Kent-Des Moines Road/I-5
interchange necessitate the provision of the following on-site
transportation infrastructure that supports the land uses included in
the Proposal/FEIS Review Alternative (see Table 3.5-12 of the DEIS
for more detail):
o Local Street Connection: create a local street connection by
extending S 231st Street from I-5 to 30th Avenue. This
connection would be designed to provide an additional link for
local traffic across I-5 and is contingent on Statestation action.
o 30th Avenue Overcrossing: Grade-separated four-lane
crossing of Kent-Des Moines Road, with right-turn access
maintained between two roadways.
o 30th Avenue Complete Streets Enhancements: Construct a
four-lane cross-section, but initially stripe to include two travel
lanes with parking on both sides of street from Kent-Des Moines
Road to S 240th Street. Design with traffic calming elements to
reduce vehicle speeds and encourage non-motorized travel.
Roadway will be converted to four-lane operations once the
Citys LOS E threshold is exceeded.
o Complete Street Connection 240th to 244th Street: Construct
a four-lane cross-section, but initially stripe to include two travel
lanes with parking on both sides of street from S 240th to
access road provided at S 244th Street. Design with traffic
calming elements to reduce vehicle speeds and encourage non-
motorized travel. Roadway will be converted to four lane
operations once the Citys LOS E threshold is exceeded.
o Business Access Service Roads: Provide two-lane route for
accessing businesses between S 244th Street and S 252nd St;
and between S 252nd and S 260th Street. Conceptual
alignments to be determined.
o SR 99 Access Roads: Provide three new access roads
between 30th Avenue and SR 99. One would extend from S
238th Street; another would be midway between S 238th Street
and S 240th Street, and the third would be located at S 244th
Street.
o Local Circulation Routes: Internal roadways are provided to
facilitate internal travel among proximate uses in the Kent
Highlands (since there will be no direct access off of S 231st
Street), and west of SR 99 in the northwestern portion of the
development.
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September 2011

o New Signalized Intersections: S 231st Street/30th Avenue;
SR 99/S 238th Street; SR 99/S 244th Street; S 259th Place/29th
Avenue S
o New Right In/Right Out Intersection: SR 99/Access road
midway between S 238th Street and S 240th Street
o 240th/SR 99: Widen westbound approach from one exclusive
left-turn lane and one through/right turn lane to addinclude an
exclusive right-turn lane or right-turn pocket.
o Internal Site Intersections: Five-to-six locations where either a
roundabout, a signal, or all-way stop may be appropriate based
on forecasted traffic volumes and site conditions
The extension of S 231st Street to 30th Avenue as a local road
connection was not originally anticipated in the Midway Subarea
Plan; however, analysis indicates that it will be necessary to address
impacts to Kent-Des Moines Road and the I-5 ramp terminal
intersections.
The above improvements to the Midway Subarea are at a greater
level of detail than that reflected in the Kent Model. To allow for
evaluation of SR 99 corridor operations with these improvements in
place, a more detailed model was developed. This more detailed
model provided the ability to assign traffic manually in the Midway
Subarea, to ensure that projected traffic followed logical paths, given
the Proposal/FEIS Review Alternatives internal connections and
traffic calming elements. Results of the 2031 LOS for the five key
intersections evaluated along the SR 99 corridor with these
additional improvements in place shows that many of the
intersections along SR 99 will still have LOS F operations. However,
the level of delay and mobility is much closer to what is projected
under the No Action Alternative.
3.6PublicServices Police
andUtilities The City could require planned action applicants to demonstrate how
they have achieved site design that complies with the City of Kent
Downtown Design Review Guidelines (November 2003) Site Design
for Safety Standards (Section I., Site Planning, Subsection E. Site
Design for Safety), or equivalent standards to result in security-
sensitive design of buildings, lighting, and landscaping.Development
using CPTED principles would help mitigate the need for additional
police facilities and services in the Midway Subarea.
However, increases in congestion due to the larger amount of
population and employees anticipated in the Midway Subarea under
the Proposal/FEIS Review Alternative is are likely to trigger the need
for additional police facilities and staff to serve the growing
population in this area. The Police Department will monitor response
time LOS in the designated Planned Action Area over time and
respond to any decreases in LOS standards through adding or
adjusting police facilities and staffing to serve the growing population.
Increases in congestion and use of service capacity due to the larger
amount of population and employees in the Midway Subarea willare
likely to trigger the need for additional fire facilities and staff to serve
the growing population in this area.
The Kent Fire Department RFA will analyze the Citys updated
population and employment projections for the Midway Subarea,
update its Concurrency Management Plan, and assess potential
impacts and facility needs using its Mitigation and Level of Service
Contribution policy as it plans for future facilities and resources. All
future development of the Kent Midway Planned Action Area will
need to comply with the Kent Fire Department RFA Mitigation and
Level of Service Contribution policy to provide adequate funding and
mitigation necessary to maintain LOS (Rabel pers. comm.).
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Summary

Applying the 2009 Parks and Recreation space LOS standards to the
Midway Subarea, shows that the Midway Subarea would need
between 83 and 449 acres of park land and between approximately
10,093 square feet and 54,748 square feet of recreation space for
the Midway Subarea. Of these amounts, between 16 and 321 acres
of park land and between 1,967 square feet and 39,131 square feet
of recreation space would need to be provided in the Midway
Planned Action Area. Acre demand figures do not reflect that there
are about 212 acres of open space in the overall Midway Subarea in
the form of the landfills, parks (City of Kent Park 2.7 acres), and
public and private wetlands. A feasibility analysis would be required
to determine whether the landfill areas have recreational value
beyond mere open space.
The 2010 Parks and Open Space Plan includes Midway Subarea
park acquisition and development of West Hill Neighborhood Park
high priority capital investments. The Envision Midway park
acquisition would be programmed to acquire some of the parks and
recreation spaces conceptually identified in the Midway Subarea
Plan. Although not in the Midway Subarea, the West Hill park will
provide park amenities proximate to the Midway Subarea that will
help meet some of the deficit of park facilities experienced in that
area.
The City could coordinate with neighboring jurisdictions, school
districts, and other entities to share parks and recreation facilities
through joint use agreements, and consider options for use of other
City park facilities as a means of expanding recreational access.
The City could require planned action applicants to provide both of
the following:
o Recreation space for leisure, play, or sport activities at a ratio
of 450 square feet per dwelling unit. A recreation space may
consist of a playground, sport court; or any other recreation
facility proposed by the applicant and approved by the parks
and community services director.
o A pedestrian-oriented plaza or open space at a ratio of 1% of
the site or building area, whichever is greater. A pedestrian-
oriented space is one that contains visual and pedestrian
access (including barrier-free access) to the abutting structures
from the public right-of-way or a non-vehicular courtyard;
paved walking surfaces of either concrete or approved unit
paving; on-site or building-mounted lighting providing at least
4-foot candles (average) on the ground; and seating area.
Through a negotiated voluntary agreement the City may apply the
parks and recreation standards to a specific development and allow
one or more of the following: 1) a portion of the recreation space to
be a community building; 2) a portion of the recreation space to be
accomplished offsite; 3) a higher or lower ratio dependent on the
demand caused by the proposed development; and 4) a fee-in-lieu of
providing the recreation or pedestrian-oriented space
Schools
The additional increment of development anticipated under the
Proposal/FEIS Review Alternative for the Midway Subarea would
likely cause the Highline School District to require additional facilities
to serve the new student population generated in the Midway
Subarea. The Highline School District may be able to meet some of
the anticipated additional capacity on a short-term basis through
relocatables and/or through adjusting attendance boundaries. In
addition, the district may consider preparing an interlocal agreement
with the City to collect a school an impact fee for the Midway
Subarea, similar to what is being done for the Kent, and Federal Way
and Auburn school districts.
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September 2011

Proposal/FEIS Review Alternative for the Federal Way School
District would likely cause the school district to require additional
facilities to serve the new student population generated in the
Midway Subarea. The Federal Way School District may be able to
meet some of the anticipated additional capacity on a short-term
basis through relocatables and/or through adjusting attendance
boundaries. The City has also adopted Federal Way School District
impact fees.
Water
There are no other mitigation measures identified for water.
Sewer
Proposal/FEIS Review Alternative for the Midway Subarea would
cause the Midway Sewer District to monitor future flows and
available capacity for a 400-foot section of 18-inch sewer pipe on
20th Avenue S between S 244th Street and S 244th Place. If
increased flows are as modeled, the district would need to program
improvements to this section of pipe to accommodate larger future
flows.
In addition, the amount of additional wastewater anticipated under
the Proposal/FEIS Review Alternative would trigger the need for the
Midway Sewer District to consider upgrades to its wastewater
treatment plant, particularly when considered with the Pacific Ridge
development located north of the Midway Subarea.
Based on discussion with City Sewer Utility staff, the additional
increment of development anticipated under the Proposal/FEIS
Review Alternative for the Kent Highlands portion of the Midway
Subarea would cause the City of Kent Sewer Utility to provide the
following additional sewer infrastructure to meet the needs of the
new development:
o Depending on the location and intensity of new development
on the Kent Highlands site, the Kent Sewer Utility would have
to increase sewer pipe sizes in S 231st Way and Riverview
Boulevard, flowing north and east, and in Kent-Des Moines
Road and Reith Road flowing south and east. Pump station
capacity either at the existing location west of the Green River
at about 221st or at another existing pump station at 212th
Street would need to be increased to accommodate additional
flows. In addition, an undercrossing of Kent-Des Moines Road
for sewer flows traveling south from the Kent Highlands would
need to be constructed to tie into the existing Kent-Des Moines
Road sewer pipes on the south side of the road (Vesper pers.
comm.).
Stormwater
There are no other mitigation measures identified for stormwater services.
Solid Waste
There are no other mitigation measures identified for solid waste services.
3.7Noise Mitigation measures described in the Kent Planning Area above

would also apply to the Midway Subarea.
The City may at its discretion, require new residential development to
install triple-pane glass windows or other building insulation
measures based on the Citys adoption of the State Energy Code
(KCC 14.01.010).
Both All alternatives would include a new Sound Transit light rail
station in the vicinity of the Highline Community College and a new
light rail track from Sea-Tac International Airport to this station and
extending south of the Midway Subarea. The new light rail segment
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Summary

would increase ambient noise and could affect existing and future
residences adjacent to the station and rail track. An environmental
review for this segment has not yet been conducted. However, based
on the noise environmental assessment for the Airport Link, Sound
Transit would provide reasonable and feasible noise mitigation to
reduce noise levels at affected properties to below the Federal
Transit Administration (FTA) or City criteria. The main form of noise
mitigation for transit projects is installing noise barriers along the
elevated guideways or park-and-rides. In accordance with Sound
Transit policy, if noise walls are not considered a reasonable and
feasible form of noise mitigation, sound insulation of affected
structures may also be considered. (Sound Transit 2005).
1.5. Significant Unavoidable Adverse Impacts

5B
This section describes whether there are any residual impacts after the application of
mitigation measures, and whether these are significant, unavoidable, and adverse.
1.5.1. Natural Environment

15B
Kent Planning Area

45B
Because of the Kent Planning Areas highly developed condition, the intensity and
location of project development, and applicable regulations, no significant unavoidable
adverse impacts on earth, water, and plants and animals would occur under either any of
the alternatives.
Midway Subarea
46B
Because of the Midway Subareas highly developed condition, the location and intensity
of development projected, and applicable regulations, no significant unavoidable adverse
impacts on earth, water, and plants and animals would occur under either any of the
alternatives.
1.5.2. Air Quality

16B
Kent Planning Area

47B
No significant unavoidable adverse impacts on regional or local air quality are anticipated
for the Kent Planning Area. The regulations described previously are adequate to mitigate
any adverse impacts anticipated to occur as a result of study area growth.
Midway Subarea
48B
No significant unavoidable adverse impacts on regional or local air quality are anticipated
for the Midway Subarea. The regulations described above are adequate to mitigate any
adverse impacts anticipated to occur as a result of study area growth.
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September 2011
1.5.3. Land Use/Plans and Policies

17B
Kent Planning Area

49B
Over time, implementation of either the Proposal/FEIS Review Alternative or the No

Action Alternative could convert vacant, partially developed, and redeveloped properties
in the Kent Planning Area to additional or new single-family, multifamily, office,
commercial, and industrial uses. Because of the densification and intensification of uses,
the City would continue to add to its urban character. The resulting transformation of
land uses from less intense suburban character to more intense urban character is
considered a significant unavoidable adverse impact.
Midway Subarea
50B
Significant unavoidable adverse impacts for the Midway Subarea are the same as those
noted for the Kent Planning Area above.
1.5.4. Aesthetics
18B
Kent Planning Area

51B
The overall character, significance, or magnitude of aesthetic impacts in the Kent

Planning Area depend largely on the quality of the architectural and urban design features
incorporated into the development, the degree to which the overall scale and form of the
development incorporates features of the local setting, and the values and preferences of
those viewing the change. While the Proposal/FEIS Review Alternative is anticipated to
create a visual character and pedestrian environment that is superior to existing
conditions overall, the Proposal/FEIS Review Alternative would ultimately result in
changes to the current visual landscape of the Kent Planning Area.
Midway Subarea
52B
The overall character, significance, or magnitude of aesthetic impacts on the analysis area
depend largely on the quality of the architectural and urban design features incorporated
into the development, the degree to which the overall scale and form of the development
incorporates features of the local setting, and the values and preferences of those viewing
the change. With proposed mitigation, particularly implementation of the Midway
dDesign gGuidelines included in the Midway Subarea Plan, aesthetic impacts resulting
from the Proposal/FEIS Review Alternative are anticipated to be less than significant.
However, the large increase in heights proposed for the Midway Subarea as a whole, and
for the Midway Planned Action Area in particular, have a high potential to increase
shading conditions on side streets and internal circulation routes beyond the ability of the
incorporated design guidelines to mitigate. While the Proposal/FEIS Review Alternative
is anticipated to create a visual character and pedestrian environment that is superior to
existing conditions overall, without the implementation of the additional mitigation
measures related to shading conditions and public views listed in the previous section, the
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Summary
Midway Planned Action Area has a high potential to be impacted by the Proposal/FEIS
Review Alternative. Additionally, should the City choose not to adopt the draft design
guidelines associated with the Midway Subarea Plan, impacts associated with the
Proposal/FEIS Review Alternative would be much greater.
1.5.5. Transportation
19B
Implementation of the Proposal/FEIS Review Alternative would result in increased traffic

volumes and demand for transportation facilities in the study area. Although the effects of
additional vehicles on traffic congestion can be lessened through construction of the
various transportation projects and adoption of the Midway Subarea Plan policies
discussed previously, the actual increase in traffic volumes under the Proposal/FEIS
Review Alternative is considered a significant unavoidable adverse impact.
Kent Planning Area

53B
Specific to the Citys corridor LOS policy, the Proposal/FEIS Review Alternatives
impact on the S 272nd Street Corridor is considered a significant unavoidable adverse
impact. As discussed, previously planned improvements to S 272nd Street have been
dropped from the Citys TMP project list. Thus, it is likely that unacceptable corridor
LOS would also been experienced under the No Action Alternative. Given the high
volumes and physical constraints along this corridor, providing meaningful delay
reduction would require substantial modification that is not considered feasible.
Moreover, the growth assumed under both the No Action all of the Aalternatives and
Proposal would result in additional traffic accessing state and regional transportation
facilities. The City works closely with the state, the ports, the county, other jurisdictions,
and many other stakeholders to assure that the state and regional projects that benefit
Kent continue to be a priority in the state and the region. The City will continue to work
with both the state transportation department and the regional transit providers to ensure
that transportation facilities will be delivered concurrent with development. However,
Bbecause these state and regional transportation facilities are not within the Citys
control, construction of projects to mitigate the impacts of the alternatives cannot be
guaranteed. Thus, impacts on state and regional facilities are considered a significant
unavoidable adverse impact. The City will coordinate with WSDOT regarding the
impacts of either the alternatives on state facilities. The City has a track record of
coordinating with WSDOT on improvements to state and regional facilities, as exhibited
by the recent addition of HOV lanes to SR 99.
Midway Subarea
54B
Full implementation of the roadway mitigation measures discussed for the Proposal/FEIS
Review Alternative relies on state actions, such as completion of the SR 509 plan as well
as City policy decisions and available revenues. The City works closely with the state, the
ports, the county, other jurisdictions, and many other stakeholders to ensure that the SR
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September 2011
509 project continues to be a priority in the state and the region. Furthermore, the City
probably has more influence over this project and can count on this happening more than
it can influence high-capacity transit projects. The City has no control over the timing,
scope, phasing, or delivery of transit, nor the amount of capacity that transit provides in
the future to this area, but the City will continue to work with both WSDOT and the
regional transit providers to assure that transportation facilities will be delivered
concurrent with development. Furthermore, the City will monitor traffic operations at
individual intersections along the SR 99 corridor and, in collaboration with WSDOT and
the City of Des Moines, will be able to respond as needed with an appropriate
combination of mitigation measures for impacts. Because the City does not have control
over the implementation of the SR 509 project, the full mitigating effects of the Midway
Subarea mitigation projects (Table 3.5-12Section 3.5, Transportation of the DEIS and
Table 1.4 above) cannot be guaranteed. Thus, all intersection and roadway impacts
identified under the Proposal/FEIS Review Alternative are considered significant
unavoidable adverse impacts.
1.5.6. Public Services and Utilities

20B
Kent Planning Area

5B
There are no identified significant unavoidable adverse impacts for public services and
utilities in the Kent Planning Area. All impacts can be mitigated by mitigation measures
identified above.
Midway Subarea
56B
There are no identified significant unavoidable adverse impacts for public services or
utilities in the Midway Subarea. All impacts can be mitigated by mitigation measures
identified above.
1.5.7. Noise
21B
Kent Planning Area

57B
With implementation of mitigation measures noted previously, neither the Proposal nor
the No Action none of the Aalternatives would cause significant unavoidable adverse
noise impacts in the Kent Planning Area.
Midway Subarea
58B
With implementation of mitigation measures noted previously, neither the Proposal nor
the No Action none of the Aalternatives would cause significant unavoidable adverse
noise impacts in the Midway Subarea.
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Chapter 2. Description of Alternatives
2.1. Introduction
The Draft Environmental Impact Statement (DEIS) issued on October 22, 2010,
presented a description of two alternatives and an evaluation of several
environmental elements. The Final Environmental Impact Statement (FEIS)
completes the environmental review process for the Proposal by revising or clarifying
portions of the analysis and responding to comments on the DEIS. This section of the
FEIS repeats the description of the Proposal and No Action Alternative, as well as
describes another alternative, the FEIS Review Alternative, which addresses
refinements to the Midway Subarea Plan since publication of the DEIS. Text that has
been inserted or deleted since the DEIS is shown in strikeout or underline format.
References to the FEIS are to this document; whereas, references to the EIS include
the DEIS and the FEIS.This chapter provides a description of the Proposal and No
Action Alternative.
2.1.1. Proposal Overview

To accommodate future population and employment growth, the City of Kent (City)
is proposing the following three actions:
Kent Planning Area (the City and Potential Annexation Area). Complete programmatic
impact evaluation for alternative growth strategies to accommodate up to an
additional estimated 25,773 households and 35,183 jobs between the 2006 base
year and a 2031 horizon year (see Figure 2-1). The additional growth would be
focused in Downtown, the Midway Subarea, and five potential Activity Centers
identified as Benson/240th, Benson/256th, Kent-Kangley/132nd, Panther Lake,
and Meeker/Washington. Specific updates to the City of Kent Comprehensive
Plan (Comprehensive Plan) and zoning amendments are proposed only for the
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September 2011
Midway Subarea. If the City later wishes to implement a growth strategy for
these other areas, the following policy and code amendments would be required:
Update of the Comprehensive Plan Land Use Plan map and policy text to
reflect the strategy; and
Update of the Zoning Districts map and text to support the Comprehensive
Plan update.
Midway Subarea. Adopt the Midway Subarea Plan and incorporate it into the Kent
Comprehensive Plan, adopt Comprehensive Plan and City of Kent Zoning map
and text amendments, including design guidelines, to implement it.
Midway Planned Action Area (i.e., the northern Transit-Oriented Community
[TOC]portion of in the Midway Subarea). Adopt a planned action ordinance for the
northern portion of the Midway Subarea Plan located in closest to planned
high-capacity transit improvements along in the vicinity of Pacific Highway
South (State Route [SR] 99).
2.1.2. Proposal Objectives

The Citys objectives for this Proposal are as follows:
Explore alternative growth concepts in the Kent Planning Area to form the basis
for future policy decisions about accommodating projected household and
employment growth through 2031 and beyond; and prepare the City for its
upcoming state-mandated Comprehensive Plan update. 1
Adopt the Midway Subarea Plan to facilitate increased intensity of development
with a mix of land uses that would increase revenues, job opportunities, and
housing choices, in proximity to the SR 99 corridor where bus rapid transit exists
and in the vicinity where high-capacity transit is planned.
Implement a planned action ordinance in the northern portion of the Midway
Subarea to increase the level of certainty about development potential in the area
nearest the future high-capacity transit station. The planned action ordinance
would streamline State Environmental Policy Act (SEPA) review for future
development proposals within that area, by addressing up-front the likely
environmental impacts associated with the overall master development plan.
2.2. Planning Process

2.2.1. Growth Management Act
The Growth Management Act (GMA)adopted by the 1990 Washington State
legislature and amended periodically thereaftercontains a comprehensive
1 RCW 36.70A.130 as amended by SSB-6611 in the 2010 Washington Legislative session establishes the deadline
for the Citys update of its Comprehensive Plan as December 1, 2014.
2-2
City of Kent Comprehensive Plan Review
and Midway Subarea Planned Action EIS
Description of Alternatives
framework for managing growth and development in local jurisdictions. King County
and all cities within it are subject to the requirements of GMA.
Comprehensive plans for all cities planning under the GMA must include elements
for land use (including a land use map), housing, transportation, capital facilities,
economic development, parks and recreation, and utilities. Each city must plan to
accommodate a share of projected regional growth; and its comprehensive plan must
also ensure that existing and planned infrastructure can support planned growth at a
locally acceptable level of service (LOS).
2.2.2. City of Kent Comprehensive Plan

The City prepared a Comprehensive Plan that was adopted in 1977. At that time, the
City was approximately 16 square miles and had a population of 17,500 persons. By
1995, the Citys land area increased to 19.5 square miles and the population exceeded
42,000 persons. This rapid growth, along with the advent of the GMA, provided the
impetus for the City to prepare a Comprehensive Plan in 1995 that was in line with
GMA requirements. Since that time, the City has updated its Comprehensive Plan
periodically as warranted, including the state-mandated 2004 Comprehensive Plan
update. Since 2005, the Comprehensive Plan has been updated through the Citys
annual docket amendment process. The next scheduled most recent amendment will
occurred by the end of 2010 on April 19, 2011, for a docket applications submitted
on September 1, 20092010. The Revised Code of Washington (RCW) 36.70A.130, as
amended by SSB-6611 in the 2010 Washington State Legislative session, requires
that the City conduct a comprehensive evaluation of its Comprehensive Plan by
December 1, 2014.
The Kent Comprehensive Plan contains nine elements that outline goals and policies,
seven of which are mandated by the GMA: Land Use, Transportation, Capital
Facilities, Housing, Utilities, Parks, and Economic Development. The plan also
includes two elements that are optional under GMA: Community Design and Human
Services. The goals and policies of the Citys Shoreline Master Program (SMP)
became the Shoreline Element of the Comprehensive Plan upon adoption by the
Washington State Department of Ecology (Ecology) on February 11, 2010.
These diverse elements are integrated into a single planning document. Each of the
elements has been coordinated with the others to result in a plan that is both
internally consistent and consistent with the GMA and King County Countywide
Planning Policies (CPPs).
2.2.3. Midway Subarea Plan

The cities of Kent and Des Moines have engaged in a joint planning effort (called
Envision Midway) for the Midway Subarea centered on SR 99 that serves as a
boundary between the two cities (Figure 2-2). The mission and goals of Envision
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September 2011
Midway were established collaboratively by the Kent and Des Moines city councils
and guided extensive public involvement. The mission statement of the Envision
Midway Subarea planning process is as follows:
To transform the Midway community into a sustainable urban area which

enhances commercial development and optimizes its geographic location,
wide range of transportation options, educational institutions, and views.
The Envision Midway goals include:
1. Provide a mix of land uses that increase revenues, job opportunities, and housing
choices.
2. Reconcile development standards along the border between the cities of Kent and
Des Moines to be consistent and reflect the vision for the study area.
3. Provide for public participation in the development of land use policies,
development regulations, and implementation strategies within the study area.
4. Provide appropriate land uses and regulations that support Bus Rapid Transit
within the Pacific Highway corridor.
5. Identify preferred alignments for light rail and the associated station and stop
locations within Kent and Des Moines.
6. Ensure design that provides a safe and inviting pedestrian environment.
The City has identified two portions of the Midway Subarea as a transit-oriented
community (TOC) that allows for mixed-use, transit-supportive development. The
northern TOC area, which includesalong with the Kent Highlands area located at the
northeast quadrant of the intersection of Interstate (I)-5 and Kent-Des Moines Road,
makes up the area where the City has proposed a planned action ordinance
(Figure 2-2). The southern TOC area is centered on the intersection of SR 99 between
S 268th Street and S 272nd Street.
2.2.4. Development Regulations

Development regulations are intended to implement the goals and policies of the
Comprehensive Plan by providing specific development standards and regulations.
Zoning regulations guide land uses, building heights, building setbacks, parking, and
other standards related to the development and use of land. Design guidelines provide
a framework of design options for ensuring a proposed development is sensitive to its
area context, both existing and planned.
2-4
FIGURE 2-1
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2.3. Planned Action

This section defines a planned action, outlines the geographic extent of the proposed
Midway Planned Action Area, and describes the Planned Action Environmental
Impact Statement (EIS) and planned action ordinance.
2.3.1. Planned Action Overview

According to Washington Administrative Code (WAC) 197-11-164, a planned action
is defined as a project that has the following characteristics:
is designated a planned action by ordinance;
has had significant environmental impacts addressed in an EIS;
has been prepared in conjunction with a comprehensive plan, subarea plan,
master planned development, a phased project, or with subsequent or
implementing projects of any of these categories;
is located within an urban growth area;
is not an essential public facility; and
is consistent with an adopted comprehensive plan.
The City proposes to designate a portion of the Midway Subarea shown on
Figure 2-2 as a planned action, pursuant to SEPA and implementing rules.
If the planned action ordinance is adopted, the City would follow the applicable
procedures contained in the ordinance and outlined in Section 2.4.6, Proposal to
determine if the proposed project impacts are consistent with the Planned Action EIS.
2.3.2. Planned Action Environmental Impact Statement

The significant environmental impacts of projects designated as planned actions must
be identified and adequately analyzed in an EIS (WAC 197-11-164). Planned action
projects should only be designated as such when a city can reasonably analyze the
area and specific impacts that would occur as a result of the types of projects
designated. The Midway Subarea Plan efforts within the planned action area
(Figure 2-2) provide a framework to complete a planned action level of review in the
EIS.
2.3.3. Planned Action Ordinance

WAC 197-11-168 requires the ordinance designating the planned action to include
the following:
description of the type of project action being designated as a planned action;
2-8
description of how the action meets the definition and criteria of a planned action
as outlined in state law;
finding that probable significant adverse environmental impacts of the planned
action have been identified and adequately addressed in an EIS; and
identification of mitigation measures that must be applied to a project for it to
qualify as a planned action.
Following the completion of the EIS process, the City intends to designate the
Midway planned action by ordinance. The ordinance would identify mitigation, as
described in theis Draft Environmental Impact Statement (DEIS) and this FEIS,
which would be applicable to future area-specific development actions. Mitigation
could include requirements that would apply to all development in the planned action
area as well as measures that may apply on a case-by-case basis. Please see the
Planned Action Ordinance narrative in Section 2.4.6, Proposal, for more information.
2.4. Environmental Review

The purpose of the environmental review in the DEIS is to provide an analysis of the
probable natural and built environment impacts of the No Action Alternative, and the
Proposal, and the FEIS Review Alternative, and identify appropriate mitigation
measures. The DEIS is information wasis made available to City decision makers,
other agencies, and the public for 3230 days (see Fact Sheet). Following the comment
period, the City will prepared thisa Final Environmental Impact Statement (FEIS)
that will responds to comments and may provide a Preferreddescribes an FEIS
Review Alternative that reflects refinements to the Proposal for the Midway Subarea.
2.4.1. Prior Environmental Review

The DEIS for the Comprehensive Plan was issued on July 18, 1994. An FEIS for the
Comprehensive Plan was issued on January 30, 1995. The City updated its
Comprehensive Plan in 2004, in compliance with the state requirement of updating
the plan. The Citys 2004 Comprehensive Plan update was adopted by
Ordinance No. 3698 with an effective date of August 19, 2004. From 1995 to 2009
there have been addenda and SEPA analyses covering a variety of topics including
individual property rezones among other things. A list of previous environmental
documents related to the Comprehensive Plan amendments since 2004 is provided
below:
2004 Comprehensive Plan Update, July 20, 2004;

Rezones to Implement 2004 Comprehensive Plan Update, November 2, 2004;
adoption of School District Capital Facilities Plans, December 14, 2004;
Downtown Strategic Action Plan, April 19, 2005;
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September 2011
2004 Annual Comprehensive Plan Land Use Plan map and zoning amendments,
April 19, 2005;
Urban Density Study, November 15, 2005;
2005 Annual Docket of Comprehensive Plan Updates, April 4, 2006;
Muth Amendment, November 7, 2006;
Annual Amendment to Comprehensive Plan Capital Facilities Element and
Amendment to Comprehensive Plan and zoning designations Citywide relating to
publicly owned property for parks and open space, June 5, 2007;
Reconciling Single-Family Residential (SFR) designations Citywide including
considering Lake Meridian Subbasin designations, June 5, 2007;
Draft SEIS for Kent Events Center (approve special use combining district for
Kent Events Center), February 2007;
Final SEIS for Kent Events Center (approve special use combining district for
Kent Events Center), May 2007;
Adoption of Transportation Master Plan and Comprehensive Plan Transportation
Element, June 17, 2008;
2008 Amendment to Comprehensive Plan adopting 2008 Water System Plan and
2008 Drainage Master Plan and incorporating them into Comprehensive Plan
Capital Facilities Element, September 92, 2008;
Approval of updated City of Kent Shoreline Master Program including goals and
policies as an element of the Citys Comprehensive Plan, September 15, 2009;
and
2008 Annual Docket Amendment to Capital Facilities and Park and Open
Space Elements adopting the Park and Open Space Plan, inventory of streets and
bridges, and reference to 2008 Transportation Master Plan, May 4, 2010.
2010 Annual Docket - Amendment to Comprehensive Plan Land Use Plan Map
for Kentara Short Plat Lot 21, April 19, 2011.
Where appropriate, prior environmental review was assessed in the course of
preparing theis DEIS.
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2.4.2. Level of Analysis

SEPA (RCW 43.21C) requires government officials to consider the environmental
consequences of actions they are about to take and better or less damaging ways to
accomplish these proposals. The officials must consider whether the Proposal will
have a probable significant adverse environmental impact on the following elements
of the natural and built environment: earth, water, plants and animals, energy and
natural resources, environmental health, land and shoreline use, transportation, and
public services and utilities.
This The DEIS considers considered potential environmental impacts in the Kent
Planning Area at a programmatic level of detail, and at a more detailed level for a
smaller geographic area consisting of the Midway Subarea, which in part is being
considered for a planned action ordinance.
Kent Planning Area

This The DEIS provides provided a qualitative and quantitative analysis of
environmental impacts as appropriate to the general nature of a comprehensive plan
update. The adoption of comprehensive plans or other long-range planning activities
is classified by SEPA as a nonproject (i.e., programmatic) action. A nonproject action
is defined as an action that is broader than a single site-specific project, and involves
decisions on policies, plans, and programs. An EIS for a nonproject proposal does not
require site-specific analyses; instead, the EIS discusses impacts and alternatives
appropriate to the scope of the nonproject proposal and to the level of planning for
the proposal (WAC 197-11-442).
The Kent Planning Area consists of the existing City limits as well as the Citys
Potential Annexation Area (Figure 2-1). In general, environmental analysis for the
Kent Planning Area has been conducted at a cumulative planning area level. This
broad cumulative review applies to evaluation of alternative growth concepts,
potential City-initiated changes to land use classifications, and updates to the Citys
household and employment projections extending to a 2031 planning horizon.
SEPA encourages the use of phased environmental review to focus on issues that are
ready for decision and to exclude from consideration issues already decided or not
yet ready for decision-making (WAC 197-11-060(5)). Phased review is appropriate
where the sequence of a proposal is from a programmatic document, such as an EIS
addressing a comprehensive plan, to other documents that are narrower in scope,
such as those prepared for site-specific, project-level analysis. The City is using
phased review in its environmental review of the Comprehensive Plan for the Kent
Planning Area with a programmatic review of alternative growth concepts and
potential plan amendments. Examples of proposals that may require more area-
specific or site-specific SEPA review when more details are known include, but are
not limited to capital improvement projects, and private development applications.
2-11
September 2011
Midway Subarea including Planned Action Area

The Midway Subarea is defined as an area located on the western edge of the Kent
City limits, generally centered on SR 99 between S 272nd Street on the south and the
Kent-Des Moines Road (SR 516) on the north. The western limit of the Midway
Subarea is the Kent City limits, and the eastern edge extends east of Military Road to
the edge of the ridge to include the Kent Highlands property and south of SR 516 to
include a cluster of commercially zoned properties. The Kent Highlands property, a
former Seattle Public Utilities landfill, and associated smaller parcels located
northeast of the intersection of I-5 and SR 516 isare also included in the Midway
Subarea (see Figure 2-2 for the Midway Subarea boundaries). The City plans to
complete a planned action ordinance in the northern a portion of the Midway
Subarea, to encourage redevelopment particularly in proximity to a planned light rail
station which is anticipated to be located near in the vicinity of Highline Community
College. The Kent Midway Planned Action Area, where the planned action ordinance
is anticipated to apply, would consist of the northern portion of the Midway Subarea,
generally north of S 246th Street and including the Kent Highlands property and
associated smaller parcels.
Because this portion of the City is being considered for a planned action ordinance,
and to allow the City some flexibility in determining its final planned action
boundaries, this DEIS provides an area-specific discussion of the Midway Subarea
under each element of the environment that encompasses the Midway Subarea
boundary shown on Figure 2-2. Where appropriate, the DEIS also identifies
area-specific mitigation measures to address identified impacts. The DEIS also
establishes recommended threshold levels, where appropriate references existing or
proposed regulations, and prescribes mitigation measures for impacts to allow future
development that falls within these thresholds or complies with prescribed
regulations/mitigation to proceed with minimal future SEPA review. Please refer to
Section 2.4.6, Description of AlternativesThe Proposal, for an additional discussion
of the Midway Subarea.
2.4.3. Scope of Review

Pursuant to SEPA Rules (WAC 197-11-408), the City requested public and agency
comment on the scope of the DEIS. This was accomplished through publication of a
Determination of Significance (DS)/Scoping Notice on February 13, 2010 (see
Appendix A of the DEIS). Interested citizens, agencies, organizations, and affected
tribes were invited to submit comments on the scope of the DEIS during the scoping
period, which closed on March 8, 2010.
During this period, the City solicited public comment through a February 22, 2010
open house meeting. Please see Section 2.4.4, Public Comment, for an additional
description of these public involvement opportunities.
2-12
This DEIS analyzes, at a programmatic level, the potential impacts on the following
elements of the environment identified through the scoping process.
Natural Environment,
Air Quality,
Land Use Patterns and Plans and Policies,
Aesthetics,
Transportation,
Public Services and Utilities, and
Noise.
2.4.4. Public Comment

An open house was held at City Hall on February 22, 2010, to take public comment
on the Proposal and to provide information on public input regarding the
environmental review process. The open house included information stations for the
Midway Subarea Plan, the Planned Action Process, and the Comprehensive Plan
Update Proposal. The City maintained the scoping materials at public information
counters in the planning department. Two people submitted comments at the open
house. The City also received three additional written comments submitted to the
Responsible Official prior to the March 8, 2010 comment deadline.
The five comments received during the scoping period include:
1. Provide a grocery store between Downtown and the base of the hill at
Gowe/Titus Street (received at the open house). The location of land uses and
land patterns within the Kent Planning Area are addressed in Section 3.3, Land
Use Patterns and Plans and Policies of the DEIS.
2. Need for parks, soccer fields, and baseball fields in the West Hill and Midway
Subarea in particular as growth occurs there (received at the open house). Parks
and recreation facilities in the Midway Subarea are addressed in Section 3.6,
Public Services and Utilities of the DEIS.
3. The location of wetlands and their buffers within the Midway Subarea (written
comment received March 2, 2010). Wetlands within the Midway Subarea are
addressed in Section 3.1.2 of Natural Environment of the DEIS.
4. Written comments received on March 4, 2010, covering the following topics:
a. Changes that are anticipated to local streets/circulation system to
accommodate proposed densities and how those changes would affect SR 99
in terms of vehicle operations and transit operations.
Section 3.5, Transportation of the DEIS, addresses assumptions for future
local street and circulation network in the Midway Subarea and how those
2-13
September 2011
changes would impact SR 99 in terms of vehicle operations. Impacts on

SR 99 transit operations are addressed qualitatively in Section 3.5,
Transportation of the DEIS.
b. The effect of future alternative development patterns on future mode split.
Section 3.5 of the DEIS, Transportation, addresses mode split assumptions
based upon future mixed-use development patterns within the centers and
corridors being considered for future growth by the City (Figure 2-3).
c. The relationship of future development in Midway Subarea east of SR 99 on
future development at Highline Community College campus.
Section 3.3, Land Use Patterns and Plans and Policies of the DEIS
qualitatively addresses relationship of land use patterns and compatibility in
the Kent portion of the Midway Planned Action Area on the Highline
Community College campus and the West Hill in general.
5. Give consideration to a long-term (50-year) build-out scenario, particularly for
the Midway Subarea. Also give consideration to an overlay zone in the Midway
Subarea that creates additional entitlements without creating any nonconforming
uses (written comments received March 8, 2010). Although not extending to
2060, as suggested by the commenter, the Citys Proposal for 2031 provides
greater land use capacity, and therefore acts as a kind of future build-out scenario
which may occur in 2031, or later, depending on market conditions and other
factors.
2.4.5. Overview
The two alternatives studied in theis DEIS are as follows:
Proposal. The Proposal would review and evaluate alternative growth scenarios in
the Kent Planning Area in anticipation of the future state-mandated
Comprehensive Plan update 2, and adopt a subarea plan for the Midway Subarea
and a planned action ordinance for the northern portion of the Midway Subarea.
No Action Alternative. The No Action Alternative would maintain the current
Comprehensive Plan and associated development regulations with no changes to
the Midway Subarea.
In addition to the two alternatives studied in the DEIS, the FEIS Review Alternative
is also addressed in the FEIS. This alternative falls within the range of the Proposal
and the No Action Alternative.
As described in Section 2.4.2, Level of Analysis, the analysis area for theis DEIS is
divided into the Kent Planning Area, consisting of the existing City limits and the
Citys Potential Annexation Area (Figure 2-1) for the programmatic EIS review, and
2 SSB-6611-passed in the 2010 Washington Legislative session establishes the deadline for the Citys update of its
Comprehensive Plan as December 1, 2014.
2-14
the Midway Subarea Plan shown on Figure 2-2 for the more detailed planned action
environmental review.
2.4.6. The Proposal

The Proposal consists of exploring alternative growth scenarios in the Kent Planning
Area for the Comprehensive Plan as noted under Comprehensive Plan discussion
below and adopting the Midway Subarea Plan and a planned action ordinance for the
northern portion of the Midway Subarea Plan as noted under the Midway Subarea
Plan discussion below. See Figure 2-3 for centers and corridors considered under the
Proposal.
Comprehensive Plan
The Proposal explores different growth concepts for the Kent Planning Area in
anticipation of a future Comprehensive Plan update meeting the requirements of
RCW 36.70A.130(4). The Proposal would retain the Citys existing vision and
framework policies, but would amend the Comprehensive Plan in the following
ways:
include new housing and employment capacity;
extend the planning horizon to the year 2031;
update relevant background information;
amend land use designations and implement zoning and development regulations,
including design guidelines, in the Midway Subarea;
lay the groundwork for future amendments to land use designations, zoning and
development regulations in the potential Activity Centers and other parts of the
Kent Planning Area; and
implement other amendments to goals and policies that maintain the internal
consistency of the Comprehensive Plan.
In addition to the above, the update to the Comprehensive Plan would account for all
annexations occurring since the 1994 Comprehensive Plan EIS and include the Citys
current Potential Annexation Areas in the analysis in anticipation of future
annexation efforts in these areas.
Population Growth and Employment Projections

The City plans for population and employment growth by working collaboratively
with other cities to agree on each citys share of the growth targets through the King
County Growth Management Planning Council. The City periodically forecasts its
land use capacity for both population and employment. To calculate capacity, the
City estimates the maximum development potential of vacant or redevelopable
properties under current land use designations. This total development potential is
reduced to account for current market factors, environmentally sensitive areas, right-
of-way needs, and public developments such as parks and schools. The results are
2-15
September 2011
summarized as households for residential land and jobs for commercial land. In 2008
and 2009, the City worked through the King County Growth Management Planning
Council to develop new population and employment targets that extend to the 2031
planning horizon. These 2031 growth targets were ratified by King County
jurisdictions in May 2010. 3 In addition, the City Council established strategic goals
for economic development in Downtown, West and East Hill commercial areas. The
Citys initial analysis of its buildable lands capacity, along with its more recent
reassessment of long-term growth potential in the Urban Center under the Citys
current Comprehensive Plan and zoning indicated that the City would have sufficient
capacity to meet 2031 targets, but that meeting established 2031 targets would use up
its existing capacity. Therefore, the City reviewed its options and developed
alternative future growth concepts that could result in future changes to
Comprehensive Plan land use designations and zoning, particularly focusing in the
Midway Subarea (Figure 2-4), and areas to be potentially designated as Activity
Centers in the Comprehensive Plan that would allow the City not only to
accommodate the anticipated growth in population and employment through 2031,
but to create additional capacity for future growth. These growth concepts could
result in future changes to Comprehensive Plan land use designations and zoning,
particularly focusing in the Midway Subarea (Figure 2-4) and areas to be potentially
designated as Activity Centers in the Comprehensive Plan. These changes to the
Citys land use designations and zoning, and the growth that they would allow are the
subject of the Proposal for the Kent Planning Area.
When the City accounts for anticipated changes in the Proposal that include focusing
additional household and employment growth in Downtown, the Midway Subarea,
and the five potential Activity Centers noted below, and extends its planning horizon
from 2022 to 2031, the City projects that it has the capacity to accommodate an
additional 25,773 households and 35,183 jobs beyond the 2006 base year. The
Proposal would add a potential for 20,487 more households and 11,688 more jobs to
the Kent Planning Area than the No Action Alternative.
Additional growth above and beyond that anticipated in the existing Comprehensive
Plan (No Action Alternative) is expected to be concentrated in Downtown, the
Midway Subarea, and the other potential Activity Centers where mixed-use
development and multimodal transportation investments, including high-capacity
transit in the Midway Subarea, are expected to occur. A comparison of Figures 2-5
and 2-6 shows that the main difference in growth in households between the two
alternatives is the amount of growth anticipated in the Midway Subarea. A much
larger percentage of new growth occurs in the Midway Subarea under the Proposal
than the No Action Alternative.
3 The 2031 growth targets amend the planning period to 2006-2031. The Citys growth targets were amended to be
7,800 dwelling units (plus 1,560 dwelling units in the Potential Annexation Area), and 13,200 jobs (plus 290 jobs in
the Potential Annexation Area) (Growth Management Planning Council Motion 09-2). The City has 3 years from
ratification to amend its comprehensive plan for consistency with the amended targets.
2-16
FIGURE 2-3
CENTERS AND CORRIDORS

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A smaller, but still substantial, growth in households is anticipated in the Downtown,

and the Benson/240th Activity Center and Panther Lake Activity Center under the
Proposal compared to the No Action Alternative. Although the area outside of centers
and corridors (labeled as the Rest of Kent) sees a growth in population under the
Proposal compared to the No Action Alternative, this area makes up a much smaller
proportion of the overall households under the Proposal compared to the No Action
Alternative.
Figure 2-5. Comparison of Total Households2006 and 2031 Alternatives

80,000
70,000
Rest of Kent
60,000
Meeker/Washington
50,000
Panther Lake
40,000 Kent-Kangley/132
30,000 Benson/256
Benson/240
20,000
Midway Subarea
10,000
Downtown
-
2006 No Action Proposal
Source: Anderson pers. comm. November 2009.
Figure 2-6. Comparison of Household Growth Share by Alternative (20062031)

100%
90%
80% Rest of Kent
70% Meeker/Washington
60% Panther Lake
50% Kent-Kangley/132
40% Benson/256
30% Benson/240
20% Midway Subarea
10% Downtown
0%
No Action Proposal
2-20
The Midway Subarea Plan is addressed specifically later in this section.
A review of Figures 2-7 and 2-8 shows that the areas outside of centers and corridors
in the Kent Planning Area retain the majority of jobs under all alternatives. However,
job growth in the Midway Subarea is noticeably greater under the Proposal compared
to the No Action Alternative. Downtown shows a similar increase in jobs as the
Midway Subarea, but because Downtown has a larger percentage of jobs under
existing conditions, the change is not as dramatic there as in the Midway Subarea.
Although all potential Activity Centers, as commercially zoned areas, show increases
in job growth under both alternatives, the Benson/240th Activity Center is the only
Activity Center showing a substantial increase under the Proposal compared to the
No Action Alternative.
Figure 2-7. Total Jobs2006 and 2031 Alternatives

100,000
90,000
80,000 Rest of Kent
70,000 Meeker/Washington
60,000 Panther Lake
50,000 Kent-Kangley/132
40,000 Benson/256
30,000 Benson/240
20,000 Midway Subarea
10,000 Downtown
-
2006 No Action Proposal
2-21
September 2011
Figure 2-8. Comparison of Job Growth Share by Alternative (20062031)

100%
90%
80% Rest of Kent
70% Meeker/Washington
60% Panther Lake
50% Kent-Kangley/132
40% Benson/256
30% Benson/240
20% Midway Subarea
10% Downtown
0%
No Action Proposal
Downtown
The Citys Downtown (including its designated Urban Center) would accommodate
additional population and employment under the Proposal. However, this area was
already designated to receive significant additional growth under the No Action
Alternative. The City anticipates that additional growth in Downtown under the
Proposal would not be a result of changes in zoning, or changes to development
standards, but mostly by means of intensifying economic development activities and
facilitating partnerships, and using other similar measures to encourage development
and redevelopment that would not otherwise occur. An example of these efforts
includes passing an amended multifamily development tax exemption, which
exempts property tax on new multifamily development in Downtown for a period of
8 years. Under the Proposal, Downtown is expected to accommodate
3,874 households and 12,366 jobs compared to 1,392 households and 7,863 jobs
accommodated under the No Action Alternative (Figure 2-9).
2-22
Figure 2-9. Downtown Growth in Households and Jobs (20062031)

10000
9000
8000
7000
6000
5000 Proposal
4000 No Action
3000
2000
1000
0
New Households New Jobs
Activity Centers
The potential Activity Centers are intended to accommodate mixed-use development
at higher intensities than found in other commercial areas outside of Downtown. The
Land Use Element describes these areas generally as having an existing base of
retail and office uses, and are typically surrounded by medium-density residential
areas (p. 4-30). Under the Proposal, the five potential Activity Centers would
accommodate 17,936 households and 10,361 jobs, compared to 15,413 households
and 9,699 jobs under the No Action Alternative (Figure 2-10).
Figure 2-10. Activity Centers Growth in Households and Jobs (20062031)

4500
4000
3500
3000
2500
Proposal
2000
No Action
1500
1000
500
0
2-23
September 2011
Several of these potential Activity Centers are already identified on the

Comprehensive Plan Land Use Plan map as having Mixed Use (MU) designations.
The maximum geographic extent of the potential Activity Centers would be generally
all commercially designated property within a 0.25-mile distance of key arterial
intersections (see Figure 2-3 for a map of centers and corridors). For the City to
accommodate the envisioned changes within the Activity Centers studied under the
Proposal, some changes to the Comprehensive Plan would be needed, as well as
zoning changes to allow mixed use, increased building heights, and site 4 coverage;
changes to design review requirements, and relaxed parking standards. Changes to
street standards and building codes may be needed to facilitate pedestrian activity and
encourage increased building heights (Anderson pers. comm. August 2009).
The potential Activity Centers are listed below:
Benson/240th
Benson/256th
Kent-Kangley/132nd
Panther Lake (Benson/208th)
Meeker/Washington
Benson/240th
This Activity Center focuses on the intersection of Benson (104th Avenue SE) and
SE 240th Street, extending from 100th Avenue SE in the west to 108th Avenue SE in
the east, from SE 236th Street in the north to SE 244th in the south. One of the early
automobile-oriented commercial areas in the City, the transformation of the
Benson/240th Activity Center is envisioned to include high intensity mixed-use
redevelopment within existing commercial areas. Under the Proposal, growth in this
Activity Center is anticipated to accommodate 4,204 households in 2031 compared to
2,783 households under the No Action Alternative. The Proposal would increase
employment to 3,029 jobs in this Activity Center compared to 2,464 jobs under the
No Action Alternative. Under the Proposal, buildings featuring a mix of commercial
and residential uses would be built to the backs of sidewalks and have a maximum
height of around ten floors. Building heights would taper down to a maximum of
three floors near the edges of the Activity Centerapproximately 0.25 mile from the
intersection of Benson and SE 240th Street. The maximum height under the No
Action Alternative (existing zoning) in this Activity Center would range from
approximately three to four stories, depending on the zone. Site coverage in this
Activity Center would increase under the Proposal from the existing 30% to 60%
range to something closer to the standard of 100% site coverage allowed in
4The City regulates site coverage in Title 15 of the Kent City Code. KCC 15.02.490 defines site coverage as that
portion of a lot covered by buildings or structures.
2-24
Downtown. Structured parking would be encouraged, either attached to buildings or

located toward the edges of the Activity Center, if constructed as stand-alone
facilities. Infill development could use existing internal parking area circulation
(Anderson pers. comm. August 2009).
The design of streets, landscaping, buildings, and transportation facilities would

establish and reinforce a more relaxed environment favoring transit, walking,
bicycling, and shopping. The comfort and security of visual recognition between
building occupants and persons at the street level would be significantly diminished
above the third or fourth floor, particularly in areas with narrower streets. Therefore,
buildings would generally be set back from streets above this height to balance the
need for eyes on the street with access to sunlight. Mature street trees could also
soften the relationships between buildings and streetscapes. Demand for regular
transit service would be anticipated to increase in terms of local and regional service
in this area, as identified in the Transportation Master Plan (TMP) (Anderson pers.
comm. August 2009).
Benson/256th
This potential Activity Center would stretch from the intersection of two designated
state routes (Benson SR 515 and Kent-Kangley SR 516), north to the SE 25200 block
of Benson, south to SE 260th Street, west to 101st Avenue S, and east to the
10700 block of SE 256th Street and Kent-Kangley Road. Under the Proposal,
redevelopment of underused land would enable the transformation of this
automobile-dominated area to higher intensity mixed use. The Proposal would
slightly increase the amount of residential to 4,965 compared to 4,908 under the
No Action Alternative, and employment would slightly decrease to 3,272 jobs
compared to 3,302 jobs under the No Action Alternative. Buildings in this Activity
Center would taper down from a maximum height closest to the key intersections of
around eight floors to approximately three floors at the edges of the Activity Center.
These heights would compare to a No Action Alternative maximum height range of
two-and-a-half to three stories in height. Site coverage in this Activity Center would
increase under the Proposal from the existing 30% to 40% range to something closer
to the standard of 100% site coverage allowed in Downtown (Anderson pers. comm.
August 2009).
Street and landscaping requirements ensuring safe and comfortable pedestrian and
bicycle circulation would be consistent with the future vision for this area. The
intersection of Benson and 256th would be the key focal point, but the intersection of
Kent-Kangley and SE 256th Street would also be important as the initial gateway into
the Activity Center from the east. As several transit routes serve these intersections,
increasing the pedestrian orientation of the streetscape would be critical to connecting
the benefits of transportation mode choice to the envisioned mixed-use
redevelopment of the area. Structured parking would be encouraged away from the
key intersections and street frontages (Anderson pers. comm. August 2009).
2-25
September 2011
Kent-Kangley/132nd
The focus of this potential Activity Center is the intersection of Kent-Kangley Road
and 132nd Avenue SE, extending north to the 26900 block of 132nd Avenue SE,
south to the 27500 block of 132nd Avenue SE, west to 128th Place SE and east to the
13300 block of Kent-Kangley Road. This Activity Center is anticipated to
accommodate 3,017 households and 881 jobs in 2031 under the Proposal, as
compared to 2,848 households and 768 jobs under the No Action Alternative. The
existing shopping centers at the northwest and southwest corners of the intersection
of 132nd Avenue SE and Kent-Kangley Road are seen as ripe opportunities for infill
mixed-use development on large surface parking lots. Maximum heights of six floors
under the Proposal could be accommodated with structured parking tucked beneath,
and lower heights would necessitate maintenance of a portion of existing surface
parking. This compares to the maximum height under the No Action Alternative of
three stories. Site coverage in this Activity Center would increase under the Proposal
from the existing 30% to 60% range to something closer to the urban standard of
75% to 100% site coverage allowed in other parts of the City (Anderson pers. comm.
August 2009).
The internal circulation roadways in the shopping centers could provide the
framework for a street network with sidewalks and other pedestrian amenities. The
eastern portions of this Activity Center are much smaller and have environmental and
adjacent residential use constraints to their expansion. Some redevelopment may be
possible in these areas, though with less intensity. Transit service frequency
improvements identified in the TMP would be anticipated to serve the increased
number of residents in the area (Anderson pers. comm. August 2009).
Panther Lake (Benson/208th)

The potential Panther Lake Activity Center extends from the intersection of Benson
(108th Avenue SE) and SE 208th Street north to SE 204th Street, south to SE 212th
Street, west to the 10300 block of SE 208th, and east to the 11100 block of SE 208th.
Prior to annexation by the City of Kent on July 1, 2010, this area was designated by
King County as Community Business (CB) for many years, though development and
redevelopment have not yet fulfilled these intentions. Upon annexation to the City,
most of the potential Activity Center was designated MU on the Comprehensive Plan
Land Use Plan map (Anderson pers. comm. August 2009).
The late 1960s marked the beginning of sporadic infill of this once agricultural area
to strip commercial. Given the lack of accessible commercial land in proximity to
existing residential capacity in this area, a vision for the future of this area under the
Proposal would focus on serving unmet local demand for commercial retail and
office uses. The Panther Lake Activity Center is expected to accommodate 3,142
households and 936 jobs in 2031 under the Proposal compared to 2,664 households
and 955 jobs under the No Action Alternative. Pedestrian-oriented mixed use would
be encouraged, particularly through infill development on existing surface parking
2-26
lots. Under the Proposal, the intensity of development in this Activity Center would
be marked by buildings topping out at four stories, with some structured parking. The
Proposal height is similar to, the height allowed under the No Action Alternative
using the Citys existing zoning. Site coverage in this Activity Center would increase
under the Proposal from the existing 40% to 60% range to near 100% site coverage,
which is allowed in Downtown (Anderson pers. comm. August 2009).
Meeker/Washington
Immediately west of Downtown and just beyond the underpasses of SR 167, the
Meeker/Washington area is an area long planned for mixed-use development. This
Activity Center extends from the intersection of Washington Avenue, designated as
SR 181, and Meeker Streetnorth to the 500 block of Washington Avenue N, south
to the Kent-Des Moines Road (SR 516), west to near 64th Avenue S and east to
SR 167. Washington Avenue has been widened in the last 10 years to reduce traffic
congestion and improve freight mobility. A result of this improvement has been an
increase in traffic speeds for most vehicular traffic outside of peak travel periods,
thereby making the pedestrian environment a bit less welcoming (Anderson pers.
comm. August 2009).
Recent redevelopment to large ministorage complexes in this area provides an

additional challenge to identifying remaining suitable locations in this Activity
Center for pedestrian-oriented mixed use development. As a result, under the
Proposal this area would change minimally regarding pedestrian orientation, but
some mixed-use redevelopment and infill development would be possible. The
Meeker/Washington Activity Center would accommodate 2,608 households and
2,243 jobs under the Proposal compared to 2,210 households and 2,210 jobs under
the No Action Alternative. With a few exceptions, the buildings in this area would
not likely exceed three stories under the Proposal, similar to the No Action
Alternative. Site coverage in this Activity Center would increase under the Proposal
from the existing 30% to 40% range to near the urban standard of 75% to 100% site
coverage, which is allowed in other parts of the City (Anderson pers. comm. August
2009).
Midway Subarea Plan

The Proposal would amend Comprehensive Plan and zoning designations in the
Midway Subarea Plan to implement the mission statement and goals for this portion
of the City as developed through the Envision Midway subarea planning process, and
adoption of a planned action ordinance for a portion of the subarea called, for
purposes of this EIS, the Midway Planned Action Area.
Amendments proposed for the Midway Subarea would include adopting the Midway
Subarea Plan as a subarea appendix to the Comprehensive Plan, adopting one or
more Comprehensive Plan Land Use Plan Map amendments to implement the goals
2-27
September 2011
and policies of the Midway Subarea Plan; amending the Zoning Districts map to be
consistent with proposed amendments to the Comprehensive Plan Land Use Plan
map; and adopting zoning and development regulations, including design guidelines,
to implement the goals and policies of the Midway Subarea Plan (see Table 2-5).
Specific amendments to comprehensive plan, land use plan map designations, zoning,
and development regulations may include, but are not limited to:
Amend the City of Kent Capital Facilities and Transportation elements of the
Comprehensive Plan to include all necessary capital improvements and a
multi-year financing plan based on a minimum of 10-year transportation needs
identified in the Comprehensive Plan, including those supporting growth in the
Midway Subarea under the Proposal;
Changes to land uses permitted in the TOC to allow and encourage high density
retail, office, and residential types of development while discouraging or
prohibiting stand alone big-box, drive-through, and other auto-oriented uses in
the TOC;
Changes to building heights, requiring a minimum of two stories. Additional
height above 65 feet is allowed through an incentive program to a maximum of
200 feet;
Development of transition regulations for areas adjoining single-family
neighborhoods located outside the northern TOCMidway Planned Action Area
and the high-intensity development anticipated to occur within the northern
TOCMidway Planned Action Area; 5
Requirement that pedestrian or vehicular throughways be developed at intervals
to encourage multi-modal transportation and to connect development with public
parks, trails, streets, or other public amenities;
Establishment of design guidelines that promote a pedestrian-friendly,
transit-supportive, and unique identity of the TOC;
Promotion of environmentally sustainable building design and landscaping
practices that, among other things, takes into account solar access, water and
energy conservation, and emphasizes natural drainage systems;
Establishment of maximum parking requirements and other revisions to parking
standards designed to encourage use of alternative modes of transportation; and
Regulation of parking location and design to minimize the effect of parking on
the pedestrian environment.
5Although the City was developing and reviewing draft zoning map options and development regulation options
with its Land Use and Planning Board during development of the Proposal, the map and development regulations
options were not used in preparation of the Proposal. The Proposals description of transition regulations was based
on review of the Draft Midway Subarea Plan goals and policies and the Draft Midway Design Guidelines.
2-28
Figure 2-11 shows the anticipated changes to the Midway Subarea under the
Proposal. The amendments accompanying the Midway Subarea Plan are expected to
allow the City to accommodate 11,821 households and 9,481 jobs in the Midway
Subarea in 2031 compared to 2,179 households and 3,721 jobs that would be
anticipated under the No Action Alternative.
Figure 2-11. Midway Subarea Growth (20062031)

12000
10000
8000
6000 Proposal
No Action
4000
2000
0
Source: Anderson pers. comm.
The Proposal would also include adopting a planned action ordinance for a subset of
the Midway Subarea called for purposes of this EIS, the Midway Planned Action
Area (Figure 2-2). This smaller area encompasses a TOC located proximate to the
future light rail station anticipated to be located near in the vicinity of Highline
Community College and the Kent Highlands redevelopment area. The Midway
Planned Action Area is expected to accommodate 8,449 of the households and 7,328
of the jobs found in the Midway Subarea by 2031. This compares to 425 households
and 1,794 jobs that could be accommodated in the Midway Planned Action Area
under the No Action Alternative. The Proposal for the Midway Planned Action Area
represents the vast majority of the housing and job growth expected in the Midway
Subarea.
Planned Action Ordinance

The Proposal includes adopting a planned action ordinance. Review of a planned
action is intended to be simpler and more focused than for other projects. When a
permit application and environmental checklist are submitted for a project that is
being proposed as a planned action project, the City must first verify the following:
The project meets the description of any project(s) designated as a planned action
by ordinance or resolution.
2-29
September 2011
The probable significant adverse environmental impacts were adequately

addressed in the DEIS.
The project includes any conditions or mitigation measures outlined in the
ordinance or resolution.
If the project meets the above requirements, the project qualifies as a planned action
project and a SEPA threshold determination is not required. However, the following
City actions (i.e., the permit process) are still applicable (this permit process is
illustrated on Figure 2-12):
The project must continue through the Citys permit process pursuant to any
notices and other requirements contained in the Citys development regulations.
The project must still be analyzed for consistency with the Citys zoning and
development regulations.
Designation of a planned action project does not limit the City from using other
authority (e.g., a conditional use permit) to place conditions on a project. The
City may still use applicable laws or regulations to impose conditions on a
project qualifying as a planned action project.
Public notice for a planned action project is tied to the underlying permit. If
notice is otherwise required for the underlying permit, then the notice will
indicate that the project qualifies as a planned action.
The manner in which the City would monitor the development levels approved in the
Midway Planned Action Area would likely be as follows:
Determine if the proposed land uses are within categories of land use studied in
theis DEIS,
Establish the maximum development potential within the Midway Planned
Action Area as reviewed in theis DEIS. Development potential can be expressed
in terms of total vehicle trips, square feet of development, and/or other methods.
As specific development is proposed, deduct from the Midway Planned Action
Areas development potential. The planned action ordinance would establish how
methods of measuring projected development capacity relate to one another if
more than one method is used.
Appendix AB contains a draft of the planned action ordinance including the
information on the draft process and the parameters used to determine consistency
with DEIS assumptions.
2-30
1 2 3
Prepare Adopt Planned Review Planned
EIS Action Ordinance Action Projects
Developer submits application

and environmental checklist
Questions Additional
each proposed project: NO environmental
Q1 If a project is a Planned Action with no further SEPA
review required
environmental review, can the City add additional Is it within the Planned
conditions to the project? Action area?
A1 Yes, but not for aspects that are addressed by Is the project within the
the Planned Action Ordinance, and only if scope of the Planned
authorized by city regulations. Action Ordinance? Standard City
permit process
Q2 How will citizens know about a Planned Are environmental impacts
Action project? within the scope of the
Planned Action EIS?
A2 Public notice of Planned Action projects is tied
to the development review process for the Does it include mitigation
underlying permit. If public notice is measures or conditions
otherwise required for the underlying outlined in Planned Action
permit, then the notice will indicate Ordinance?
that this is a Planned Action project.
YES
941.08/Graphics
Standard City permit process
Figure 2-12
Planned Ac on Area Development Process
City of Kent Comprehensive Plan Review and Midway Subarea Planned Ac on EIS
2.4.7. No Action Alternative

The evaluation of a No Action Alternative is required by SEPA. This alternative
assumes that the Comprehensive Plan is not updated and that a planned action
ordinance and associated Comprehensive Plan and zoning amendments are not
adopted for the Midway Subarea or Activity Centers.
Comprehensive Plan
Under the No Action Alternative, the City would retain its existing Comprehensive
Plan without amendments noted above. The City would not update its
Comprehensive Plan to anticipate revised land use assumptions and distribution of
growth; goals and policies related to Activity Centers would not be amended; and
updated functional plans would not be incorporated into the Comprehensive Plan.
Growth and redevelopment under the No Action Alternative would be limited to

what is allowed under the current Comprehensive Plan. The No Action Alternative
would assume a continuation of existing population and employment growth trends
without changing the horizon year to 2031. The City would accommodate an
additional estimated 5,285 households and an additional estimated 23,496 jobs in
2031 compared to the 2006 baseline year. In contrast to the Proposal, the No Action
Alternative estimates of future household and employment growth are based upon
Puget Sound Regional Council (PSRC) forecasts that the City used in preparation of
its TMP. Although the Citys Downtown, Activity Centers, and Midway Subarea
would see additional concentration in household and employment growth under
existing land use designations and regulations, the area outside of these areas would
see a larger percentage of growth than under the Proposal. In addition, growth outside
these areas would likely be more auto-oriented and auto-dependent than that
anticipated to occur under the Proposal.
Midway Subarea Plan

Under the No Action Alternative, the City would not adopt amendments to the
Comprehensive Plan, Land Use Plan map, Zoning Districts map, zoning and
development regulations, design guidelines, or a planned action ordinance to
implement the vision for this part of the City developed as part of the Envision
Midway subarea planning process.
Population and employment growth under the No Action Alternative would be

limited to that which is allowed under the current Comprehensive Plan. Growth in
households and jobs would be assumed to continue as allowed under existing
Comprehensive Plan policies and zoning regulations to the horizon year of 2031. The
No Action Alternative assumes an increase of 262 households and 1,538 jobs would
be accommodated in the Midway Subarea by 2031 compared to the base year. This is
2-32
9,642 fewer households and 5,760 fewer jobs than anticipated under the Proposal.
The smaller Midway Planned Action Area (northern TOC) would accommodate an
increase of 129 households and 1,103 jobs in 2031 under the No Action Alternative.
This is 8,024 fewer households and 5,534 fewer jobs than anticipated under the
Proposal. A planned action ordinance to facilitate development in the area proximate
to the planned light rail station in the vicinity of Highline Community College light
rail station and Kent Highlands redevelopment area conforming to the vision of the
Midway Subarea Plan would not be adopted under the No Action Alternative.
2.4.8. FEIS Review Alternative
Kent Planning Area

The FEIS Review Alternative is the same as the Proposal for the portion of the Kent
Planning Area outside of the Midway Subarea. The FEIS Review Alternative would
provide the same level of household and employment growth as the Proposal with
growth anticipated to occur in the same areas as the Proposal. The main difference
between the FEIS Review Alternative and the Proposal are described under the
Midway Subarea heading below.
Midway Subarea
The FEIS Review Alternative for the Midway Subarea assumes a phased approach to
the same level of future growth within the Midway Subarea. It would also provide
more specific zoning to implement the land use concept of the subarea plan. 6 The
FEIS Review Alternative falls within the range of the Proposal and No Action
Alternative for the Midway Subarea.
Phasing of growth is assumed due to the economic downturn and Sound Transits
delay in providing planned light rail service to the Midway Subarea. Under the FEIS
Review Alternative, a low level of growth is assumed to continue for the first 10
years of the planning periodcomparable to what is assumed for the No Action
Alternativefollowed by a higher level of growth in the second 10 years
comparable to the growth assumed under the Proposal. Because growth is assumed to
be phased over time, the City plans to phase in Comprehensive Plan amendments
necessary to support the higher level of growth in the subsequent 10-year period as
well.
6 Although the City was developing and reviewing draft zoning map options and development regulation options
with its Land Use and Planning Board during development of the Proposal, the options were not used in preparation
of the Proposal. The Proposal relied on the Draft Midway Subarea Plan and Draft Midway Design Guidelines.
However, the FEIS Review Alternative is based on the Citys recommended options for zoning map and
development regulations, in addition to updated drafts of the Midway Subarea Plan and Midway Design Guidelines
that were included in the November 22, 2010 Land Use and Planning Board public hearing packet (see Appendices
B through E).
2-33
September 2011
Regarding building height, the FEIS Review Alternative would continue to include
maximum height limits in the TOC of up to 200 feet, as described in the DEIS. Also
similar to the Proposal, the FEIS Review Alternative addresses proximity of more
intensive TOC areas to lower intensity residential districts. The FEIS Review
Alternative includes a finer level of detail with respect to implementing regulations
than the Proposal, including a new zoning designation (Midway Transit Community
1, or MTC-1);, centered on SR 99 north of approximately S 245th Street and south of
S 268th Street, that has a maximum building height of five stories or 55 feet. The
MTC-1 zone, which abuts SR 99 in the TOC, as well as several areas of low intensity
residential development in the City of Des Moines, assumes the following height
transitions to existing residential districts abutting the TOC areas: a maximum
building height of 35 feet within 20 feet of existing residential districts and a
maximum height of 45 feet within 40 feet of a residential district. The combination of
the lower maximum height in the MTC-1 zone, and the implementation of lower
transition heights when adjacent to existing residential districts, helps mitigate the
effects of taller buildings in this area. Given the presence of the I-5 freeway and
topography, height transitions are not implemented in the other Midway zones
(MTC-2 and MCR) with heights up to 16 stories or 200 feet located east of the MTC-
1 zone in the northern TOC. In these zones with taller maximum heights, the
implementation of proposed Midway Design Guidelines relating to height, bulk, and
scale would help provide transitions between taller buildings, public uses and less
intensive zone edges. Height, bulk and scale design guidelines would include, among
others, those calling for increased building setbacks from a less intensive zone edge,
and stepping back upper stories of buildings from the original footprint starting at the
third story and once again at seven stories.
The FEIS Review Alternative differs from the Proposal for the Midway Subarea in
the following ways:
(Figure 6 in the Draft Midway Subarea Plan) which identifies Midway Subarea
Land Use Plan Map designations. Changes to the Land Use Plan Map compared
to the Proposal include adding a small portion of area near the Midway
Highlands west of Military Road into a TOC designation.
flexibility in the land uses allowed to provide a transition from existing auto-
oriented land uses located throughout the Midway Subarea to a dense pedestrian-
friendly form, particularly in the TOC areas. For example, the FEIS Review
Alternative would allow new single-story construction, rather than requiring
buildings to be a minimum of two stories in height.
growth and identifies street improvements needed for the latter half of the
planning period, identifies a city-wide transportation analysis and funding
structure, and incorporates them into the Citys 2014 Comprehensive Plan update
(see Policy MT-4.4). Until such time as these improvements are added to the
2-34
Citys Comprehensive Plan Transportation Element and the Citys Transportation

Master Plan, the No Action Alternative level of growth is assumed in the
Midway Subarea.
findings, including adding parallel northsouth transportation routes that serve as
an alternative to SR 99, accounting for transportation system management (TSM)
techniques, as well as adding language on coordinating with the City of Des
Moines and Washington State Department of Transportation (WSDOT) on a
local connection at the I-5/SR 509 interchange, as identified in the DEIS (new
policy MT-1.4).
MTC-1) with a lower maximum height (five stories or 55 feet) is applied to the
entire MTC-1 zone. In addition, the MTC-1 zone would provide further height
restrictions of 35 feet in height within 20 feet of a residential district, and 45 feet
in height within 40 feet of a residential district, for example adjacent to lower
intensity residential districts located further to the west, residential districts east
of the southern TOC area, and at two locations abutting the Mobile Home Park
(MHP) residential district. Other implementing zones (Midway Transit
Community-2 [MTC-2], and Midway Commercial/Residential [MCR]), with
maximum heights of 200 feet or 16 stories are located farther east in the northern
Midway TOC.
Does not include minimum building heights or maximum parking standards
though parking provisions are addressed through design guidelines.
Overall, the FEIS Review Alternative for the Midway Subarea Plan assumes the
same level of growth as the Proposal, but phases it, and refines the approach to
2.4.9. Alternatives Comparison

Tables 2-1 and 2-2 below summarize key features of the Proposal and No Action
Alternative for the Kent Planning Area.
Table 2-1. City of Kent Comprehensive Plan EIS Growth Alternatives

Comparison
Proposal/ FEIS
Review No Action
Features Base Year (2006) Alternative (2031) Alternative (2031)
Total households 43,120 68,893 48,405
Total jobs 58,419 93,603 81,915

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September 2011
Table 2-2. City of Kent Comprehensive Plan EIS Alternatives Comparison

Proposal/FEIS Review Alternative
Features (2031) No Action Alternative (2031)
Changes to Activity The Proposal growth scenario No changes to
Centers aAssumes the following changes to Comprehensive Plan related
the five identified Activity Centers: to Activity Centers or changes
Emphasis on mixed uses; to the Zoning Districts map, or
zoning and development
Allow for greater building heights standards related to Activity
and site coverage; Centers.
Encourage good design and
aesthetics in new construction;
Assumes future changes to code
that minimize the effect of on-site
parking;
Future policy and development
standards facilitate pedestrian
connectivity within the Activity
Centers.
Additional Amends the Comprehensive Plan No amendments to the
Comprehensive Plan and/or Comprehensive Plan Land Use Comprehensive Plan or
amendments Plan map as follows: Comprehensive Plan Land
See Midway Subarea Plan below Use Plan map.
Provides framework to allow future
amendments to Comprehensive
Plan Land Use Plan map for
designated Activity Centers to allow
for varying increases in mixed-use
development intensity as noted
above.
Amendments to the Amends the Zoning Districts map as No amendments to the Zoning
Zoning Districts map follows: Districts map
See Midway Subarea Plan below
Provides framework to allow future
amendments to Zoning Districts
map with new Activity Center
zoning designations to allow for
varying increases in mixed-use
development intensity as noted
above.
Amendments to the For Midway Subarea, see Table 2-53 No amendments to the zoning
zoning code below. code or development
Provides the framework to allow future standards, including street
amendments to the City of Kent standards and building code.
Zoning Code and development
regulations to implement anticipated
changes in the Comprehensive Plan
for Activity Centers as follows:
Allow for and encourage mixed use;
Allow increase in heights;
Allow greater site coverage on lots;
Revise design review requirements
to facilitate mixed-use
development;
Relax parking standards; and
Amend street standards and
building code to facilitate
pedestrian activity and encourage
2-36
Proposal/FEIS Review Alternative

Features (2031) No Action Alternative (2031)
increased building height in
designated Activity Centers.
Additional incentives Assumes implementation of Assumes no additional
for development in additional incentives for incentives for development
Downtown (including development and redevelopment of and redevelopment in
Urban Center) Downtown to achieve a higher FAR Downtown to achieve higher
within existing zoning, including but FARs.
not limited to implementation of a
multifamily tax exemption.
FAR = floor area ratio
Table 2-3 below provides a comparison of the growth anticipated to occur in

Downtown and the Activity Centers under the Proposal and No Action Alternative.
Table 2-3. Alternatives Comparison by Centers and Corridors

Proposal/
FEIS Review
Base Year Alternative No Action
Geographic Area (2006) (2031) Alternative (2031)
Downtown
Total Households 895 3,874 1,392
Total Jobs 3,682 12,366 7,863
Benson/240th
Total Households 2,399 4,204 2,783
Total Jobs 1,798 3,029 2,464
Benson/256th
Total Jobs 2,440 3,272 3,302
Kent-Kangley/132nd
Total Jobs 649 881 768
Panther Lake
Total Jobs 858 936 955
Meeker/Washington
Total Jobs 1,688 2,243 2,210
Outside Centers and Corridors
(except Midway Subarea see
Table 2.4)
Total Jobs 45,120 61,395 60,633
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September 2011
Tables 2-4 and 2-5 summarize key features of the Proposal and No Action
Alternative for the Midway Subarea Plan portion of the DEIS.
Table 2-4. Midway Subarea Plan Growth Alternatives Comparison

Proposal/FEIS Review No Action
Features Base Year (2006) Alternative (2031) Alternative (2031)
Midway Subarea
Total Jobs 2,183 9,481 3,721
Midway Planned Action Area (Northern TOC)
Total Households 296 8,449 425
Total Jobs 691 7,328 1,794
Table 2-5. Midway Subarea Plan Alternatives Comparison

Proposal/FEIS Review Alternative No Action Alternative
Features (2031) (2031)
Amendments related to the adoption of Midway Subarea Plan
Amendments to the Includes the following amendments to Assumes no amendments

Comprehensive Plan the Land Use Plan map based upon the to the Land Use Plan map
Land Use Plan map Midway Subarea Plan: based on Midway Subarea
Amend from a combination of Plan.
Commercial (C), MHP, Low Density
Multifamily (LDMF), Medium Density
Multifamily (MDMF), Single Family 6
Units/Acre (SF-6), and Mixed Use
(MU) future land use designation to
one or more a new TOC designations
for the Midway Planned Action Area,
located north of S 245th Street, and
the portion of the Midway Subarea
located south of S 268th Street.
Amendments to the Includes the following amendments to Assumes no amendments
zoning Districts map the Zoning Districts map based upon the to the Zoning Districts
Midway Subarea Plan: map based on Midway
Amend the Zoning Districts map for Subarea Plan.
the Midway Planned Action Area from
a combination of General Commercial
(GC), Community Commercial (CC),
MHP, High Density Multifamily (MR-
H), Garden Low Density Multifamily
(MR-G), Community Commercial-
Mixed Use (CC-MU),
Townhouse/Condo (MRT-16),
Industrial Park (M-1), Commercial
Manufacturing II (CM-2), and
Professional Office (O) to one or more
zoning designations that will
implement the goals and policies of
the Midway Subarea Plan.
Implementing zoning designations are
identified as MTC-1, MTC-2, and
MCR. In addition, the existing MHP
zoning district is retained for existing
mobile home parks, and the existing
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Features (2031) (2031)
CC and CM-2 zoning districts are also
implemented in portions of the
Midway Subarea Plan, mostly outside
the northern TOC.
Amendments to Includes the following amendments to Assumes no amendments
Comprehensive Plan the Comprehensive Plan text based on to the Comprehensive
text the Midway Subarea Plan: Plan text based on
Add the Midway Subarea Plan to the Midway Subarea Plan.
Comprehensive Plan as a subarea
appendix, or otherwise incorporate
the subarea plan into the
Comprehensive Plan,
Amend the Capital Facilities and
Transportation elements of the
Comprehensive Plan to include all
necessary capital improvements and
a multi-year financing plan based on a
minimum of 10-year transportation
needs identified in the
Comprehensive Plan, including those
supporting growth in the Midway
Subarea, and
Amend existing Comprehensive Plan
text to retain internal consistency
between the Midway Subarea Plan
and the rest of the Comprehensive
Plan.
Prior to implementation of these
amendments, only the No Action
Alternative level of growth is assumed
for the Midway Subarea.
Amendments to zoning Includes the following amendments to Assumes no amendments

regulations the zoning regulations applicable to the to the zoning regulations
Midway Planned Action Area and other based on Midway Subarea
parts of the Midway Subarea based on Plan.
the Midway Subarea Plan:
Change land uses allowed in the TOC
to allow and encourage high-density
retail, office, and residential
development, while discouraging or,
in some cases, prohibiting auto-
oriented uses.
Establish implementing zoning and
development standards for new TOC
designations, including the new MTC-
1, MTC-2, and MCR zoning districts.
Include in the MTC-1 zone transition
regulations for areas adjoining single-
family neighborhoods located outside
the planned action area, and
transition heights for areas within 40
feet of residential districts.
Require that pedestrian or vehicular
throughways be developed to provide
connectivity.
Establish design guidelines that
promote a pedestrian-friendly, transit-
supportive environment;
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September 2011

Features (2031) (2031)
Promote environmentally sustainable
building design and landscaping
practices.
Establish parking requirements and
other revisions to parking standards
designed to minimize the effects of
surface parking on the environment
and to encourage use of alternative
modes of transportation.
Planned action Includes City adoption of a planned Assumes the City does
ordinance action ordinance to facilitate not adopt a planned action
development within the limits outlined in ordinance.
the planned action ordinance.
Source: City of Kent 2009.
In summary, the City is reviewing alternative locations for growth. Citywide the City
seeks a more compact growth pattern in Downtown, and other Activity Centers
where housing can be added to commercial nodes. The City may select a
combination of the Activity Centers as they explore future growth patterns. In the
Midway Subarea, the City has refined an alternative following a joint planning
process with the City of Des Moines and Midway citizens. After considering three
alternatives (see Section 2.6, Alternatives Previously Considered and Future
Alternatives) the Proposal was selected for additional study since it concentrates
mixed use development around future light rail stations identified as part of Sound
Transits Sound Transit 2 Regional Transit System Plan that was passed by the
regions voters in 2008. The City has mademay make adjustments among the
Proposal and No Action Alternative as it moves toward adoptingcompletes the
Midway Subarea Plan that are reflected in the FEIS Review Alternative. The FEIS
Review Alternative assumes a similar amount of growth as the Proposal over a longer
period of time, and with lower heights in areas where the TOC abuts residential
districts. The City may make additional adjustments among the Proposal, FEIS
Review Alternative, and No Action Alternative as it completes the Midway Subarea
Plan adoption process.
2.5. Benefits and Disadvantages of Delaying the

Proposal
SEPA requires a discussion of the benefits and disadvantages of reserving, for some
future time, the implementation of a proposal compared to possible approval at this
time. In other words, the City must consider the possibility of foreclosing future
options by implementing the Proposal.
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There are several benefits to adopting a Comprehensive Plan that includes new
household and employment forecasts and updated goals and policies that focus future
development in the potential Activity Centers.
There is a greater range of housing choices and a diversified employment base.

It prepares the City for the state-mandated 7-year Comprehensive Plan update
with household and employment forecasts required to 2031.
It guides development and City resource allocations to meet forecast trends along
with the community vision.
There are also several benefits to adopting the Midway Subarea Plan, and associated
policy and code amendments, in addition to adopting a planned action ordinance for
the Midway Planned Action Area.
It provides land use guidance for near-term investments in bus rapid transit and
long-term investments in light rail along in the vicinity of the SR 99 corridor.
It coordinates land use planning with the neighboring City of Des Moines.
It guides the development and City resource allocations to meet the forecast
population and employment attracted to the subarea by transportation
investments.
It facilitates development in an area with the capacity to support higher-intensity
TOC.
It places the City in a good position to coordinate with Sound Transit for future
light rail alignment and station locations in the Midway area.
Delaying implementation of the Proposal would allow for growth to occur on the
basis of the current Comprehensive Plan and zoning regulations. However, it would
not prepare the City for its 2014 Comprehensive Plan update, nor would it provide a
land use regulatory environment supportive of bus rapid transit investments occurring
on the SR 99 corridor at this time (beginning in Octoberfall 2010).
Delaying implementation of the Proposal could delay natural environment impacts on

vacant and underdeveloped lands in the Activity Centers, Downtown, and the
Midway Subarea. However, the delay could also increase development pressure on
lands located outside of the Activity Centers, Downtown, and the Midway Subarea as
development pressure would continue without the focus to these centers provided in
the Proposal/FEIS Review Alternative.
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September 2011
2.6. Alternatives Previously Considered and Future

Alternatives
The Envision Midway planning process developed three potential growth alternatives
entitled Transit-Oriented Village, Transit-Oriented Centers, and Transit-Oriented
Corridor that were eliminated from consideration during the Envision Midway
planning process. The Proposal most closely reflects a fourth alternative known as
Land Use Scenario 3.0 which condensed mixed-use development into nodes
around future light rail stations. The City may make adjustments in the range of the
Proposal/FEIS Review Alternative and No Action Alternative as it completes
consideration of the Midway Subarea Plan.
Regarding the Kent Planning Area, this DEIS provides a range of growth and land
use patterns between the Proposal and No Action Alternative. In the future the City
may consider alternatives that fall within this range. For example, the City may
include such an alternative in the Final EIS based upon public comment.
Major Issues to be Resolved
The City plans to use this DEIS to help it resolve the following:
Refinement of implementation measures for the Midway Subarea Plan, including

but not limited to Comprehensive Plan goals and policies, development
regulations, and design standards guidelines for the Midway Subarea.
Refinement of Comprehensive Plan goals, objectives, and policies and
development regulations applicable to the Citys Comprehensive Plan update.
Identification of areas where capital improvements are needed to address future
growth in population and employment.
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Chapter 3. Environmental Analysis
3.1. Kent Planning Area
As described in Chapter 2 of the Final Environmental Impact Statement (FEIS), the
FEIS Review Alternative outside of the Midway Subarea is the same as the Proposal
for the Kent Planning Area. Under the FEIS Review Alternative, the same level of
overall household and employment growth is anticipated as under the Proposal, and
growth would be concentrated in the same centers and corridors as described under
the Proposal. The principal differences are found within the Midway Subarea, where
the FEIS Review Alternative incorporates a phased approach to growth, and
refinements that include recommended zoning map and regulations provide for more
detailed assessment of impacts and mitigation related to subjects such as land use and
aesthetics. See Midway Subarea below for this environmental analysis relating to the
FEIS Review Alternative.
3.2. Midway Subarea

The FEIS Review Alternative for the Midway Subarea assumes a phased approach to
the same level of future growth within the Midway Subarea. It would also provide
more specific zoning to implement the land use concept of the subarea plan
(Appendices D and E of the FEIS). Overall, the FEIS Review Alternative for the
Midway Subarea is similar to the Proposal, and falls within the range of the Proposal
and the No Action alternatives studied in the Draft Environmental Impact Statement
(DEIS). This chapter analyzes the differences related to the FEIS Review Alternative
in the Midway Subarea for the elements of the environment studied in the DEIS.
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September 2011
3.2.1. Natural Environment

Impacts of the FEIS Review Alternative would be similar to those of the Proposal for
the natural environment because both alternatives would include the same amount of
household and employment growth. Growth would be concentrated in the same
Transit-Oriented Community (TOC) areas as described under the Proposal, including
the Midway Planned Action Area (northern TOC) and the southern TOC area. Since
these TOC areas and the majority of the remaining Midway Subarea would be largely
built out with buildings, surface parking, and other impervious surfaces dominating
the environment, it is likely that even with increases in site coverage standards under
the Proposal or FEIS Review Alternative, redevelopment of the subarea would
replace one type of impervious surface with another (i.e., smaller building footprint
with surface parking replaced by larger building footprint with much of the parking
contained within a structure), resulting in little or no additional impervious surfaces,
stormwater volume, or runoff. Some excavation for construction would occur, but
would not result in a significant loss of vegetation or soil productivity.
Focus of new development in the largely built-out Planned Action Area and other
developed areas of the Midway Subarea would avoid impacts on most categories of
environmentally sensitive areas; in the locations where there are environmentally
sensitive features, critical area regulations would apply. Conversion of existing
underdeveloped land to development would be greatest on the former landfill area,
since most other portions of the Planned Action Area are already developed.
However, land use conversions in these areas would not result in significant loss of
habitat function. Some grassy areas of the former Kent Highlands landfill could be
converted to mixed-use developments, but with essentially no loss in habitat function
since this area provides little ecological function and the sites are highly altered.
Further, as described in the reuse plans developed for these sites and in compliance
with development codes and conditions of restrictive covenants placed on these
properties, it is likely that large portions of both former landfill sites would remain as
passive open space under both alternatives.
Additionally, while some vacant lands would see new impervious surfaces,
development in the Midway Subarea would likely have minimal impacts on the
limited natural resources within the Midway Subarea; with the implementation of the
Citys stormwater standards, water quality would be protected with development of
vacant sites and water quality would improve on redevelopable properties since these
were originally developed without such standards.
Therefore, the FEIS Review Alternative would have similar or less impact than the
Proposal on the natural environment.
3.2.2. Air Quality

air quality because both alternatives would include the same amount of household
3-2
Environmental Analysis
and employment growth which would generate a similar level of air quality impact as
the Proposal.
3.2.3. Land Use Patterns and Plans and Policies

The FEIS Review Alternative would result in a similar, but less intense impact on
land use patterns and plans and policies as the Proposal for the Midway Subarea.
Although the City was considering various options for amendments to zoning maps
and development regulations in the Midway Subarea, the Proposal was primarily
based on draft Midway Subarea Plan goals and policies and draft Midway Subarea
Design Guidelines. The FEIS Review Alternative would include updates of both of
these documents (Appendices B and C), as well as a draft zoning map (Appendix D)
and draft development regulations that implement the goals and policies contained in
the draft Midway Subarea Plan (Appendix E). As such, the FEIS Review Alternative
provides a more detailed review of potential land use impacts in the Midway
Subarea.
The FEIS Review Alternative would provide greater flexibility for transitioning
existing land uses to those envisioned under the Midway Subarea Plan by allowing a
slightly wider range of uses within the zoning districts that implement the TOC
Comprehensive Plan designation in the Midway Subarea, and by eliminating the
Proposals requirement for a minimum of two stories in height for new development
within the TOC designation. In addition, the FEIS Review Alternative would also
eliminate maximum on-site parking standards included as part of the Proposal for the
Midway Subarea. The net effect of these changes to land uses and development
standards that allow for flexibility in uses would be that existing land uses and
development types in the TOC are likely to remain longer and provide a longer
timeframe for transition to the more intense mixed-use development types envisioned
for the Midway Subarea.
The FEIS Review Alternative would also provide a finer detail of implementing
zoning for the Midway Subarea by specifying zones with lower heights along State
Route (SR) 99 in the north and south TOC designations (MTC-1 zone). These lower
maximum heights would provide a transition to lower intensity residential zones to
the west in Des Moines, and would also allow for a more consistent scale of
development on both sides of SR 99 whether the development is in Kent or Des
Moines. The zones with taller maximum heights (MTC-2 and MCR) would be
located in areas where they have natural or human-created buffers to existing
surrounding development, such as topography (e.g., the hillside between Midway and
the Green River Valley), wide right-of-way (e.g., Interstate [I]-5 and SR 516), and
undevelopable areas of the former Kent Highlands and Midway landfills. In addition
to the MTC-1 zone having a lower maximum height, it also includes provisions for
transitional height limits for development located adjacent to residential zonesin
this case, residential zones located to the west in the City of Des Moines, as well as
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September 2011
Kent residential districts located east of the southern TOC and at two locations
abutting the Mobile Home Park (MHP) residential district. Although the MTC-2 and
MCR zones that allow up to 200 feet in building height do not include transitional
height limits, topographic (e.g., slopes) and built environment (e.g., interstate and
state highways) features would provide transitions between the MTC-2 and MCR
zones and most areas abutting less intense zones. The proposed Midway Design
Guidelines would be applicable to the TOC areas. The preliminary draft Midway
Design Guidelines used to review the Proposal included guidelines addressing siting
of buildings and the transition between residences, street, and adjacent sites under the
Site Design category, as well as Height, Bulk and Scale under the Architectural
Design category. These guidelines have been updated since the Proposal and the
guidelines addressing the transition between newer and taller buildings and existing,
less intense uses and zones would help mitigate some of the impacts of more intense
uses and buildings on neighboring land uses. See the aesthetics analysis below for
more description of the Midway Design Guidelines.
Implementing the MTC-1 zone and its height transitions, the natural buffers found
through much of the subarea, and implementation of the design guidelines would
provide a more detailed transition between less intense zones located outside the
Midway Subarea and the more intense zoning designations found within the Midway
TOC than under the Proposal, greater compatibility of land uses. and transitions
between new, taller buildings and lower intensity existing uses in the Midway TOC.
The overall effect of the changes to zoning and development standards considered
under the Proposal, and implementation of more detailed zoning designations and
amended Midway Design Guidelines would be to provide for slightly less land use
pattern impact under the FEIS Review Alternative than under the Proposal.
With respect to other plans and policies, the FEIS Review Alternative would provide
a phased approach to implement the Midway Subarea Plan. Because of changes to
economic conditions and the planned delay in implementing Sound Transits light
rail service in the Midway Subarea, the City will plan for a lower level of growth
within the Midway Planned Action Area and the Midway Subarea as a whole for the
first 10-year period (Phase 1). This level of growth is expected to be similar to that
anticipated under the No Action Alternative. The higher levels of growth anticipated
under the Proposal would occur under the second 10-year period (Phase 2). The same
or similar amendments to the Comprehensive Plan and implementing zoning and
development standards required under the Proposal would be required as part of the
FEIS Review Alternative. However, amendments to implement these changes would
occur over a longer period, and would likely be coordinated with the next update to
3-4
the Transportation Master Plan and complete Comprehensive Plan update required by
the Growth Management Act. 1
3.2.4. Aesthetics
As described above, the FEIS Review Alternative uses drafts of implementing zoning
maps and development regulations, as well as updated drafts of the Midway Subarea
goals and policies and Midway Design Guidelines that were used to create the
Proposal. Overall, implementation of the FEIS Review Alternative would have less
impact on height and bulk and solar access/shading condition issues than the
Proposal, in which a maximum height of 200 feet was considered throughout the
TOC designations for the Midway Subarea.
The FEIS Review Alternative would include three Midway Subarea zones to
implement the Midway Subarea Plan. One zone, the MTC-1, applied on both sides of
SR 99 in the northern TOC and throughout the southern TOC, would provide a lower
maximum height than considered in the DEIS. The MTC-1 zone would allow a
maximum height of 55 feet per five stories rather than the 200 feet per 16 stories
maximum height considered in the DEIS. This would provide a transition between
sensitive uses, such as between lower intensity residential uses found west of the
Midway Subarea in the City of Des Moines and the MTC-2 zone, as well as provide
for lower maximum heights in the southern TOC than considered under the Proposal.
In addition to the lower maximum height, the development regulations for the MTC-
1 zone would include provisions for transitional height limits for development
located adjacent to residential zones. For example, the MTC-1 development
regulations state that no building in the MTC-1 zone shall exceed 35 feet within 20
feet of a residential zone, and no building shall exceed 45 feet in height within 40 feet
of a residential zone. These stepped height limits create a more gradual transition
between the SR 99 corridor and the lower intensity residential zones located along
the western boundary of the Midway Subarea where the MTC-1 abuts Des Moines
residential zones, as well as Kent residential districts located east of the southern
TOC, and at two locations abutting the MHP residential district. Overall, aesthetic
impacts related to height and bulk and shade and shadow would be less intense than
those described under the Proposal for the MTC-1 zone.
The other implementing zones within the Midway Subareas northern TOC, the
MTC-2, and the MCR zones would retain a maximum height of 200 feet per 16
stories, which is similar to what was considered under the Proposal in the DEIS.
Topographic (e.g., slopes) and built environment (e.g., interstate and state highways)
features would provide transitions between the MTC-2 and MCR zones and most
areas abutting less intense zones.
1 A complete review cycle refers to the 7 or 10 year review cycles in the Growth Management Act, whichever
comes first. The next complete review requirement is scheduled by December 1, 2014 for King County and its
cities. As the law is subject to amendment the City should verify the Acts requirements on a regular basis.
3-5
September 2011
The FEIS Review Alternative would also maintain the existing MHP zone on mobile
home parks in the Midway Subarea. These include existing sites abutting or
surrounded by the MTC-1, MTC-2, and CM-2 zones. MHP property owners that are
within the TOC Comprehensive Plan designation would be able to request a rezone to
another zoning designation applied within that Comprehensive Plan designation. It is
likely that existing mobile home parks located within or adjacent to the MTC-1 zone
would be able to rezone to that designation, and those located within or adjacent to
the MTC-2 zone would be able to rezone to that zoning designation, resulting in
similar height and bulk, and solar access and shading impacts as described for the
MTC-1 and MTC-2 zones.
Midway Design Guidelines are applicable to all zones within the Midway Subarea
TOC designation. The FEIS Review Alternative would provide amendments to some
of these design guidelines that would further encourage transitions from lower
intensity uses and residential zones to new development within the Midway TOC
zones (MTC-1, MTC-2, and MCR) (see Appendix C). These design guidelines call
for building design that considers adjacent lower intensity zoning districts that may
be affected by high-intensity development. The following excerpted design
guidelines are applicable to height and bulk and solar access/shading impacts 2.
Transition between Residence, Street, and Adjacent Sites

Overview
For residential projects, the space between the building and the sidewalk should
provide security and privacy and encourage social interaction among neighbors.
Buildings should respect adjacent properties, particularly less intensive uses.
Intent
To create a safe, attractive, and comfortable transition between private and public
spaces for residential uses.
Guidelines
Step back the upper floors, or increase the side or rear setback, so that
window and balcony areas are farther from the property line.
Height, Bulk and Scale

Overview
Projects should be compatible with the scale of development anticipated by the
applicable Zoning Districts for the surrounding area and should be sited and designed
2 The design standards included here were excerpted from the Draft City of Kent Midway Design Standards.
3-6
to provide a sensitive transition to nearby, less intensive zones as well as the

pedestrian environment.
Intent
Projects located along different zone edges or next to public spaces or which have
unusual physical characteristics such as large lot size, unusual shape, or topography,
should be developed in a manner that creates gradual transition in perceived height,
bulk, and scale.
Guidelines
Consider a variety of factors to address height, bulk and scale impacts on adjacent
properties with different zoning district designations, including the following:
Distance from the edge of a less intensive zone
Differences in development standards between abutting zones (allowable
building height, width, lot coverage, etc.)
Effect of site size and shape
Type and amount of separation between lots in the different zones (i.e.,
separation by only a property line, by a street, or by other physical features
such as grade changes).
Reduce height, bulk and scale of the proposed structure as needed to mitigate adverse
impacts to adjoining public amenities, including sidewalks, parks, and open space
and to achieve an acceptable level of compatibility, by including the following:
Articulate the ground floor building faade vertically or horizontally in
intervals that conform to new neighboring structures.
Step back building upper levels from original footprint starting at the third
story and once again when the building exceeds 6 stories to take advantage of
views, increase sunlight at street level, and create a pedestrian scale.
Set back buildings located at street intersection corners to promote visibility
and encourage pedestrians to gather.
Increase building setbacks from a less intensive zone edge.
Use architectural features to reduce building scale, such as:
Landscaping, trellis.
Variety of complementary building materials.
Detailing, accent trim, fenestration, or modulation.
Implementation of the above design standards within the MTC-1, MTC-2, and MCR
zones would help provide transitions between proposed tall buildings, adjacent lower
intensity residential zones, and, to a lesser extent, adjacent and nearby lower intensity
residential uses. Provision of the above Midway Subarea design standards, including
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September 2011
zones with a 200-foot maximum height, would make the aesthetics impacts
associated with height and bulk and solar access and shading conditions slightly less
intense than those anticipated under the Proposal for the Midway Subarea.
Under the FEIS Review Alternative, impacts on other aesthetic elements including
visual character, pedestrian environment, scenic views, and light and glare would be
similar to the Proposal.
3.2.5. Transportation
Transportation impacts of the FEIS Review Alternative would be similar to those of
the Proposal because both alternatives would include the same amount of household
and employment growth. Amendments to Midway Subarea goals and policies related
to transportation would also provide further refinement of the policy direction that
the City is moving toward in the Midway Subarea, supporting the transportation
analysis and impacts described under the Proposal. Although the proposed
transportation improvements needed for mitigation under the FEIS Review
Alternative are the same as considered under the Proposal, the phased growth under
the FEIS Review Alternative would allow the City time to phase in these projects.
The delay of light rail service and the economic recession results in the City
anticipating a lower level of growth and transportation improvements similar to those
described in the No Action Alternative for the first 10 years, with the higher level of
growth anticipated under the Proposal and the transportation projects needed for
mitigation of that level of growth (similar to that found in the Proposal) needed in the
second 10 years of the planning period. This change would also allow the phasing of
transportation and capital facilities amendments needed to the Citys Transportation
Master Plan and Comprehensive Plan in coordination with the Citys next complete
comprehensive plan update, tentatively scheduled for December 1, 2014, or as
otherwise allowed by legislative amendments to GMA.
3.2.6. Public Services and Utilities

public services and utilities because both alternatives would include the same amount
of household and employment growth. Similar to transportation impacts noted above,
phasing of growth anticipated under the FEIS Review Alternative would allow the
City to phase its capital facility amendments needed to incorporate public service and
utility amendments into the Capital Facilities Element, and to update associated
functional plans.
3.2.7. Noise
Noise impacts of the FEIS Review Alternative would be similar to those of the
Proposal because both alternatives would include the same amount of household and
employment growth.
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Chapter 4. Clarifications and Corrections
This chapter includes Draft Environmental Impact Statement (DEIS) clarifications
and corrections based on responses to comments presented in Chapter 5 of this Final
Environmental Impact Statement (FEIS) or based on City or consultant review of the
DEIS. The clarifications and corrections are organized in the same order as the DEIS
sections and by page numbers. The clarifications and corrections do not change the
relative impacts of the Environmental Impact Statement (EIS) alternatives or the
overall EIS conclusions.
4.1. Natural Environment

4.1.1. Revisions to DEIS Page 3.1-19
Amend text on DEIS page 3.1-19, Regulatory Environment to clarify adjustments
made to the Surface Water Design Manual.
Kent Drainage Code and Surface Water Design
All development is required to comply with the standards set forth in the Kent
Surface Water Design Manual (City of Kent 2002). The City plans to update its
surface water manual from the current 2002 version to a new manual that meets
revised Ecology standards. This update is tentatively scheduled for September 2010
(Tan pers. comm ). These standards have been adjusted to meet equivalency
requirements of the Washington State Department of Ecologys Stormwater
Management Manual for Western Washington (2005). Thus, projects and programs
evaluated in this DEIS would be regulated under the Ecology stormwater manual as
early as 2010.
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September 2011

Amend text on DEIS page 3.1-22, Impacts Common to Both AlternativesKent
Planning Area to add clarification requested by the City relating to impacts of
impervious surfaces on groundwater and surface water.
Water
Impervious surfaces could intercept precipitation and alter the timing and
volume of discharge to groundwater and surface water.

Amend text on DEIS page 3.1-29, ImpactsMidway Subarea to recharacterize
former landfills from undeveloped to underdeveloped and clarify impacts of
impervious surface impacts of new development and redevelopment on the natural
environment.
ProposalMidway Subarea
Under the Proposal, there would be extensive redevelopment in the Midway
Subarea as a result of changes arising from adoption of the Midway Subarea Plan
that would create a dense, pedestrian-friendly, sustainable community that
provides jobs, housing, and services around nodes of high capacity mass transit.
Development would likely be greater and more intense under the Proposal than
under the No Action Alternative. Conversion of existing
underdevelopedundeveloped land to development would be greatest on the two
former landfill areas under the Proposal, since most other portions of the Midway
Subarea are already developed. However, land use conversions in these areas
would not result in loss of habitat function.
Additionally, while some vacant lands would see new impervious surfaces,
development under tThe Proposal would have minimal impacts on the limited
natural resources of the Midway Subarea. With implementation of the Citys
stormwater standards, water quality would be protected with development of
vacant sites and would improve on redevelopable properties since these were
originally developed without such standards. The Proposals focus of new
development in corridors and centers, including the Midway Subarea, avoids
impacts on most categories of environmentally sensitive areas, and in the
locations where there are environmentally sensitive features, critical area
regulations would apply. As noted above, the Midway Subarea is a largely built-
out area with few environmentally sensitive areas within its boundaries.
Since the Midway Subarea is largely built out with buildings, surface parking,
and other impervious surfaces dominating the environment, it is likely that even
with increases in site coverage standards under the Proposal, redevelopment of
the subarea would replace one type of impervious surface with another (i.e.,
4-2
Clarifications and Corrections
smaller building footprint with surface parking replaced by larger building

footprint with much of the parking contained within a structure), resulting in little
or no additional impervious surfaces, stormwater volume, or runoff. Some
excavation for construction would occur, but would not result in a significant loss
of vegetation or soil productivity.

Similar to the remainder of the Midway Subarea, the Proposal would have
minimal impacts on the limited natural resources of the Midway Planned Action
Area. As described above for the former landfill sites, some grassy areas of the
former Kent Highlands landfill could be converted to mixed-use developments,
but with essentially no loss in habitat function, and as the sites are highly altered.
Because the remainder of this portion of the Midway Subarea is currently
developed, there would be little if any other changes in natural resources
associated with the Proposal.
4.2. Air Quality

4.2.1. Revisions to DEIS Table 3.2-9
Amend Table 3.2-9, Potential Greenhouse Gas Reduction Measures within
Mitigation MeasuresKent Planning Area, on page 3.2-24 to clarify greenhouse gas
(GHG) measures related to planting of mature trees near buildings and use of
recycled building materials.
Table 3.2-9. Potential Greenhouse Gas Reduction Measures

Reduction Measures Comments
Site Design
Plant mature large-caliper trees and Trees and vegetation that directly shade
mature vegetation near structures to buildings decrease demand for air
shade buildings conditioning. By reducing energy
demand, trees and vegetation decrease
the production of associated air pollution
and GHG emissions. They also remove
air pollutants and store and sequester
carbon dioxide. Thus trees and
vegetation rReduces on-site fuel
combustion emissions and purchased
electricity plus enhances carbon sinks.
Minimize building footprint. Reduces on-site fuel combustion

emissions and purchased electricity
consumption, materials used,
maintenance, land disturbance, and
direct construction emissions.
Design water efficient landscaping. Minimizes water consumption,

purchased energy, and upstream
emissions from water management.
4-3
September 2011

Minimize energy use through building Reduces on-site fuel combustion
orientation. emissions and purchased electricity
consumption
Building Design and Operations

Apply LEED (Leadership in Energy and Reduces on-site fuel combustion
Environmental Design) standards (or emissions and off-site/indirect purchased
equivalent) for design and operations electricity, water use, waste disposal
Purchase Energy Star equipment and Reduces on-site fuel combustion

appliances for public agency use. emissions and purchased electricity
consumption
Incorporate on-site renewable energy Reduces on-site fuel combustion

production, including installation of emissions and purchased electricity
photovoltaic cells or other solar options. consumption.
Design street lights to use energy efficient Reduces purchased electricity.

bulbs and fixtures
Construct green roofs and use high- Reduces on-site fuel combustion
albedo roofing materials. emissions and purchased electricity
consumption
Install high-efficiency HVAC systems. Minimizes fuel combustion and

purchased electricity consumption.
Eliminate or reduce use of refrigerants in Reduces fugitive emissions. Compare

HVAC systems. refrigerant usage before/after to
determine GHG reduction.
Maximize interior day lighting through floor Increases natural/day lighting initiatives
plates, increased building perimeter and and reduces purchased electrical energy
use of skylights, celestories clerestories consumption.
and light wells.
Incorporate energy efficiency technology Reduces fuel combustion and purchased

such as: super insulation motion sensors electricity consumption.
for lighting and climate control; and
efficient, directed exterior lighting
Use water conserving fixtures that surpass Reduces water consumption.

building code requirements.
Reuse gray water and/or collect and reuse Reduces water consumption with its
rainwater. indirect upstream electricity
requirements.
Recycle demolition debris and Uuse Reduces extraction of purchased

recycled building materials and products. materials, possibly reduces
transportation of materials, encourages
recycling and reduction of solid waste
disposal.
Use building materials that are extracted Reduces transportation of purchased

and/or manufactured within the region. materials
Use rapidly renewable building materials. Reduces emissions from extraction of

purchased materials
Conduct 3rd party building commissioning Reduces fuel combustion and purchased
to ensure energy performance. electricity consumption.
Track energy performance of building and Reduces fuel combustion and purchased
develop strategy to maintain efficiency. electricity consumption.
4-4

Transportation
Size parking capacity to not exceed local Reduced parking discourages auto
parking requirements and, where possible, dependent travel, encouraging
seek reductions in parking supply through alternative modes such as transit,
special permits or waivers. walking, biking etc. Reduces direct and
indirect VMT
Develop and implement a Reduces direct and indirect VMT

marketing/information program that
includes posting and distribution of
ridesharing/transit information.
Subsidize transit passes. Reduce Reduces employee VMT

employee trips during peak periods
through alternative work schedules,
telecommuting, and/or flex-time. Provide a
guaranteed ride home program.
Provide bicycle storage and Reduces employee VMT

showers/changing rooms.
Utilize traffic signalization and coordination Reduces transportation emissions and

to improve traffic flow and support VMT
pedestrian and bicycle safety.
Apply advanced technology systems and Reduces emissions from transportation

management strategies to improve by minimizing idling and maximizing
operational efficiency of local streets. transportation routes/systems for fuel
efficiency.
Develop shuttle systems around business Reduces idling fuel emissions and direct
district parking garages to reduce and indirect VMT
congestion and create shorter commutes.
Source: Ecology 2008b.
4.3. Land Use Patterns and Plans and Policies

Amend text on DEIS page 3.3-56, ImpactsMidway Subarea, under the Proposal to
clarify areas where redevelopment would occur under the Proposal, which would
include existing auto-oriented areas within the Midway Planned Action Area
(northern Transit-Oriented Community[TOC]).
Development within the Midway Planned Action Area under the Proposal would
consist of taller buildings with greater lot coverage than found in either existing
conditions or the No Action Alternative. With the notable exception of areas in
the Kent Highlands designated for passive open space and less intense uses, the
majority of vacant, and surface parking areas, and auto-oriented uses in the
Midway Planned Action Area would be transformed into compact buildings or
structured parking under the Proposal. The Proposal would also include smaller
blocks and/or more frequent pedestrian and/or bicycle connections throughout
the Midway Planned Action Area to facilitate use of nonmotorized modes of
4-5
September 2011
transportation and access to the planned transit light rail station alongin the
vicinity of SR 99.
4.3.2. Revisions to DEIS Page 3.3-61 and 3.3-62

Amend text on DEIS pages 3.3-61 and 3.3-62 Significant Unavoidable Adverse
ImpactsKent Planning Area to clarify the intent of the existing paragraph in
response to comment 2-27.
Over time, implementation of either the Proposal or the No Action Alternative

could convert vacant, partially developed, and redeveloped properties in the Kent
Planning Area to additional or new single-family, multifamily, office,
commercial, and industrial uses. Because of the densification and intensification
of uses, the City would continue to add to its urban character. The resulting
transformation of land uses from less intense suburban character to more intense
urban character is considered a significant unavoidable adverse impact.
4.4. Aesthetics
4.4.1. Revision to DEIS Page 3.4-21
Amend text on DEIS page 3.4-21, ImpactsKent Planning Area, to add
clarifications regarding interior lighting in response to comment 2-14.
Light and Glare
Additional growth in the Activity Centers would introduce new sources of light and
glare, such as increased numbers of automobiles, additional exterior illumination for
buildings, and new street lighting. Under the Proposal, most of this growth would
take the form of mixed-use developments that de-emphasize the automobile and
focus on providing a pedestrian-friendly environment, and one aspect of a desirable
pedestrian environment is appropriately designed lighting. Exterior light and glare
under the Proposal would come more from streetlights and illuminated signage than
from automobiles or lighted billboards, but increased growth in the Activity Centers
still has the potential to create additional lighting and glare issues, particularly in the
evening hours, when lighting from retail and entertainment uses may impact
residences in mixed-use areas. Furthermore, although there is potential for interior
lighting to contribute to increased ambient light and glare during evening hours, the
effects would be localized and highly dependent on the glazing and architectural
features of individual buildings. Compared to impacts associated with exterior
illumination and street lighting, interior building lighting is not anticipated to be a
major factor in light and glare impacts. The application of design standards for
exterior lighting, such as directional/shielded fixtures or limits on the height of
4-6
lampposts, would be necessary to ensure that no significant lighting and glare

impacts are generated under the Proposal.

Amend text on DEIS page 3.4-30, Impacts Midway Subarea, to clarify that the
design guidelines apply only within the TOC areas.
Visual Character
Under the Proposal, the portion of the Midway Subarea south of the Midway Planned
Action Area would primarily redevelop as an auto-oriented commercial corridor,
which would continue the traditional function of commercial development along SR
99. The uses in this portion of the subarea would be similar to existing conditions,
though density is anticipated to increase as properties redevelop to accommodate
future growth. The primary change that would occur to visual character under the
Proposal is the implementation of design policies and design guidelines that would
require more human-scaled architectural design.

Amend text on DEIS page 3.4-31, ImpactsMidway Subarea, to clarify that the
Kent Highlands area retains open space, rather than a natural character, since the
majority of this area consists of a former landfill site.
In contrast to the Transit-Oriented Communitys residential/employment focus,

the Kent Highlands mixed-use area would be slightly more accommodating of
auto-oriented uses and a mix of residential and community retail. While still a
primarily pedestrian-oriented district, this area would not have such strong transit
connections, though the same urban design, parks, and streetscape policies and
guidelines would apply, producing a similar visual character as seen in the
Transit-Oriented Community. Existing conditions in this portion of the Midway
Planned Action Area, however, are far less commercially oriented than along
SR 99. The Kent Highlands area is currently far less developed than the SR 99
corridor and retains far more of its natural characterprovides for some open space
though the area is altered. As such, high intensity development of the kind
proposed under the Midway Subarea Plan would have the potential to
significantly transform the visual character of this area.
4.4.4. Revision to DEIS Page 3.4-31

Amend text on DEIS page 3.4-31, Impacts---Midway Subarea, to clarify current
height regulations and that design guidelines do not apply to the auto-oriented area.
Height and Bulk
4-7
September 2011
In the portion of the Midway Subarea south of the Midway Planned Action Area and
north of S 268th Street, maximum building heights would increase to approximately
50 feet, which is a moderate increase over remain at the current limit of 35 feet, with
the allowable administrative approval of one additional story. With the
implementation of design guidelines, Therefore, no height and bulk impacts are
anticipated.

Amend text on DEIS page 3.4-32, ImpactsMidway Subarea to clarify that, under
the Proposal, a minimum height of two stories is applied to new development.
Under the Proposal, building heights in the Midway Planned Action Area would
be a minimum of two stories, upincrease to a maximum of approximately 200
feet, which is a substantial increase over the current maximum heights of 30 to
40 feet. According to City staff, the tallest buildings (up to 15 stories) would be
concentrated in the area between S 240th Street and S 246th Street, and in the
Kent Highlands area east of I-5 (Gould-Wessen pers. comm.). The remainder of
the Midway Planned Action Area would consist of a mix of building heights in
the five- to six-story range with taller buildings interspersed throughout. Such a
large increase in heights has a potential to introduce a canyon effect for
pedestrians at street level without mitigation, and the Proposal uses areas of
lower height to provide buffers between tall buildings and sensitive areas, such as
parks, open space, and defined pedestrian corridors (Gould-Wessen pers.
comm.). The Midway Subarea Plan includes a set of integrated design guidelines
focused on the reduction of visual bulk at street level and compatibility between
the subarea and less intense adjacent development such as single-family
residences. With mitigation incorporated, height and bulk impacts are anticipated
to be less than significant.

Amend text on DEIS page 3.4-33, ImpactsMidway Subarea, to provide
grammatical edits and clarify the pedestrian environment that currently exists on 30th
Avenue within the Midway Planned Action Area.
Under the Proposal, no significant adverse impacts are anticipated to the

pedestrian environment. At present, the Midway Planned Action Area provides
only the barest accommodation for pedestrian needs; blocks are large, sidewalks
are frequently interrupted by curb cuts, transit stops are not sheltered from the
elements, and no on-street parking or landscaping areis present to buffer
pedestrians from the adjacent highway. There are no curbs, gutters, or sidewalks
along 30th Avenue. Under the Proposal, a set of design guidelines focused on
enhancement of the pedestrian experience would be implemented, which would
4-8
encourage new development to provide pedestrian amenities such as seating,

weather protection, and human-scaled lighting. Over time, this would result in a
pedestrian environment in the Midway Planned Action Area that is more similar
to the historic core of Downtown, focused on social interaction and use of public
transit.

Amend text on DEIS page 3.4-33, ImpactsMidway Subarea, to clarify that design
guidelines apply only to the TOC areas (for both the Proposal and the FEIS Review
Alternative).
Scenic Views
As fewer views are available in the portion of the Midway Subarea south of the
Midway Planned Action Area, and building heights would not increase as much,
impacts on scenic views are anticipated to be less than significant with the
application of proposed design guidelines. Impacts on views would be greater in the
secondary Transit-Oriented Community at S 272nd Street, though the increase in
building heights would create territorial views that are not currently available at this
location.

clarification relating to the Community Design element language relating to views,
and of additional mitigation measures for scenic views in the Midway Planned
Action Area.
Views from public rightsof-way in the Midway Planned Action Area are mostly
fragmentary, often screened by intervening topography, vegetation, or existing
development. However, strong views of the Cascades are available in the former
Kent Highlands Landfill area, and views of Mount Rainier and Puget Sound are
available at topographically high points along SR 99 north of S 240th Street. The
large increase in heights under the Proposal has a potential to block these public
views, though such development would increase the availability of private views.
The Community Design Element of the comprehensive plan calls for the
preservation of views from public rights-of-way and public areas to the greatest
extent practicable. Though the Midway Subarea Plan contains design guidelines
that call for upper-story setbacks to take advantage of views, it does not address
view preservation in the same detail as it does architectural design or pedestrian
amenities. As a result, additional mitigation should be considered to prevent
significant impacts on scenic views in the Midway Planned Action Area, such as
the definition of protected public view corridors and the implementation of
measures to provide viewpoints from public areasreduced height limits in
4-9
September 2011
locations where higher topography provides views of scenic visual resources. A

detailed discussion of these additional measures is included in Section 3.4.3,
Mitigation Measures.

Amend text on DEIS page 3.4-34, ImpactsMidway Subarea, to clarify where the
design guidelines apply and to add clarifications regarding interior lighting in
Light and Glare
Additional growth in the Midway Planned Action Area would introduce new sources
of light and glare, such as increased numbers of automobiles, additional exterior
illumination for buildings, and new street lighting. The Kent Highlands area would
be particularly impacted by increases in illumination, as this area is currently
developed at a very low intensity. Furthermore, although there is potential for interior
lighting to contribute to increased ambient light and glare during evening hours, the
effects would be localized and highly dependent on the glazing and architectural
features of individual buildings. Compared to impacts associated with exterior
illumination and street lighting, interior building lighting is not anticipated to be a
major factor in light and glare impacts. The Midway Subarea Plan includes a set of
design guidelines Design Guidelines focused on limiting glare and light pollution in
the TOC areas. With the implementation of these guidelines, impacts are anticipated
to be less than significant.
Lighting conditions in the remainder of the Midway Subarea are anticipated to be

similar to the Midway Planned Action Area what presently exists. Furthermore, Kent
City Code (15.08.050.A. and D.4 and 15.05.090.E.) regulates impacts from lighting
and glare. With mitigation Therefore, light and glare impacts are anticipated to be
less than significant.

grammatical edit and correct statement on design guidelines.
As heights along the highway commercial corridor portion of SR 99 would only

moderately not increase over current allowable limits, the application of design
standards included in the Midway Subarea Plan should be sufficient to reduce
shading impacts are anticipated to be at less than significant levels.
4-10

Amend text on DEIS page 3.4-38, Incorporated Plan FeaturesMidway Subarea, to
clarify design guidelines apply to TOC areas only under both the Proposal and the
FEIS Review Alternative.
In addition to these goals and policies, the Midway Subarea Plan is accompanied by a
set of draft design guidelines. The following draft guidelines would serve to mitigate
impacts associated with future development within the TOC areas under the Proposal
and the FEIS Review Alternative (City of Kent 2009see Appendix C of the FEIS
presenting draft design guidelines as of November 2010).
4.4.12. Revisions to DEIS Page 3.4-40 to 3.4-41

Amend text on DEIS page 3.4-40 and 3.4-41, Mitigation Measures for the Midway
Subarea, relating to Applicable Regulations and Commitments and Other Mitigation
Measures to clarify mitigation measures described in the DEIS for application in a
planned action ordinance.
Applicable Regulations and CommitmentsMidway Subarea

At present, the only applicable regulations for the Midway Subarea are the Citys
current zoning regulations. With adoption of the Midway Subarea Plan and the
Midway Design Guidelines for the TOC areas, these Citys regulations would be
amended to include the mitigation measures described under Incorporated Plan
Features above.
Other Mitigation MeasuresMidway Subarea

The City will should identify significantshould establish defined view corridors
from public areasrights-of-way within the Midway Subarea which may include
but are not limited to the SR 99/S 240th Street intersection, looking southeast
(Mount Rainier), to provide a framework for preservation of important views to
Mount Rainier, the Cascades, and Puget Sound. Primary locations shall include
the intersection of SR 99 and S 240th Street, looking southeast (Mount Rainier).
Site design measures from the Midway Design Guidelines should be applied to
development within these view corridors to prevent the obstruction of public
views.
To minimize shading impacts within the Midway Planned Action Area, the City
should require, to the greatest extent feasible, that the tallest portions of new
buildings or the tallest buildings on a development site will be located central to
the property to maximize the distance from any adjacent sensitive development
that may exist, such as single-family residences. This may be accomplished by
applying transitional height standards and implementing Midway Design
Guidelines relating to Site Characteristics, Transition Between Residence, Street,
4-11
September 2011
and Adjacent Sites, and Height Bulk and Scale, or equivalent action. The City
should also implement the following mitigation measures regarding shading
conditions:
Solar access for public pedestrian spaces, pedestrian/bicycle pathways, parks,

schools and other areas sensitive to shading should be preserved by requiring
upper-story and/or ground-level setbacks for adjacent development.
Development shall include upper-story step -backs at the third story and
again at the seventh story to increase sunlight at street level when adjacent
toshould not exceed four stories in height within 50 feet of any component of
the Open Space Framework illustrated in the Midway Subarea Plan,
including multi-modal streets, pedestrian/bicycle pathways, and parks.
Coordinated design should be encouraged between properties in the area
south of S 240th Street and north of S 246th Street to ensure that the high-
intensity development anticipated in this location preserves solar access to
interior spaces and private pedestrian connections.
4.5. Transportation
4.5.1. Revisions to DEIS Table 3.5-3
Updated DEIS Table 3.5-3 on pages 3.5-10 to 3.5-11 identifying transit service in the
Centers and Corridors identified in the DEIS to include service changes resulting
from the start of RapidRide A Line in October 2010. This edit was prepared in
4-12
Table 3.5-3. Transit Service

Route Centers and Corridors
Meeker Kent
Downtown Midway Washington Panther Lake Benson/240th Benson /256th) Kangley/132nd
Regional Routes1
150 X
157 X
158 X X X X X
159 X X X X X
161 X X
162 X
173 X
174 X
175 X
192 X
193 X
197 X
564 (Sound Transit Express) X
565 (Sound Transit Express) X
574 (Sound Transit Express) X X
RapidRide A Line X
Sounder Commuter Rail X

2
South County Routes
153 X
164 X X X X
166 X X X
4-13
September 2011
Route Centers and Corridors

Meeker Kent
Downtown Midway Washington Panther Lake Benson/240th Benson /256th) Kangley/132nd
168 X X X X
169 X X X X
180 X
183 X X X
2 3
Local Routes ,
913 X
914 X X X X
916 X X X X
918 X
1
Operated by Metro unless otherwise specified.
2
Other regional services in the Kent Planning Area that do not overlap with the Midway Subarea, Downtown, or Activity Centers: 190, 191, 194, 197, 247, 941/952 (Boeing Shuttle).
3
Operated by Kent DART shuttles.
4-14

Amend text on DEIS page 3.5-32, Mitigation MeasuresKent Planning Area, to edit
Incorporated Plan Features relating to anticipated updates to the City Concurrency
Ordinance suggested by the consultant, and to clearly add applicable regulations and
commitments currently in place that serve as mitigation measures in a subsection
after Incorporated Plan Features.
Incorporated Plan FeaturesKent Planning Area

As discussed earlier, implementation of the transportation improvement projects
defined in the adopted TMP (City of Kent 2008) are needed to maintain
acceptable operations through 2031 under both the No Action Alternative and the
Proposal. These TMP projects are summarized in Table 3.5-5.
Moreover, the City is in the process of adopting a new Concurrency Ordinance,

which would require development to meet citywide pay its fair share toward
maintenance of corridor LOS standards. This update should be completed in
20112010.
Applicable Regulations and CommitmentsKent Planning Area

Commute Trip Reduction (CTR) Program
Kent requires employers of a certain size to encourage employees to reduce
vehicle miles of travel and single-occupant vehicle commute trips in Chapter
6.12 KCC. This program currently serves 35 worksites within the City. The City
manages its CTR program proactively by providing public outreach to the entire
business community, not just the businesses required by law to participate.
Public Infrastructure Improvements

Chapter 6.02 KCC requires developers to install public infrastructure
improvements as conditions of permit. Infrastructure improvements include, but
are not limited to, rights-of-way and paved streets, street lighting systems, curbs,
gutters, sidewalks, landscaping, storm drainage systems, sanitary sewer systems,
domestic water and fire systems, traffic control systems, and conduit for fiber
optic systems. The City has adopted the 2009 City of Kent Design and
Construction Standards (construction standards) and all codes, standards, and
provisions cited therein in Section 1.6.
Concurrency Management
Chapter 12.11 KCC sets forth specific standards providing for city compliance
with the concurrency requirements of the GMA and for consistency between city
and countywide planning policies under the GMA. This chapter establishes a
transportation concurrency management system (TCMS) to ensure that the
necessary facilities or programs needed to maintain minimum LOS can be
4-15
September 2011
provided simultaneous to, or within, a reasonable time of new development as

required in the GMA.
The City of Kent Transportation Master Plan

The TMP includes capital improvement projects designed to help the City
maintain transportation concurrency.
Transportation Impact Fees

Chapter 12.14 KCC requires development to pay its fair share for capital
improvement projects in the Citys TMP and provides guidance for how impact
fees are to be assessed.

Amend text on DEIS page 3.5-32, Mitigation MeasuresMidway Subarea, to add
text clarifying that applicable regulations and commitments in the Kent Planning
Area are also applicable to the Midway Subarea.
Applicable Regulations and CommitmentsMidway Subarea

Applicable regulations and commitments for the Midway Subarea are the same
as noted for the Kent Planning Area under Section 3.5.3.1.

Amend DEIS Table 3.5-12 on page 3.5-33, Mitigation Projects for the Midway
Subarea Plan to add clarification to Project ID #10.
Table 3.5-12. Mitigation Projects for the Midway Subarea Plan

ID Roadway Facility Description
1 Local Street Create a local street connection by extending 231st
Connection Street from I-5 to 30th Avenue. This connection
would be designed to provide an additional link for
local traffic across I-5 and is contingent on sState
action.
2 30th Avenue Grade-separated four-lane crossing of Kent-Des

Overcrossing Moines Road, with right-turn access maintained
between two roadways.
3 30th Avenue Complete Construct a four-lane cross-section, but initially

Streets Enhancements stripe to include two travel lanes with parking on
both sides of street from Kent-Des Moines Road to
S 240th Street. Design with traffic calming elements
to reduce vehicle speeds and encourage non-
motorized travel. Roadway will be converted to four
lane operations once the Citys LOS E threshold is
exceeded.
4 Complete Street Construct a four-lane cross-section, but initially

Connection 240th to stripe to include two travel lanes with parking on
244th Street both sides of street from S 240th Street to access
4-16

road provided at S 244th Street. Design with traffic
calming elements to reduce vehicle speeds and
encourage non-motorized travel. Roadway will be
converted to four lane operations once the Citys
LOS E threshold is exceeded.
5a,b Business Access Provide two-lane route for accessing businesses

Service Roads between S 244th Street and S 252nd St; and
between S 252nd and S 260th Street. Conceptual
alignments to be determined.
6a,b,c SR 99 Access Roads Provide three new access roads between 30th
Avenue and SR 99. One would extend from S 238th
Street; another would be midway between S 238th
Street and S 240th Street, and the third would be
located at S 244th Street.
7a,b Local Circulation Internal roadways are provided to facilitate internal

Routes travel among proximate uses in the Kent Highlands
(since there will be no direct access off of S 231st
Street), and west of SR 99 in the northwestern
portion of the development.
8a,b,c,d New Signalized 231st Street/30th Avenue; SR 99/S 238th Street;

Intersections SR 99/S 244th Street; S 259th Place/29th Avenue S
9 New Right In/Right Out SR 99/Access road midway between S 238th Street
Intersection and S 240th Street
10 240th/SR 99 Widen westbound approach from one exclusive

left-turn lane and one through/right-turn lane to
addinclude an exclusive right-turn lane or right-turn
pocket.
11 Internal Site Five to six locations where either a roundabout, a

Intersections signal, or all-way stop may be appropriate based on
forecasted traffic volumes and site conditions

Replace Figure 3.5-4 to remove complete street improvements from the City of
Des Moines in response to comment 2-19 from City of Des Moines.
4-17
September 2011

Amend text on DEIS page 3.5-36, Significant Unavoidable Adverse ImpactsKent
Planning Area, further clarifying the traffic impacts on state and regional
transportation facilities.
Moreover, the growth assumed under both the No Action Alternative and
Proposal would result in additional traffic accessing state and regional
transportation facilities. The City works closely with the state, the ports, the
county, other jurisdictions, and many other stakeholders to ensure that the
state and regional projects that benefit Kent continue to be a priority in the
state and the region. The City will continue to work with both WSDOT and
the regional transit providers to assure that transportation facilities will be
delivered concurrent with development. However, because these state and
regional transportation facilities are not within the Citys control,
construction of projects to mitigate the impacts of the alternatives cannot be
guaranteed. Thus, impacts on state and regional facilities are considered a
significant unavoidable adverse impact. The City will coordinate with
WSDOT regarding the impacts of either alternative on state facilities. The
City has a track record of coordinating with WSDOT on improvements to
state and regional facilities, as exhibited by the recent addition of HOV lanes
to SR 99.

Amend text on DEIS page 3.5-36, Significant Unavoidable Adverse Impacts
Midway Subarea, clarifying the reliance upon completion of the SR 509 plan as part
of the Proposal.
Full implementation of the roadway mitigation measures discussed for the

Proposal relies on state actions, such as completion of the SR 509 plan as well as
City policy decisions and available revenues. The City works closely with the
state, the ports, the county, other jurisdictions, and many other stakeholders to
assure that the SR 509 project continues to be a priority in the state and the
region. Furthermore, the City probably has more influence over this project and
can count on this happening more than it can influence high-capacity transit
projects. The City has no control over the timing, scope, phasing, or delivery of
transit, nor the amount of capacity that transit provides in the future to this area,
but the City will continue to work with both WSDOT and the regional transit
providers to assure that transportation facilities will be delivered concurrent with
development. Furthermore, the City will monitor traffic operations at individual
intersections along the SR 99 corridor and, in collaboration with WSDOT and the
City of Des Moines, will be able to respond as needed with an appropriate
combination of mitigation measures for impacts. Because the City does not have
4-19
September 2011
control over the implementation of the SR 509 project, the full mitigating effects
of the projects described in Table 3.5-12 cannot be guaranteed. Thus, all
intersection and roadway impacts identified under the Proposal are considered
significant unavoidable adverse impacts.
4.6. Public Services and Utilities

Amend text on DEIS page 3.6-6, Affected EnvironmentKent Planning Area, to
correct and clarify fire and emergency service information provided by Kent Fire
Department RFA.
The Kent Fire Department Regional Fire Authority (RFA) provides 24-hour
coverage for fire suppression, technical rescue, and emergency medical and
advanced basic life support (ABLS). It is made up of three units: Operations
(encompassing all emergency response services and training); Fire Prevention
(including the planning unit, fire investigators, public education, code
enforcement and plans review); and Administration/Support (recruitment,
promotion, facilities and apparatus). Other fire districts in adjacent areas may
provide assistance as requested. The Kent Fire Department RFA has been
accredited jointly by the International Association of Fire Chiefs (IAFC), the
Commission on Fire Accreditation International (CFAI), and the International
Cities/Counties Management Association (ICMA).
Fire and Emergency Services and Facilities Inventory

The Kent Fire Department RFA operates eight fire stations with an on-duty staff
of 30 firefighters (Table 3.6-4). Figure 3.6-2 illustrates locations of fire and
emergency services and facilities. The Kent Fire Department RFA has plans for
at least threean additional fire stations with two locations defined near the
intersection of SE 217th Street and 108th Avenue SE, and 407 N Washington.
One additional station is planned in the general area of S 231st Way near
Riverview Boulevard (Rabel pers. comm.City of Kent 2010a).

clarify the Citys 2010 Park & Open Space Plans future direction related to Level of
Service standards, as suggested by City.
Parks and Recreation Level of Service

The National Recreation and Park Association (NRPA) no longer recommends a
standard for facility and park land based on population ratios; however, the
NRPA recommends that because every community is different, standards should
4-20
be developed by the community and used as a guide in planning. The Citys 1994
Comprehensive Park and Recreation Plan LOS standards were developed with
these standards, which represent the minimum for which a community should
strive.
The 1994 Comprehensive Plan described an LOS standard for parks of 20 acres
per 1,000 population (10 acres of local park land and 10 acres of open space).
This LOS standard was based on previous review of a former NRPA standard of
parkland per population ratio. The 1994 Comprehensive Plan Park and Open
Space Element further broke out LOS standards into 2.53 acres of park land per
1,000 population for neighborhood park land and 18.19 acres of parkland per
1,000 population for community park land, as well as a standard for golf courses
of 0.56 holes/1,000 population. The 2010 Park & Open Space Plan and updated
Comprehensive Plan Park and Open Space Element describe LOS standards
based on 2009 population in Table 3.6-8 below.
Table 3.6-8. Parks and Recreation Level of Service Standards
Facility Type LOS Standard1

Park land 15.24 acres/1,000 population
Recreational Facilities 1.86 square feet/person

Source: City of Kent 2010b:Table 2).
1
Based on 2009 population estimates.
While the 2010 Park & Open Space Plan identified the LOS standards above, the
plan also indicated that the Citys direction is to develop a more qualitative parks
and recreation standard. The 2010 Park & Open Space Plan includes
implementation plans and acquisition plans for both the short term (2010 to
2020) and long term (2010 to 2030) that will address part of the anticipated needs
under the Proposal. Some of the core themes of the plan include developing trails
and greenway corridors to connect parks, schools, and neighborhoods.

revise the anticipated adoption date of the updated Stormwater Management Manual
as suggested by City.
Specific requirements (LOS standards) for on-site stormwater management and

stream protection are contained in the Citys 2002 Surface Water Design Manual,
which is a modified version of the 1998 King County Surface Water Design
Manual. Portions of the stormwater system are improved to these standards as
public and private development projects are constructed. These standards will be
have been adjusted as necessary to meet equivalency requirements of the
4-21
September 2011
Washington State Department of Ecologys Stormwater Management Manual for

Western Washington (2005) in the future. The City plans to update to the
Ecology Manual in late 2010.

Amend text on DEIS page 3.6-44, Impacts Common to Both AlternativesKent
Planning Area, to add clarifications suggested by Kent Fire Department RFA related
to comment 4-1.

Growth in households and employment under both alternatives are expected to
result in increases in traffic volumes, which may impede fire and emergency
medical service response time and reduce service capacity of existing resources.
The degree to which growth affects response time varies by alternative.

clarifications suggested by Kent Fire Department RFA in response to comment 4-1.
The Kent Fire Department RFA uses a geographic information system (GIS) to
assess the impact of future population and employment growth upon fire
services. The department RFA plans to analyze the Citys updated population and
employment projections, update its Concurrency Management Plan, and assess
potential impacts and facility needs using this tool its Mitigation and Level of
Service Contribution policy as it plans for future facilities and resources (Rabel
pers. comm.).

Amend text on DEIS page 3.6-55, ImpactsKent Planning Area, to clarify
stormwater regulations.
New development is required to provide manage stormwater conveyance to

equivalent standards of the Citys 2002 Surface Water Design Manual (a modified
version of the 1998 King County Surface Water Design Manual). These standards are
have been adjusted as needed to meet the equivalency requirements of the 2001
Western Washington (2005). Under the No Action Alternative, the Citys Stormwater
Utility would be required to adopt Ecology Stormwater Manual during the planning
period.
4-22

clarifications suggested by Kent Fire Department RFA in response to comment 4-1.

As noted in the discussion of impacts on police protection, the Kent Planning
Areas population is anticipated to increase to a total of approximately
68,900 households. Similar to the Police Department, the Kent Fire Department
RFAs LOS standards are related to response time. Although the Kent Planning
Area is only a portion of the Kent Fire Department RFAs regional service
areait also serves the City of Covington and areas of unincorporated King
County served by Fire District 37a 60% increase in population and
employment in the Kent Planning Area would have an effect of eroding existing
service capacity and increasing vehicular trips which could will slow response
time. Congestion is expected to vary based on location as noted in Section 3.5,
Transportation and as described under the section entitled Police, above.
Increases in congestion would also have a similar effect of slowing response time
to emergency medical calls. In addition to increased traffic congestion,
population and workforce increases would erode existing service capacity.
Therefore growth anticipated under the Proposal can be expected to result in a
need for additional fire and emergency response facilities and/or expansion of
existing facilities to serve the larger population anticipated under the Proposal.
The Kent Fire Department RFA will uses GIS to assess the impact of future
population and employment growth upon fire services, similar to the No Action
Alternative. The department RFA also plans to analyze the Citys updated
population and employment projections, update its Concurrency Management
Plan, and assess potential impacts and facility needs using this tool its Mitigation
and Level of Service Contribution policy as it plans for future facilities and
resources (Rabel pers. comm.).

Amend text on DEIS page 3.6-64, ImpactsKent Planning Area, to clarify revise the
anticipated adoption date of the updated Stormwater Management Manual as
suggested by the City.
New development is currently required to provide manage stormwater

conveyance to equivalent standards of the Citys 2002 Surface Water Design
Manual (a modified version of the 1998 King County Surface Water Design
Manual). These standards are have been adjusted as needed to meet the
equivalency requirements of the 2001 Washington State Department of
Ecologys Stormwater Management Manual for Western Washington (2005).
4-23
September 2011
The City Stormwater Utility plans to adopt the Ecology Stormwater Manual in
2011late 2010.

Amend text on DEIS page 3.6-77, Impacts Common to Both AlternativesMidway
Subarea, to add clarifications suggested by Kent Fire Department RFA in response to
comment 4-1.

Growth in the Midway Subarea under both alternatives would cause an increase
in congestion which may will cause an increase in response time for fire and
emergency medical services and a decrease in service capacity in the Midway
Subarea. Kent Fire Department RFA will need to maintain and improve existing
service to the Midway Subarea to minimize impacts on service capacity and
established levels of service.
Under both alternatives, the Midway Subareas irregular boundary with Des
Moines would require the City to maintain some type of mutual aid agreement
with neighboring jurisdictions to ensure timely response to calls for fire and
emergency medical service delivery in the Midway Subarea.

Amend text on DEIS page 3.6-80, No Action Alternative ImpactsMidway Subarea,
to add clarifications suggested by Kent Fire Department RFA in Comment 4-1.
As noted for the proposal, the Kent Fire Department RFA uses a GIS-based
system to assess impact of future population and employment growth upon fire
services. The RFA plans to analyze the Citys updated population and
employment projections, update its Concurrency Management Plan, and assess
potential impacts and facility needs using its Mitigation and Level of Service
Contribution policythis tool as it plans for future facilities and resources (Rabel
pers. comm.).
Even though the City does not define its operational LOS in terms of employed
fire and emergency response staff, it can be reasonably assumed that the number
of calls for fire and emergency response services would increase in conjunction
with the Citys increase in population. In order to maintain the ability to respond
to emergency calls in a timely manner, it may will be necessary for the Kent Fire
Department RFA to hire additional firefighters, EMTs, and support staff during
the planning period.
Because the Kent Fire Department RFACity has a mutual aid agreement with
nearby fire service and emergency medical service providers in the Midway
4-24
Subarea, increases in population and employment in the subarea would also

result in an increase in calls for service that could impact other fire and
emergency medical response providers.

Amend text on DEIS page 3.6-82, ImpactsMidway Subarea, to correct projected
households and students identified by City staff. The results show fewer households
and students in the Federal Way School District portion of the Midway Subarea.
Federal Way School District

The Federal Way School District encompasses a larger portion of the City limits
than the Highline School District. Under the No Action Alternative, the Federal
Way School District would anticipate an increase of approximately 320
households in the Kent portion of the school district over the planning period.
Most of the new households would be single-family dwellings located outside the
Midway Subarea. Only about 1526 of the new households would be located in
the Kent Highlands portion of the Midway Planned Action Area under the No
Action Alternative.
Using the same student generation ratios used to analyze the Kent and Highline
School Districts, the portion of the Federal Way School District located in West
Hill would experience an increase of approximately 224 students over the
planning period. The majority of these students would come from areas of the
West Hill outside the Midway Subarea. Only about 1018 of these students would
be found living in the Kent Highlands portion of the Midway Planned Action
Area.

Amend text on DEIS page 3.6-86, ImpactsMidway Subarea, to add clarifications
indicating that Kent Police has a mutual aid agreement with Federal Way as well as
Des Moines in response to comment 2-16.
Because the City has a mutual aid agreement with Des Moines and Federal Way
for police services in the Midway Subarea, increases in population and
employment in the Subarea would also result in an increase in calls for service
that could affect the City of Des Moines and City of Federal Way Police
Departments.

Amend text on DEIS page 3.6-87, Proposal ImpactsMidway Subarea, to add
clarifications suggested by the Kent Fire Department RFA in comment 4-1.
4-25
September 2011

As noted in the discussion of impacts on police protection, the Midway Subareas
population is anticipated to increase to a total of approximately 11,800
households by 2031. Similar to the Police Department, the Kent Fire Department
RFAs LOS standards are related to response time. Although the Midway
Subarea represents a small portion of the Kent Fire Department RFAs service
area, (it also serves the City of Covington and areas of unincorporated King
County served by Fire District 37), and an even smaller percentage of the overall
fire service area population, a six-fold increase in population and four-fold
increase in employment in the Midway Subarea would have an effect of
increasing traffic congestion which would slow response time. Congestion will
vary based upon location. However, the SR 99, S 272nd Street, and S 260th
Street corridors all become more congested compared to existing conditions. The
SR 99 corridor is expected to worsen to LOS F for both the Proposal and the No
Action Alternative, although the corridor includes high-occupancy vehicle
(HOV)/transit-only lanes which could be used by fire and emergency response
services, as needed. More information on future traffic conditions can be found in
Section 3.5, Transportation. However, the already congested SR 99 corridor is
expected to worsen as a result of the Proposal. Increases in congestion will also
have a similar effect of slowing response time to emergency medical calls. In
addition to increased traffic congestion, increases in population and employment
will erode existing service capacity. Therefore, growth anticipated under the
Proposal wouldcan be expected to result in a need for additional fire and
emergency response facilities, expansion of existing facilities, relocation of fire
and emergency response facilities, or a combination of these measures to serve
the larger mixed-use population without reducing existing LOS. The Kent Fire
Department RFA defines its operational LOS based on response time. To achieve
the defined LOS response time, the availability or capacity of fire and
emergency medical units must be equal to, or greater than, the adopted
performance expectation during peak hours. Reserve capacity only exists if the
unit is available more than the stated LOS objective. Because minimal capacity
exists prior to implementing the Proposal, it would be necessary for the Kent Fire
Department RFA to hire additional firefighters, emergency medical technicians
(EMTs), and support staff during the planning period.
The Kent Fire Department RFA uses a GIS-based system to assess impact of
future population and employment growth upon fire services. The RFA plans to
analyze the Citys updated population and employment projections, update its
Concurrency Management Plan, and assess potential impacts and facility needs
using its Mitigation and Level of Service Contribution policy as it plans for
future facilities and resources this tool (Rabel pers. comm.).
4-26
Even though the City does not define its operational LOS in terms of employed
fire and emergency response staff, it may be necessary for the Kent Fire
Department RFA to hire additional firefighters, EMTs, and support staff during
the planning period.
Because the Kent Fire Department RFACity has a mutual aid agreement with
nearby fire service and emergency medical service providers in the Midway
Subarea, increases in population and employment in the subarea would also
result in an increase in calls for service that could impact other fire and
emergency medical response providers.

Amend text on DEIS page 3.6-88, ImpactsMidway Subarea, to add clarifications
related to other existing open space that exists in the Midway Subarea, grammatical
corrections, and language describing potential City actions for addressing parks and
recreation shortfalls within the Midway Subarea. Amendments to this section address
in part, comment 2-42.
Since the vast majority of the planned residential growth is expected to occur in
the Midway Planned Action Area, Table 3.6-18 also includes calculations for the
Planned Action Area showing that 321 acres of park land and 39,131 square feet
of recreation facilities would be needed in that northern TOC.
Acre demand figures do not reflect that there are about 212 acres of open space
in the overall Midway Subarea in the form of the landfills, parks (City of Kent
Park 2.7 acres), and public and private wetlands.As described under the Affected
Environment, many of the City recreation programs and larger parks and open
spaces are intended to serve a larger population. In addition, although there are
no formal parks or recreation spaces in the Midway Subarea, several parks are
located nearby, both in the City, and the City of Des Moines, and the City of
SeaTac. The Draft Midway Subarea Plan itself recognizes that not all parks and
recreation needs would be met in the subarea. Therefore, Policies MP&OS-1.6
and -1.7 are oriented toward sharing existing facilities with neighboring
jurisdictions, school districts and other entities through joint use agreements, and
considering a shuttle service for from the Midway Subarea to options for use of
other City park facilities as a means of expanding recreational access for the area
Midway Subarea.
The Midway Subarea Plan also includes a number of other parks and open space
goals and policies which could be incorporated into and otherwise expand upon
the 2010 Park & Open Space Plans CIP West Hill park acquisition. Midway
Subarea parks and recreation goals and policies are oriented towards acquiring,
designing and constructing civic plazas, parks, and other recreation facilities
4-27
September 2011
appropriate to development of a high density TOC. A listing of draft Midway

Subarea policies is included in the Mitigation section below.
Given the lack of park and recreation facilities in all portions of the Midway
Subarea and the Citys intended direction to prepare more qualitative LOS
standards in the future, the City could in the interim determine an appropriate
ratio of on-site park and recreation space to be provided with new development.
For example, currently, the City requires that residential subdivisions and short
subdivisions provide recreation space for leisure, play, and sport activities at a
ratio of 450 square feet per dwelling unit (KMC 12.04.060), and also allows a fee
in-lieu of providing the facility on site (KMC 12.04.065). Applying this ratio to
the growth of the Proposal in the Midway Planned Action Area (8,153
households) would result in approximately 84 acres of open space. This,
combined with the 83 acres of landfill that are identified as part of the Subarea
Plan Open Space Framework, would begin to achieve substantial park and open
space land serving the increased population in the Midway Planned Action Area,
as well as the overall subarea. It is recognized that a feasibility analysis is
required to determine whether the landfill area has recreational value beyond
mere open space.

Amend text on DEIS pages 3.6-88 and 3.6-90, ImpactsMidway Subarea, to correct
projected households and students in the Midway Subarea. The resulting figures
provide for a smaller number of households and students in the Federal Way School
District portion of the Midway Subarea and slightly higher numbers of projected
households and students in the Kent School District portion of the Midway Planned
Action Area.

The Federal Way School District encompasses a larger portion of the City limits
than the Highline School District. Under the Proposal, the Federal Way School
District can expect an increase of approximately 5,400 households in the Kent
portion of the school district over the planning period. More than 89% of the new
households would be multifamily dwellings located in the Midway Subarea.
Approximately, 2,9503,925 of the new multifamily households would be located
in the Kent Highlands as part of a mixed-use development under the Proposal.
There would be a smaller increase (approximately 19%) in single-family housing
in residential neighborhoods located outside the Midway Subarea.
Using the same student generation ratios utilized to analyze the Kent School
District and Highline School District, the portion of the Federal Way School
District located in Kent would experience an increase of 2,400 students over the
4-28
planning period. More than Approximately 1,1801,500 of these students would

be located in the Kent Highlands, part of the Midway Planned Action Area.
The Federal Way School Districts 2010 Capital Facilities Plan identifies some
infrastructure projects that would add capacity in the vicinity of the Midway
Subarea, including the replacement Sunnycrest Elementary School. These
improvements would help address school capacity needs, at least in part. The
large increase in population, particularly in concentrated areas and areas with
little or no existing residential development, such as Kent Highlands, makes it
likely that additional capacity would be needed at one or more level of school
facilities in this portion of the Federal Way School District. The school district
may also make use of relocatables, attendance boundary adjustments, or similar
measures to ensure student capacity is available at the time it is needed.
Kent School District

Under the Proposal, the portion of the Kent School District within the Kent
Highlands would likely include mixed-use development, including multifamily
residential development. Under the Proposal, the schools in the Kent School
District serving this portion of the Kent Highlands could see an increase of
approximately 400200 to 300 students given the magnitude of new development
anticipated in the Kent Highlands.

Amend text on DEIS page 3.6-91, ImpactsMidway Subarea, to clarify the area
where sewer infrastructure would be at or slightly over capacity.
The Midway Sewer Districts consultant modeled the new growth anticipated in
Kents portion of the Midway Subarea. Based upon this analysis, the Midway
Sewer Districts infrastructure is capable of handling the increased flows
resulting from the Proposal. However, the model showed one area along 20th
Avenue S, between S 244th Street and S 244th Place (located west of the
Midway Subarea boundary) that would be at or a little over capacity with new
flows. The district will monitor as development occurs to see if the capacity
issues actually do develop as predicted in the model, and implement facility
improvements as needed for this 400-foot section of an18-inch pipe (Kase pers.
comm.).

Amend text on DEIS page 3.6-93, Mitigation MeasuresKent Planning Area, to
clarify the Kent Fire Department RFA Mitigation and Level of Service Contribution
policy in response to comment 4-1.
4-29
September 2011
KCC Title 13 contains the Citys fire code and enforcement provisions.
The Kent Fire Department RFA has a Mitigation and Level of Service
Contribution policy which it uses to analyze impacts on LOS arising from new
growth. This policy also establishes a flexible framework of mitigation options
that fairly credit developers with existing capacity and offset adverse impacts on
LOS.

Amend text on DEIS page 3.6-93, Mitigation MeasuresKent Planning Area, to
clarify the update to the Surface Water Design Manual.
The City of Kents Storm and Surface Water Utility Code (KCC 7.05) applies to all
new development and redevelopment occurring within the City limits. The Citys
existing 2002 Stormwater Surface Water Design Manual is a version of the 1998
King County Stormwater Surface Water Design Manual. The standards have been
adjusted to meet equivalency requirements of the Washington State Department of

Amend text on DEIS page 3.6-94, Mitigation MeasuresKent Planning Area, to add
clarifications suggested by City.
The City has a new contract for garbage, recycling, and yard/food waste
collection effective April 1, 2011, which allows for more items to be recycled
and also provides a yard and food waste cart for all customers. In terms of long-
range planning, the 2006 King County Solid Waste Transfer and Waste
Management Plan (King County Solid Waste Division 2007) is being updated
with the latest draft dated October 2009. Except for the cities of Seattle and
Milton, all of King County is covered by this plan and its update. The 2006 King
County Solid Waste Transfer and Waste Management Plan (King County Solid
Waste Division 2007) includes measures to help facilitate and increase the
amount of recyclable materials being diverted from the waste stream. These
measures should reduce the amount of waste going to landfills via transfer
stations and residential/commercial collection. There are no other applicable
regulations and commitments for solid waste utilities.

Amend text on DEIS page 3.6-94, Mitigation MeasuresKent Planning Area, to add
clarifications suggested by the Kent Fire Department RFA.
4-30
The Kent Fire Department RFAService providers could add fire facilities and
staff to serve the growing population. The RFAd willService providers should
monitor growth and demand for service through its regular planning and
budgeting processes and implementation of the departments Mitigation and
Level of Service Contribution policy. Revenues from increased employment
activity and increased property values could help offset some of the additional
expenditures for providing additional responses to incidents as a result of growth.
The Kent Fire Department RFA is in the process of updating developing a its
cConcurrency mManagement systemPlan, which, when completed, will be used
in conjunction with its Mitigation and Level of Service Contribution policy to
help assess and mitigate the impacts of new development on fire facilities and
resources (Rabel pers. comm.).

Amend text on DEIS page 3.6-95, Mitigation Measures Kent Planning Area, to
revise the anticipated adoption date of the updated Stormwater Management Manual
as suggested by the City.
Stormwater
The City Stormwater Utility is in process of revising its stormwater manual, and
anticipates that by the end of 2010, it will have adopted a stormwater manual
equivalent to Ecologys Stormwater Manual adjusted the standards of the 2002
Surface Water Design Manual (a modified version of the 1998 King County
Surface Water Design Manual) to meet the equivalency requirements of the
Western Washington (2005).

Amend text on DEIS page 3.6-97, Mitigation MeasuresMidway Subarea, to add
clarifications suggested by the Kent Fire Department RFA in response to comment
4-1.

Increases in traffic congestion and use of service capacity due to the larger
amount of population and employees in the Midway Subarea willare likely to
trigger the need for additional fire facilities and staff to serve the growing
population in this area.
The Kent Fire Department RFA will analyze the Citys updated population and
employment projections for the Midway Subarea, update its Concurrency
Management Plan and assess potential impacts and facility needs using its
Mitigation and Level of Service Contribution policy as it plans for future
4-31
September 2011
facilities and resources. All future development of the Midway Planned Action
Area will need to comply with this policy to provide adequate funding and
mitigation necessary to maintain LOS (Rabel pers. comm.).

Amend text on DEIS page 3.6-97 and 3.6-98, Mitigation MeasuresMidway
Subarea, to clarify the proposed method of obtaining parks and recreation mitigation.

Applying the 2009 Parks and Recreation space LOS standards to the Midway
Subarea, shows that the Midway Subarea would need 83 and 449 acres of park
land and between approximately 10,093 square feet and 54,748 square feet of
recreation space for the Midway Subarea. Of these amounts, the between 16 and
321 acres of park land and approximately 1,967 square feet and 39,131 square
feet of recreation space would need to be provided in the Midway Planned
Action Area. Acre demand figures do not reflect that there are about 212 acres of
open space in the overall Midway Subarea in the form of the landfills, parks
(City of Kent Park 2.7 acres), and public and private wetlands. A feasibility
analysis would be required to determine whether the landfill areas have
recreational value beyond mere open space.
The 2010 Park & Open Space Plan includes Envision Midway Subarea park
acquisition and development of the Kent West Hill Neighborhood Park high
priority capital investments. The Envision Midway park acquisition would be
programmed to acquire some of the parks and recreation spaces conceptually
identified in the Midway Subarea Plan. Although not in the Midway Subarea, the
Kent West Hill park will provide park amenities proximate to the Midway
Subarea that will help meet some of the deficit of park facilities experienced in
that area.
The City could require planned action applicants to provide both of the
following:
Recreation space for leisure, play, or sport activities at a ratio of 450 square
feet per dwelling unit. A recreation space may consist of a playground, sport
court, or any other recreation facility proposed by the applicant and approved
by the parks and community services director.
A pedestrian-oriented plaza or open space at a ratio of 1% of the site or
building area, whichever is greater. A pedestrian-oriented space is one that
contains visual and pedestrian access (including barrier-free access) to the
abutting structures from the public right-of-way or a nonvehicular courtyard;
paved walking surfaces of either concrete or approved unit paving; on-site or
building-mounted lighting providing at least 4-foot candles (average) on the
ground; and a seating area.
4-32
Through a negotiated voluntary agreement, the City may apply the parks and
recreation standards to a specific development and allow one or more of the
following: 1) a portion of the recreation space to be a community building; 2) a
portion of the recreation space to be accomplished off site; 3) a higher or lower
ratio dependent on the demand caused by the proposed development; and 4) a fee
in-lieu of providing the recreation or pedestrian-oriented space.
4-33
September 2011
Chapter 5. Responses to Comments
This chapter of the Final Environmental Impact Statement (FEIS) contains the
written and verbal comments provided on the Draft Environmental Impact Statement
(DEIS) during the comment period that extended from October 22, 2010 to
November 23, 2010. Written comments during the 32-day comment period and
verbal comments received at the Land Use and Planning Board meeting held on
December 6, 2010, 1 are included. Responses to these comments are also included in
this chapter.
5.1. Written Comments

During the 32-day comment period, four individuals prepared letters commenting on
the DEIS. A list of the commenters in chronological order of the date their comments
were received is provided in Table 5-1.
Table 5-1. Public Comment Letters Received

DEIS Comment Letters
Letter Number Commenter Date
1 Patrick McGraner, Department of Ecology November 8, 2010
2 Grant Fredericks, Director of Planning, Building, and Public Works, November 22, 2010
City of Des Moines
3 Karen Williams, Housing Development Consortium November 22, 2010
4 Larry Rabel, Kent Fire Department Regional Fire Authority November 23, 2010
1
The City originally scheduled and advertised a public hearing for Monday, November 22,
2010, during the official DEIS comment period. However, the public hearing was canceled
because of heavy snow and the resulting hazardous traveling conditions. The City rescheduled
the public hearing for December 6, 2010, and allowed public comment on the DEIS to be
taken at that time because the original public hearing included comment on the DEIS on its
agenda.
5-1 September 2011

5.1.1. Responses to Comments

Responses to letter comments are provided in Table 5-2. Distinct comments are
numbered in the margins with responses corresponding to the numbered comment.
Comments that state an opinion or preference are acknowledged with a response that
indicates the comment is noted and forwarded to the appropriate decision maker(s).
Comments that ask questions, request clarifications or corrections, or are related to
the DEIS analysis are provided a response that explains the EIS approach, offers
corrections, or provides other appropriate replies.
Table 5-2. Responses to Letter Comments

Comments
Comment
Number Response
Letter 1: Patrick McGraner, Department of Ecology
1-1 The large majority of the wetland noted in this comment letter is located outside of the Midway
Subarea. However, a portion of the wetland crosses through the southern portion of the
Midway Subarea. The parcels within the Midway Subarea are currently zoned as General
Commercial, and are envisioned to continue with commercial zoning designations. However,
as described on page 3.1-28 of the DEIS, because of protections assumed under the Citys
critical areas regulations for wetlands (Chapter 11.06 of the Kent City Code, particularly Article
IV), as well as the requirements of the Clean Water Act, the wetland areas within the Midway
Subarea were assumed to remain undeveloped and not considered part of developable land.
Also see Applicable Regulations and Commitments on DEIS page 3.1-30 which apply to both
the Kent Planning Area and the Midway Subarea. These include compliance with the federal
Clean Water Act and Kent Critical Areas Ordinance.
Letter 2: Grant Fredericks, City of Des Moines
2-1 The document consists of one EIS with level of analysis broken out in two separate
geographic areas. As described in Chapter 2 of the DEIS, the Proposal consists of both impact
evaluation of alternative growth strategies to accommodate additional growth in the Kent
Planning Area on a programmatic level, as well as a more detailed review and analysis of
future growth arising out of adoption of the Midway Subarea Plan and associated regulations
in the Midway Subarea suitable for a planned action. Because of the two levels of analysis
Kent Planning Area and Midway Subarea within itthe document is broken down
geographically to describe the Kent Planning Area at a programmatic level, followed by
discussion of the Midway Subarea for a planned action review. The Proposal in both
geographic areas is compared to the No Action Alternative throughout the EIS.
2-2 The Proposal includes goals and policies regarding housing, which was addressed on page
3.3-54 of the DEIS. In particular, the Draft Midway Subarea Plan (see DEIS Appendix B)
includes goals and policies relevant to affordable housing. Goal MH-1 promotes a diversity of
housing types that supports a full range of incomes. Policy MH-1.1 encourages workforce
housing, and policy MH-1.2 would create an Affordable Housing Task Force by 2012 to
consider options for resolving issues surrounding the potential displacement of existing
affordable housing in the Midway Subarea. Policy MH-1.3 calls for using a mix of regulatory
incentives, public investments, and other strategies to assist in realizing a mix of housing
types. In addition, the Citys proposed zoning for the Midway Subarea (Appendix C) preserves
Mobile Home Park (MHP) zoning on existing mobile home parks that currently have that
zoning. A property owner would need to seek a rezone to redevelop the property with mixed-
use development, providing an opportunity for public comment and review on any
redevelopment of existing mobile home parks within the Transit-Oriented Community (TOC)
designation of the Midway Subarea, where much of the displacement due to redevelopment is
anticipated to occur.
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Comments
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Number Response
2-3 See tracked edits to Chapter 1 of this FEIS for a revised order that creates a parallel structure
for describing the Proposal to that shown in other parts of the EIS.
2-4 See track-changes edits to Chapter 1 of this FEIS for revised language that clarifies the
organization of Sections 1.3. Clarifications are provided at pages 1-5 (Section 1.3) and 1-16
(Section 1.3.2). Also see response 2-1, the DEIS is one EIS that compares a single Proposal
to a No Action Alternative, though analysis is broken down by the Kent Planning Area
(programmatic) and Midway Subarea (planned action) geographic areas.
2-5 Growth in the Kent Planning Area is shown in Table 2-1 and that within the Midway Subarea is
shown in Table 2-4. These tables are located close to one another to allow a comparative
review of growth, as well as potential growth broken out by Downtown and various activity
centers (Table 2-3). As found in Table 2-4, the Midway Subarea grows by 262 dwelling units
under the No Action Alternative (14%), and grows by 9,904 dwelling units under the Proposal
(517%). The Midway Subarea experiences a growth of 1,538 jobs under the No Action
Alternative (70%), and an increase of 7,298 jobs (136%) under the Proposal. Whereas the
Midway Subarea provides only 5% of the dwelling unit growth and 6.5% of the job growth in
the Kent Planning Area under the No Action Alternative, the Midway Subarea provides 38% of
the Kent Planning Areas household growth and 21% of its job growth under the Proposal.
2-6 Chapter 3 of the DEIS states that implementation of either the No Action Alternative or the
Proposal would result in increased traffic volumes and demand for transportation facilities
within the Midway Subarea. Since both of the identified intersections (Kent-Des Moines
Road/30th Avenue S. and Kent-Des Moines Road/SR 99) are within the Midway Subarea, they
are included in this statement. The specific operational effects of the No Action Alternative and
Proposal on operations at Kent-Des Moines Road/SR 99 intersection are addressed in DEIS
Tables 3.5-10 and 3.5-11 (see DEIS pages 3.5-29 through 3.5-30). The text on page 3.5-30
states that all five key intersections along the SR 99 corridor would have LOS F operations
with greater overall delays than the No Action alternative. This is due to the increase in traffic
volumes under the Proposal relative to the No Action Alternative. Operations at the Kent-Des
Moines Road/30th Avenue intersection is addressed specifically through project mitigation,
which proposes constructing an overcrossing of Kent-Des Moines Road that would alleviate
traffic volumes at all key intersections along SR 99.
2-7 See response to comment 2-4.
2-8 Having an LOS F standard for SR 99 is a policy decision made by the City and is reflected as
such in its Transportation Master Plan and adopted Comprehensive Plan. While the LOS
standard for SR 99 is F, for operational reasons, the DEIS proposes mitigation measures to
lower the delay time. The SR 99 corridor was recently widened with high-occupancy vehicle
(HOV) lanes and there are no further plans for adding roadway capacity within the corridor.
2-9 See DEIS page 3.1-28 (and also page 1-7) where the natural environment analysis indicates
that the parcels with wetlands on them are assumed not to redevelop due to requirements of
the Kent Critical Areas regulations. Also, see response to comment 1-1.
2-10 See response to comment 2-5 above. DEIS pages 1-40 and 3.3-55 to 56 address the greater
intensity of redevelopment planned for the TOC in the Midway Planned Action Area portion of
the Midway Subarea under the Proposal as opposed on DEIS page 1-40, which addresses
both TOCs and areas that are intended to remain lower intensity commercial.
2-11 The Draft Midway Subarea Plan (Appendix B of the FEIS) identifies conceptual open space
framework and includes goals and policies relating to developing parks and recreation space
within the Midway Subarea. As it is a conceptual plan, the framework does not provide an
estimate of the amount of the Midway Subarea dedicated to public open space and recreation
uses. Section 3.6 of the DEIS addresses the estimated parks and recreation areas needed to
meet the Citys parks and recreation LOS standards.
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2-12 Under the Proposal, redevelopment in the Midway Subarea is assumed to occur in buildings
with a maximum height of 200 feet. Section 3.4 of the DEIS addresses impacts of taller
buildings in the surrounding community and sensitive adjacent land uses, such as single-
family residential. DEIS Section 3.4 includes recommended mitigation measures to address
the impact of additional height (see DEIS page 3.4-41). Since the DEIS, the City has refined its
plans for the Midway Subarea. Draft zoning and development regulations apply a zone
(Midway Transit Community 1, or MTC-1) to the portion of the Planned Action Area that abuts
SR 99 and the single-family residential areas to the west that incorporates lower maximum
heights (between 35 and 45 feet) within a 35- to 40-foot distance of a residential zone. In
addition, the maximum height in the MTC-1 zone is 55 feet instead of 200 feet, reducing
impacts associated with taller buildings adjacent to single-family residential areas. This same
MTC-1 zone is applied to the TOC proposed near S 272nd Street, resulting in lower potential
building heights in this area as well.
2-13 See response to comment 2-12 above.
2-14 Although there is potential for interior lighting to contribute to increased ambient light and glare
during evening hours, the effects would be localized and highly dependent on the glazing and
architectural features of individual buildings. Compared to impacts associated with exterior
illumination and street lighting addressed in Section 3.4 of the DEIS, interior building lighting is
not anticipated to be a major factor in light and glare impacts. See Chapter 4, Clarifications
and Corrections, for clarification on this issue.
2-15 As described in the DEIS, the City does not have a quantitative LOS standard associated with
police staffing. This is because the City of Kent Police Department does not believe a
quantitative LOS standard such as number of officers per 1,000 population, correlates to a
meaningful police LOS standard. Instead, as described in the DEIS, the City relies on a
response time LOS standard. The City also has qualitative means of assessing its police LOS
standards that include assessment of any complaints received relating to interaction with
police, as well as community surveys on police service and community safety. The City
intends to use a combination of response time with its other qualitative measures for LOS in
the future to assess adequacy of police services and staffing (Painter pers. comm.).
Regardless of the measure used to assess Police, the large amount of growth in population
and employment anticipated under the Proposal is expected to increase the demand for police
services that may trigger a need for additional police facilities and staff, as described in the
DEIS.
2-16 The TOC near S 272nd Street is near the boundary with both City of Des Moines and City of
Federal Way. Therefore, population and employment growth in this portion of the Midway
Subarea would result in some increase in calls from the cities of Des Moines and Federal Way
through the mutual aid agreement that these jurisdictions have with one another. However,
since the Citys portion of the Midway Subarea has a small common border with the City of
Federal Way, increases in calls for mutual aid service is expected to be smaller for the City of
Federal Way than for the City of Des Moines, which shares a larger common boundary with
Kent in the Midway Subarea. See Chapter 4, Clarifications and Corrections, for clarification on
this issue.
2-17 Section 3.6 of the DEIS identifies the acres of parks needed under the Proposal for both the
Midway Subarea (449 acres) and the Midway Planned Action Area (321 acres). See DEIS
page 3.6-87.
2-18 Your comment regarding the 30th Avenue Overcrossing, Local Street Connection, and New
Signalized Intersections are noted and have been forwarded to the decision makers for their
consideration. We recognize that the City will have to collaborate closely with the City of Des
Moines and the State to ensure that projects are constructed to mitigate impacts related to the
project. The City is taking a phased approach to implementing the Proposal in the Midway
Subarea. The City is assuming the No Action Alternative level of growth for the first 10 years,
which reflects improvements found within the Citys June 2008 Transportation Master Plan,
and the Proposals level of growth in the second 10 years of the planning period. Within the
5-4
Comments
Comment
Number Response
first 10 years, the City will update its Transportation Master Plan and Comprehensive Plan to
incorporate transportation projects and their funding assumed as mitigation for the Proposal in
the Midway Subarea.
As you note, Table 3.5-12 states that the local street connection extending 231st Street from
I-5 to 30th Avenue is identified as contingent on state action. We recognize that the timing,
exact location, and potentially partial funding for this project would be related to the States
plans for SR 509.
2-19 Although complete streets are shown as extending into the City of Des Moines, Figure 2-4 is
intended to conceptually show future land uses in the Midway Subarea. It is not intended to
imply extension of complete streets into the City of Des Moines. See Chapter 2 for the
updated Figure 2-4, and Chapter 4, Clarifications and Corrections for edited Figure 3.5-4 that
removes extension of complete streets into Des Moines.
2-21 See DEIS Table 2-4 where baseline and growth figures for both the No Action Alternative and
the Proposal in the Midway Subarea are located. The growth figures this comment identifies
were taken from the draft Midway Subarea Plan included in the DEIS (see DEIS Appendix C)
and the figures were updated in the EIS analysis to show an increase of 334% in employment
within the Midway Subarea under the Proposal (see Growth Forecast section of Draft Midway
Subarea Plan in Appendix B of FEIS starting on pages 15-21).
2-23 See response to comment 2-5
2-25 As described on page 3.3-60 (sixth bullet) of the DEIS, the provisions of KCC 15.08.215 do not
address the impacts of mixed-use development as these regulations are applied in multifamily
zones only. This zoning code provision is included under the Applicable Regulations and
Commitments for the Kent Planning Area where it would be applicable to subdivision and short
subdivision applications in residential zones. Part of the Citys proposal for the Midway
Subarea is adoption of design guidelines for the Midway Subarea. These design guidelines
include guidelines that address transition with surrounding sites among other things, which
help transition between higher intensity uses anticipated in the TOC, and surrounding
residential districts. In addition, the FEIS Review Alternative includes transitions for maximum
height in the MTC-1 zone, which abuts the lower density residential areas west of SR 99
described in the comment. The MTC-1 zone allows no more than 35 feet of building height
within 30 feet of a residential district and no more than 45 feet within 40 feet of a residential
district. The maximum height within the MTC-1 zone is 55 feet and the zone itself provides a
transition to the MTC-2 and MCR zones located east of SR 99 which allow up to 200 feet in
height.
2-26 Draft Midway Design Guidelines were reviewed as part of the environmental analysis for the
DEIS (see DEIS pages 3.4-38 through 3.4-40 for description of the design guidelines assumed
for the Midway Subarea). The City plans to bring design guidelines forward concurrent with its
Midway Subarea Plan review and adoption. See Appendix C for proposed Midway Design
Guidelines.
2-27 Sections 3.3.4.1 and 3.3.4.2 of the DEIS (pages 3.3-61 and 3.3-62) describe the significant
unavoidable adverse impact of densification and intensification of uses that would add to the
Citys urban character, including in the Midway Subarea. Additional clarification is added in
particular to describe changes in the proposed TOC designations within the Midway Subarea.
See Chapter 4, Clarifications and Corrections.
2-28 See Chapter 4, Clarifications and Corrections, for the addition of Rapid Ride A Line to the
transit service now in effect in the Midway Subarea. Rapid Ride A Line began service in
5-5
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Number Response
October 2010 at the time the DEIS was published.
2-29 Comment noted and forwarded to the decision makers for their consideration regarding TMP
Project #I-16 (which includes widening the westbound approach to the SR 99/S 260th Street
intersection).
2-30 Due to the uncertainties surrounding the states SR 509 project, including how it will affect
connections to I-5 and how traffic would be routed through this area, intersections along Kent-
Des Moines Road were not modeled. Thus, the document identified a significant unavoidable
adverse impact related to the increase in traffic volumes that would be anticipated under either
the No Action Alternative or the Proposal.
The modeling discussed in this section is related to a small area model that evaluated internal
subarea circulation with and without the 30th Avenue overcrossing and other projects listed in
Table 3.5-12. This subarea model suggested that many travelers (approximately 1,500 to
2,000 during the PM peak hour) would use the overcrossing to travel between the subarea and
points north (including the City of Des Moines and destinations accessible from S 231st
Street), bypassing the intersections along Kent-Des Moines Road. The overcrossing should
provide a high degree of relief for the current configuration of traffic flow (the SR 516/SR 99
intersection).
2-31 The extension of S 231st Street from I-5 to 30th Avenue provides an alternate route for
Midway Subarea traffic to access destinations east of I-5 without traveling through the heavily
congested I-5/ Kent-Des Moines Road interchange. The connection would serve the local
development within Kent Midway. Traffic not related to the subarea would likely choose to use
Kent-Des Moines Road, since that route is more directly linked to the regional roadway
network. The local road connection would not be conducive to higher speed or large vehicle
traffic. The City would need to coordinate closely with both the City of Des Moines and the
state to ensure that it fits within the neighborhood setting and is consistent with proposed
improvements to the I-5/Kent-Des Moines interchange and SR 509.
2-32 Please see the Appendix F, which includes the volumes for the SR 99 intersections with S
240th, S 252nd, S 260th, and S 272nd under both the No Action Alternative and Proposal.
Please note that intersection volumes were not forecast at the SR 99/Kent Des Moines Road;
however, it was disclosed that this intersection, which is already approaching capacity today,
would operate at LOS F in the future.
2-35 Your comments about the substantial delays at the SR 99/Kent-Des Moines Road intersection
have been noted and forwarded to decision makers for their consideration. The intersection is
managed by the State of Washington and the City of Des Moines which is one reason that the
City of Kent proposed mitigation to the nearby streets and intersections which are within the
Citys domain. Having an LOS F standard for SR 99 is a policy decision by the City and is
reflected as such in its Transportation Master Plan and adopted Comprehensive Plan. The
City is considering mitigation, including the projects identified in Table 3.5-12 of the DEIS for
the Proposal level of development in the Midway Subarea. The SR 509 study conducted by
WSDOT on SR-509/I-5 interchange connections will study the effects of various intersection
enhancements, grade separations, a pedestrian bridge, and the effects of not completing SR
509 on the operations at this intersection. The City has every expectation that the state will
complete this phase of the SR 509 project before full buildout in the Midway area is realized.
Traffic operations at the SR99/Kent-Des Moines Road intersection and at individual
intersections along the SR 99 corridor will need to be monitored as areas in Kent and Des
Moines redevelop and travel patterns and modes evolve. An appropriate combination of
mitigation measures then should be developed as required to meet adopted LOS standards, in
collaboration with WSDOT and the City of Des Moines. By implementing all of the proposed
transportation demand management techniques, proposed infrastructure improvements that
are within the Citys area of influence, coordinating with the two regional transit agencies on
5-6
Comments
Comment
Number Response
their planned capacity improvements, and coordinating with WSDOT on its planned capacity
improvements, the City plays an integral role in assuring both mobility and accessibility to
future households and jobs.
2-36 Your comment has been noted and forwarded to decision makers for their consideration.
2-37 Your comments have been noted and forwarded to decision makers for their consideration.
2-38 The Draft Midway Subarea Plan (Appendix B) includes several goals and policies related to
improving pedestrian safety and security, including Goals MLU-3 and MUD-3, and policies
MUD-3.1 and MUD-3.2. Part of the Proposal for Midway would include improvements to
pedestrian safety, particularly in the TOC, where pedestrian activity is expected to grow more
than in other areas. Your comments have been noted and forwarded to decision makers for
their consideration.
2-39 The City requested inclusion of bus pull-outs in SR 99 design in 2000 and 2003. However,
King County Metro was unwilling to build bus pull-outs in Kent. In its correspondence with the
City in 2000, King County Metro indicated that the only potential need for bus pull-outs would
be for handicapped van service. However, this service in the area had been cut and at the
time King County Metro staff indicated that it was extremely doubtful that this service would
return. Your comments have been noted and forwarded to decision makers for their
consideration.
2-40 Policy MP&O 1.6 calls on the City to engage with neighboring jurisdictions, school districts,
and others in an effort to share existing facilities through joint use. The Midway Subarea Plan
also includes interjurisdictional coordination goals that call for the City to work with City of Des
Moines and other entities to implement the Midway Subarea Plan. Your comment has been
noted and forwarded to decision makers for their consideration.
2-42 The City has developed a mechanism that it intends to use for providing additional park and
recreation facilities in the Midway Subarea that is based, in part on the Citys current parks and
open space requirements for subdivisions and short subdivisions. A clarification has been
added to Chapter 4 (see Section 4.6.21 of Chapter 4) outlining this method, and it is also
included in Exhibit B in Appendix A, Draft Planned Action Ordinance.
Letter 3: Karen Williams, Housing Development Consortium
3-1 See response to comment 2-2. Your comments have been noted and forwarded to decision
makers for their consideration.
3-2 As noted in your recommendation, Midway Subarea Plan policy MH-1.2 calls for creating an
Affordable Housing Task Force by 2012 to consider options, policies, and partnerships for
resolving issues surrounding the potential displacement of existing affordable housing. Your
comments relating to specific recommendations for this task force and its work program have
been noted and forwarded to decision makers for their consideration.
3-3 Although the Midway Subarea Plan policies do not identify numerical targets for affordability,
the City does this for the Kent Planning Area as a whole. The Citys Housing Element includes
targets for low-income and moderate-income households consisting of percentages of the
Citys regionally adopted growth targets. For the City, these are 20% for low-income
households and 17% for moderate-income households (see page 6-9, City of Kent
Comprehensive Plan). Your comments have been noted and are forwarded to decision
makers for their consideration.
3-4 Although the City does not have specific regulations proposed for affordable housing in the
Midway Subarea, the City has chosen to retain the MHP zone as an implementing zone within
the Midway Subarea. This zone is applied to existing mobile home parks within the Midway
Subarea, representing a large portion of the existing affordable housing stock within the
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September 2011
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Number Response
Midway Subarea. By retaining the MHP zone, a property owner would first be required to apply
for a rezone of the property, providing a public process with opportunity for public comment
and a hearing prior to deciding to rezone the property. Additional regulations and land use
policies relating to affordable housing would be part of the Affordable Housing Task Forces
work program (see response to comment 3-2). Your comments on specific recommended
regulatory actions have been noted and forwarded to decision makers for their consideration.
Letter 4: Larry Rabel, City of Kent Regional Fire Authority
4-1 Your comments on Fire and Emergency Services in Chapter 1 and Section 3.6 of the DEIS
have been incorporated into FEIS Chapter 4, Clarifications and Corrections.
5.2. Public Hearing Comments

Table 5-3 provides a list of individuals who provided verbal comments at the
December 6, 2010 Public Hearing 2 and a summary of the public comment that was
made divided by comment subject. Detailed comments may be reviewed by listening
to a recording available at <http://www.ci.kent.wa.us/planning/lupb/>.
Table 5-3. Public Hearing Comments Received

DEIS Public Hearing CommentsDecember 6, 2010
Meeting
Comment
Number Name Summary of Comment
PH 1-1 Betty Lou Kapela Wants to know who made the decision on the location of
the light rail found in the Land Use and Planning Board
packet.
The whole Midway Subarea Plan looks mind-boggling
and fabulous. However, she owns 13 acres next to the
freeway behind Lowes. The Midway Subarea Plan
appears to place more than half of this property in park or
watershed. She does not want to see her land devalued
by making it a park or watershed.
She is also concerned by future property tax increases
that would result from the rezone of her property in
Midway Subarea.
PH 2-1 Jim Seymour He has seen lots of traffic growth on 30th Avenue over
the years. The plan for additional mixed-use and
commercial traffic in Midway would further degrade
2
The City originally scheduled and advertised a public hearing for Monday, November 22,
2010, during the official DEIS comment period. However, the public hearing was canceled
because of heavy snow and the resulting hazardous traveling conditions. The City rescheduled
the public hearing for December 6, 2010, and allowed public comment on the DEIS to be
taken at that time because the original public hearing included comment on the DEIS on its
agenda.
5-8

Meeting
Comment
safety conditions on 30th Avenue which needs widening,
sidewalks, turn lands, and school bus pullouts, and
crosswalks now.
PH 3-1 Bob Bolger He was part of the original Envision Midway citizens
group. At one point there was talk of creating a road that
crosses over I-5 near S 240th Street. What happened
with this idea? A crossing at this place would have
impacts on 30th Avenue and the area behind Lowes that
was discussed by previous speakers.
PH 4-1 Karen Williams, South King County The City needs clear provisions and targets for affordable
Housing Consortium housing with a relocation plan for existing residents.
Many cities have affordable housing goals, but not
implementing measures. The Midway Subarea Plan
provides for improvement and redevelopment of the
area, which is good. But, the City should also plan for
affordable housing, including housing for seniors, and
families. The City estimates that 700 residents would be
displaced for redevelopment. The City should provide a
plan for relocation of those residents.
The City has plans for streets, landscaping, and design
among other things. But, the City also needs to plan for
affordable housinghousing that people working in
service jobs can afford.
Suggestions include a requirement that new
development include 10% affordable housing, and that
the City seek support from non-profits.
PH 5-1 Bob Kapela His wife addressed their 13-acre property near I-5
already. They also own property on SR 99 between S
240th and S 244th Streets. He has concerns that
rezoning his property will increase his property taxes.
PH 6-1 Robert Pond His concern is to retain his neighborhood as a residential

area suitable for condos. He does not want an access
road dumping more traffic into 30th Avenue for SR 509.
There was a past problem with semi trucks in his
residential neighborhood. He is afraid that semi trucks
will be back. Semis dont mix with a residential
neighborhood.
PH 7-1 Brad Corner He represents property owners of property in NE

quadrant of 231st Street and Military Road intersection.
He is in favor of Option #3 presented for the Midway
Subarea Plan. It responds to their demand for more
flexibility. He concurs with previous speakers concerns
about the law of unintended consequences with respect
to results of the rezone. He wonders if there is a way to
incorporate mechanisms into the planned action
ordinance or elsewhere that provides flexibility for
property owners.
PH 8-1 Dana Kapela Her family owns three different properties in the Midway
Subarea. They were initially excited about the planning
efforts. However, they are now worried about increased
taxes resulting from the rezone.
5-9
September 2011

Meeting
Comment
PH 8-2 Dana Kapela She identified potential problems with requirements for a
minimum of two-story buildings when the economy may
not support redevelopment of multistory buildings now.
Supports more of an incentive based method of allowing
the redevelopment that is envisioned in the Midway
Subarea Plan, but allowing existing land uses to
continue.
PH 8-3 Dana Kapela Also concerned that their roughly 13 acres of land is
shown as a part and storm detention facility. Her family is
not interested in seeing their land turned into park and
storm detention for other properties.
PH 8-4 Dana Kapela Also concerned with how to operate a mobile home park
under the new zoning. Would replacement of mobile
homes (i.e., double-wide replacing a triple-wide) be
considered expansion of a nonconforming use? City
should have provisions in place to allow continued
operation of mobile home parks under new zoning.
Responses to public hearing comments appear in Table 5-4. Comments that state an
opinion or preference are acknowledged with a response that indicates the comment
is noted and forwarded to the appropriate decision makers. Comments that ask
questions, request clarifications or corrections, or are related to the DEIS analysis are
provided a response which explains the EIS approach, or offers corrections, or
provides other appropriate replies.
5.2.1. Responses to Public Hearing Comments
Table 5-4. Responses to Public Hearing Comments

Comments
Comment
Number Response
PH-1: Betty Lou Kapela
PH 1-1 Your comments have been noted and forwarded to decision makers for their consideration.
PH-2: Jim Seymour
PH 2-1 Table 3.5-12 in the DEIS (page 3.5-33) identifies improvements to 30th Avenue that would
provide safety improvements for pedestrians as well as improving the streets function as an
alternative for local traffic to SR 99. Your comments have been noted and forwarded to
decision makers for their consideration.
PH-3: Bob Bolger
PH 3-1 The concept of a connection between the Midway Subarea and the rest of the Kent West Hill
near S 240th Street remains within the Midway Subarea Plan. However, this project was
considered to be a long-term improvement that occurred outside of the planning horizon for
this EIS. Therefore, if the project were to be considered sooner, the City would need to
5-10
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Number Response
prepare appropriate environmental documentation.
PH-4: Karen Williams, South King County Housing Consortium
PH 4-1 Please see responses to comments 2-2 and 3-2. Your comments have been noted and
forwarded to decision makers for their consideration.
PH-5: Bob Kapela
PH-6: Robert Pond
PH 6-1 Please see response to comment 2-31.
PH-7: Brad Corner
PH 7-1 Your comments have noted and forwarded to decision makers for their consideration.
PH-8: Dana Kapela
PH 8-2 The City has amended the Midway Subarea Plan to provide increased flexibility, including
removing the requirement for buildings to have a minimum of two stories.
PH 8-4 The City has revised its zoning recommendations to recommend that existing MHP-zoned land
with existing mobile home parks on them retain their MHP zoning. A property owner who has
MHP-zoned land must apply for a rezone to obtain one of the other Midway Subarea zoning
designations.
5.3. Marked Comment Letters

Marked comment letters received follow this page.
5-11
September 2011
Letter 1
1-1
Letter 2
2-1 2-2 2-3 2-4 2-5 2-6 2-7 2-8 2-9
2-10 2-11 2-12 2-13 2-14 2-15 2-16 2-17 2-18
2-19 2-20 2-21 2-22 2-23 2-24 2-25 2-26 2-27 2-28
2-29 2-30 2-31 2-33 2-35
2-32 2-34
2-36 2-37 2-38 2-39 2-40 2-41
2-42
Letter 3
3-1
3-2
3-3
3-3
3-4
3-5
Letter 4
4-1
Chapter 6. Distribution List
A notice of availability, or a compact disk, or a copy of the FEIS was sent to the
following agencies, organizations, or individuals. A notice of availability was also
published in the Citys newspaper of record, and emailed to a stakeholder list.
Agencies with an asterisk (*) were provided with an electronic copy of the FEIS.
6.1. Federal Agencies

U.S. Army Corp of Engineers U.S. Department of the Interior, Fish and
Wildlife Service
U.S. Department of Archaeology and
Historic Preservation U.S. Environmental Protection Agency
U.S. Department of Housing and Urban
Development, Market Analysis Staff
OASM
6.2. Tribal, State and Regional Agencies

Duwamish Tribal Services Puyallup Tribe of Indians
Environmental Planning, OAP King County *Recreation and Conservation Office

Wastewater Treatment Division *Washington Department of Fish and
Wildlife
King County Adult Detention
*Washington State Department of
King County Arts Commission, Department Archaeology and Historic Preservation
of Historic Preservation
*Washington State Department of
Commerce, Growth Management
6-1
September 2011
King County Department of Natural Services, Review Team

Resources *Washington State Department of
Corrections
King County Department of Transportation,
Metro Transit Division, Design and *Washington State Department Of Ecology
Construction Environmental Planning and Attn: Patrick McGraner
Real Estate
*Washington State Department of Health,
King County Office of Cultural Resources Environmental Health Division
King County Water and Land Resource *Washington State Department of Natural
Resources
Division
*Washington State Department of Social
Metropolitan King County Council and Health Services
Muckleshoot Tribe *Washington State Department of
Transportation
Nisqually Indian Tribe
Washington State Office of Superintendent
Public HealthSeattle and King County
of Public Instruction
Puget Sound Clean Air Agency Attn: Terry Michalson
Washington State Utilities and
*Puget Sound Partnership
Transportation Commission
Attn: Jeffrey Showman
Norman Abbott, Puget Sound Regional
Council Paul Reitenbach, King County Department
of Development and Environmental
King County DDES, SEPA Review Services
U.S. Geological Services, Washington
District Office
6.3. Cities and Neighboring Planning Departments

*City of Auburn Planning Department *City of Renton Planning Department
*City of Covington Planning Department *City of SeaTac Planning Department
*City of Des Moines Planning Department City of Seattle

Attn: Grant Fredericks, Director
*City of Tukwila
*City of Federal Way Planning Department Department of Community Development
City of Maple Valley *King County DDES, SEPA Review
6-2
Distribution List
6.4. Public Services, Transportation, and Utilities

*Auburn School District *Midway Sewer District
*Cedar River Water and Sewer District Puget Sound Energy
Des Moines Library Qwest Communications
*Federal Way School District *Renton School District
*Highline Community College Seattle Public Utilities
*Highline School District *Soos Creek Water and Sewer District
*Highline Water District *Sound Transit
Kent Fire Department Regional Fire University of Washington

Authority Suzzallo Library
Attn: Larry Rabel Government Publications Division
*Kent Regional Library Valley View Library
*Kent School District *Water District #111
*King County Metro Transit Woodmont Library
*Lakehaven Utility District
6.5. Individuals and Companies

Norman Abbott Bruce Lorig, Lorig Associates
Kennedy Akinlosotu Bruce Malcolm

M. Bruce Anderson, Anderson and Michael D. Manderville
Associates
Elisa Martin
Mauricio Ayon, La Plaza Development
Alex Martinac, CBRE Real Estate
Jordan Balls
Linda and Larry Martinez
Steve Babbitt
Patrick McBride, GMS Architectural Group
Dawn Banfield
Grant McClamrock
Peter Battuello, Principal, Parametrix
John McKnight, Assist, Inc.
6-3
September 2011
Steve Fuller, Parametrix Michael J. McMahon, West Hill Manor

Mobile Home Park
Kim Beasley, Kimberley's Exquisite
Jewelry Robert W. McOmber
Jack and Mary Becvar Theresa Lynn Melton, New Alaska Mobile
Home Park
Jim Bitondo, Ditco Inc.
Bill Miller
Bob Bolger
Greg Mitchell, Bsi Owner, Loan Company
Kendra Breiland, Fehr and Peers
Chuck Monro
Allen Brown
Ed Moore
Fred Brown, F.F. Brown Design
Carol Morford
Wayne Browne
Dee Moschel
Earl Brunk
Pat Murray, Murray's Collision Center
Christina Budell
Bridget Myers, John L Scott
Steve Burpee
John Nason, Nason's Graphics Factory
Sarah Campbell, Manager, Key Bank
Greg Newborn
Betty Lou Kapela
Steven Nuss
Bob Kapela
Robert O, Windermere Real Estate
Dana Kapela
Bonnie Oakley
Steven L Carroll, New Alaska Mobile
Home Park Eric Olason, ARCA Architecture and Urban
Design
Gene Chase
James Ouderkirk
Pamela-Raie Cobley
John Owen, MAKERS architecture + urban
Pat Colgan
design
May Collier
Sam Pace, Seattle King County Association
Sue Cornell of Realtors
Brad Corner David Paice
Colleen Cristel Bob Pond
Robert Cryan, Cryan Properties Lee Porter, Second Avenue North

Associates
6-4
Distribution List
Charlet and Fred Dalbec Mark Proulx
Terrence Danysh Jerry Puetz
Randy Dorn Glenda Pugerude, Pugerudes Draperies
Chester Dorsey Jr., Chester Dorsey Auto Dallas Radford

Salons
Rainier Audubon Society
Joshua Douglass
Hans and Donna Rasmussen
Fauna Doyle, Berk and Associates
Richard Rawlings, Polygon Homes NW
Noly Ducay
Melvin L. Roberts, KBAB
Dave Dunn
Stephan Rodmyre, Holy Trinity Lutheran
John Fanning School
Dorothy Farnsworth Steve Rodrigues, Its the Water, LLC
Kelsey Feola, Seattle University Bob Rosain, Parametrix
Friends of the Green River Harold Schwanke
Futurewise Seattle Audubon Society
Terrence Gallman Seattle PI, Southend News
Ted Gimln Seattle Times
Meghann Glavin, Berk and Associates Paul Seely
Bobbie Gojenola James Seymore PhD, Key Pharmacy
Diane Gordon, Keller Williams Realty Don Shaffer, Kent C.A.R.E.S.
Scott Goss Tom Sharp
Jennifer Grant Amarjeet Singh
Alan Gray Robert Slattery
Jacob Grob, KBAB Barbara Smith, Kent Downtown Partnership
Pati Guenther Lloyd and Loraine Smith
Emily Gunther Sathya Srinivasan
Rena Hamburger Ben Stark
Alyne Hansen Brian Starr, Snap Fitness
6-5
September 2011
Madge Hanson John Steeds
Brad, Beverly and Nathan Hart Garry Stewart, Doorman Services
Charlie Heffernan, ClearPath RE, LLC Carsten Stinn Architecture
Pam Hemminger, Owner, Brierwood Apts Marvia Stratis
Joseph Hetzel Cynthia Tanis
Ryan Hitt Michael Taskey, KBAB
David Hoffman Tory Laughlin Taylor, Housing Resources
Gerrit Holks Scott Thomson, Strider Group
Pat Holliday Roseanne Torgerson
Karen Hopper Joe Wagenius
Garrett Huffman Rich Wagner, FAIA, Baylis Architects
George Humphrey Washington Environmental Council
Theodore Hunter Weber Thompson Architects
Erica Jensen Bob and Sara Weigand
Bob Johnson, Krazan and Assoc Karen Williams, Housing Development

Consortium
Daryl Johnson
Vicki Winch
Marcia Johnson
Tom Wood, Washington Park Mortgage
Rick and Vicki Johnson
Colleen Wojciechowski
Cheryl Jones
Lee and Roxanne Yardley
Kathi Jones, John L. Scott Realty
Gary Young, Polygon NW
Dana Kalapa, Davis Investors
Kurt Easthouse
Dave Kaplan, Des Moines City Council
Ivana Halvorsen, Barghausen Consulting
John Kastien Engineers
Jerry Kauth
Kent Chamber of Commerce
Kent Downtown Partnership
Lim Hau Kim
6-6
Distribution List
Laurine Knott, Trunk Show Inc
Dale and Gary Labelle
Jun Lagnada
Helen Lakeru, Many Lights Foundation
Andrew Langsford, Venture Real Estate

Group
Rob Larsen, ClearPath RE, LLC
Tim Lloyd
Bob Loeliger
James Peyton
Murphy McCullough, Tarragon
6.6. City Officials, Commissions, and Departments

*City Council *City Hall
*City Department Directors *Land Use and Planning Board
6-7
September 2011
Appendix A
Planned Action Ordinance
SEPTEMBER 2011
ORDINANCE NO.________
AN ORDINANCE of the City Council of the City of Kent, Washington,

establishing a Planned Action for a portion of the Midway Subarea referred
to herein as the Midway Planned Action Area, pursuant to the State
Environmental Policy Act
WHEREAS, the State Environmental Policy Act (SEPA) and

implementing rules provide for the integration of environmental review with land
use planning and project review through designation of Planned Actions by
jurisdictions planning under the Growth Management Act (GMA); and
WHEREAS, the City has adopted a Comprehensive Plan complying with

the GMA; and
WHEREAS, the City has prepared a subarea plan, development

regulations and design guidelines for the Midway Planned Action Area; and
WHEREAS, the City of Kent Comprehensive Plan Review and Midway

Subarea Planned Action EIS identifies impacts and mitigation measures
associated with planned development in the subarea; and
WHEREAS, the City has adopted development regulations which will help
protect the environment, and is adopting zoning regulations specific to the
subarea which will guide the amount, location, form, and quality of desired
development; and
WHEREAS, designation of a Planned Action expedites the permitting

process for subsequent, implementing projects whose impacts have been
previously addressed in a Planned Action environmental impact statement
(EIS), and thereby encourages desired growth and economic development;
and
WHEREAS, a portion of the Midway Subarea referred to as the Midway
Planned Action Area is deemed to be appropriate for designation of a Planned
Action.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF KENT,

WASHINGTON, DOES HEREBY ORDAIN AS FOLLOWS:
SECTION 1. - Purpose. The City Council declares that the purpose of this
ordinance is to:
A. Combine analysis of environmental impacts with the Citys development
of plans and regulations;
Planned Action Ordinance - 1

Kent Comprehensive Plan Review and Midway Planned Action EIS
SEPTEMBER 2011
B. Designate the Midway Planned Action Area as a Planned Action for

purposes of environmental review and permitting of subsequent, implementing
projects pursuant to the State Environmental Policy Act (SEPA), RCW
43.21C.031;
C. Determine that the EIS prepared for the subarea plan meets the
requirements of a Planned Action EIS pursuant to SEPA;
D. Establish criteria and procedures, consistent with state law, that will
determine whether subsequent, implementing projects qualify as Planned
Actions;
E. Provide the public with information about Planned Actions and how the
City will process applications for implementing projects;
F. Streamline and expedite the land use review and approval process for
qualifying projects by relying on the environmental impact statement (EIS)
completed for the Planned Action; and
G. Apply the Citys development regulations together with the mitigation

measures described in the EIS and this Ordinance to address the impacts of
future development contemplated by the Planned Action.
SECTION 2. Findings. The City Council finds as follows:
A. The City is subject to the requirements of the Growth Management Act,

RCW 36.70A, and is located within an Urban Growth Area;
B. The City has adopted a Comprehensive Plan complying with the GMA,
and is amending the Comprehensive Plan to incorporate a subarea element
specific to the Midway Planned Action Area;
C. The City is adopting development regulations and design guidelines

concurrent with the Midway Subarea Plan to implement said Plan;
D. The City has prepared an Environmental Impact Statement (EIS) for

the Midway Subarea, and specifically for the portion of the subarea described as
the Midway Planned Action Area designated as a Planned Action (Planned
Action EIS), and finds that this EIS adequately addresses the probable
significant environmental impacts associated with the type and amount of
development planned to occur in the designated Planned Action area;
E. The mitigation measures identified in the Planned Action EIS and

attached to this ordinance as Exhibit B, together with adopted City development
regulations, will adequately mitigate significant impacts from development within
the Planned Action area;

SEPTEMBER 2011
F. The subarea plan and Planned Action EIS identify the location, type and
amount of development that is contemplated by the Planned Action;
G. Future projects that are implemented consistent with the Planned

Action will protect the environment, benefit the public and enhance economic
development;
H. The City has provided numerous opportunities for meaningful public

involvement in the proposed Planned Action; has considered all comments
received; and, as appropriate, has modified the proposal or mitigation measures
in response to comments;
I. The Midway Subarea Plan is not an essential public facility as defined by

RCW 36.70A.200(1). Future improvements to state education facilities, state
highways or development of light rail transit facilities within the subarea are not
eligible for review or permitting as Planned Actions. However, such future
proposals may use the information contained in the Planned Action EIS,
consistent with SEPA;
J. The Planned Action area applies to a defined area that is smaller than
the overall City boundaries; and
K. Public services and facilities are adequate to serve the proposed

Planned Action, with implementation of mitigation measures identified in the EIS.
SECTION 3. - Procedures and Criteria for Evaluating and Determining

Projects as Planned Actions.
A. Planned Action Area. The Planned Action designation shall apply to the
area shown in Exhibit A.
B. Environmental Document. A Planned Action determination for a site-

specific implementing project application shall be based on the environmental
analysis contained in the Draft EIS issued by the City on October 22, 2010 and
the Final EIS published on _________. The Draft and Final EISs shall comprise
the Planned Action EIS. The mitigation measures contained in Exhibit B are
based upon the findings of the Planned Action EIS and shall, along with adopted
City regulations, provide the framework that the City will use to impose
appropriate conditions on qualifying Planned Action projects.
C. Planned Action Designated. Land uses and activities described in the

Planned Action EIS, subject to the thresholds described in subsection 3.D and
the mitigation measures contained in Exhibit B, are designated Planned Actions
or Planned Action Projects pursuant to RCW 43.21C.031. A development
application for a site-specific Planned Action project located within the Midway
Planned Action Area shall be designated a Planned Action if it meets the criteria

SEPTEMBER 2011
set forth in subsection 3.D of this ordinance and applicable laws, codes,
development regulations and standards of the City.
D. Planned Action Qualifications. The following thresholds shall be used

to determine if a site-specific development proposed within the Midway Planned
Action Area is contemplated by the Planned Action and has had its environmental
impacts evaluated in the Planned Action EIS:
(1) Land Use. The following general categories/types of land uses, which
are permitted or conditionally permitted in zoning districts applicable to the
Midway Planned Action Area, are considered Planned Actions:
multi-family residential uses; retail and service uses; office uses; commercial
activities, including civic uses; educational uses, including colleges;
public/governmental uses; open space; utilities and capital facilities; and lodging.
Anticipated land uses are further identified below:
(a) Retail and service activities, including those categorized as
department, drug and grocery stores; eating and drinking establishments;
specialty goods/foods; entertainment and recreation; convenience stores;
services; and commercial goods;
(b) Civic and cultural uses, including but not limited to libraries, museums,
community center, stadium, performing arts facility, City Hall and other
public facilities which are not defined as essential public facilities;
(c) Office uses, including but not limited to business and professional
offices such as medical or dental, educational and institutional offices,
research and development;
(d) Commercial uses;
(e) Manufacturing/industrial uses (including those categorized as
wholesale, transportation, communication and utilities [WTCU]).
(f) Lodging, such as hotels and motels;
(g) Public and quasi-public uses, including governmental facilities, and
educational facilities, including colleges and universities; and
(h) Residential dwelling units, including multi-family dwellings, residential
care facilities, nursing homes and senior housing.
Individual land uses considered as Planned Actions shall include those

uses specifically listed in development regulations applicable to the zoning
classifications applied to properties within the Planned Action area.
(2) Development Thresholds.

(a) The following amount of various new land uses are contemplated by
the Planned Action:

SEPTEMBER 2011
If Northern Transit Oriented Community is used for the Planned Action

Area
Land Use Development Amount

Residential 8,153 units
Retail 553,351 gross square feet
Office and Services 1 1,623,874 gross square feet
Industrial 2 160,541 gross square feet
Government/Ed 71,588 gross square feet
Lodging 243,957 gross square feet
1. Office & Services includes all land uses categorized as finance, insurance,
real estate and services [FIRES]).
2. Industrial includes all land uses categorized as manufacturing and
wholesale, transportation communication and utilities [WTCU]).
If entire Midway Subarea is used for the Planned Action Area
Land Use Development Amount

Residential 9,904 units
Retail 713,556 gross square feet
Office and Services 1 1,528,715 gross square feet
Industrial 2 338,362 gross square feet
Government/Ed 92,351 gross square feet
Lodging 243,957 gross square feet
1. Office & Services includes all land uses categorized as finance, insurance,
real estate and services [FIRES]).
2. Industrial includes all land uses categorized as manufacturing and
wholesale, transportation communication and utilities [WTCU]).
(b) Qualifying projects shall meet the Planned Action minimum

density/intensity standards of KCC 15.04 for the underlying zone.
(c) If future development proposals in the Midway Planned Action area

exceed the development thresholds specified in this ordinance, further
environmental review may be required pursuant to WAC 197-11-172. Further, if
proposed development would alter the assumptions and analysis in the Planned
Action EIS, further environmental review may be required. Shifting the total build-
out between categories of uses may be permitted so long as the total build-out
does not exceed the aggregate amount of development, and trip generation
reviewed in the EIS, and so long as the impacts of that development have been
identified in the Planned Action EIS and are mitigated consistent with Exhibit B.
(3) Building Height. Building height shall be consistent with the applicable
definitions and standards of the Kent City Code.
(4) Transportation.

SEPTEMBER 2011
(a) Trip Ranges & Thresholds. The number of net new pm peak hour trips
anticipated in the Planned Action area and reviewed in the EIS are as follows:
Net PM Peak Hour trips (northern 7,950

Transit Oriented Community)
Net PM Peak Hour trips (Total 9,833
Midway Subarea)
Uses or activities that would exceed these maximum trip levels will require
additional SEPA review.
(b) Concurrency. The determination of transportation impacts shall be

based on the Citys concurrency management program contained in KCC 12.11.
(c) Off-Site Mitigation. As provided in the EIS, in order to mitigate

transportation related impacts, all Planned Action Projects shall pay an
environmental mitigation fee to participate in and pay a proportionate share of
off-site improvements. Off-site improvements are identified in Attachment B.
(d) Director Discretion. The Director of Economic & Community

Development shall have discretion to determine incremental and total trip
generation, consistent with the Institute of Traffic Engineers (ITE) Trip Generation
Manual (latest edition) or an alternative manual accepted by the City Engineer at
his sole discretion, for each project permit application proposed under this
Planned Action.
(5) Elements of the Environment and Degree of Impacts. A proposed

project that would result in a significant change in the type or degree of impacts
to any of the elements of the environment analyzed in the Planned Action EIS,
would not qualify as a Planned Action.
(6) Changed Conditions. Should environmental conditions change

significantly from those analyzed in the Planned Action EIS, the Citys SEPA
Responsible Official may determine that the Planned Action designation is no
longer applicable until supplemental environmental review is conducted.
E. Planned Action Review Criteria.

(1) The Citys SEPA Responsible Official may designate as Planned
Actions, pursuant to RCW 43.21C.030, applications that meet all of the following
conditions:
(a) the proposal is located within the Planned Action area identified in
Exhibit A of this ordinance;
(b) the proposed uses and activities are consistent with those described in
the Planned Action EIS and Section 3.D of this ordinance;

SEPTEMBER 2011
(c) the proposal is within the Planned Action thresholds and other criteria
of Section 3.D of this ordinance;
(d) the proposal is consistent with the City of Kent Comprehensive Plan
and the Midway Subarea Plan;
(e) the proposals significant adverse environmental impacts have been
identified in the Planned Action EIS;
(f) the proposals significant impacts have been mitigated by application of
the measures identified in Exhibit B, including any equivalent measures
authorized by the City, and other applicable city regulations, together with any
modifications or variances or special permits that may be required;
(g) the proposal complies with all applicable local, state or federal laws
and regulations, and the Responsible Official determines that these constitute
adequate mitigation; and
(h) the proposal is not an essential public facility as defined by RCW
36.70A.200(1).
(2) The City shall base its decision on review of a SEPA checklist, or an
alternative form approved by the Department of Ecology, and review of the
application and supporting documentation.
(3) A proposal that meets the criteria of this section shall be considered to
qualify and be designated as a Planned Action, consistent with the requirements
or RCW 43.21C.030, WAC 197-11-164 et seq, and this ordinance.
F. Effect of Planned Action
(1) Designation as a Planned Action project means that a qualifying

proposal has been reviewed in accordance with this ordinance and found to be
consistent with its development parameters and thresholds, and with the
environmental analysis contained in the Planned Action EIS.
(2) Upon determination by the Citys SEPA Responsible Official that the
proposal meets the criteria of Section 3.D and qualifies as a Planned Action, the
proposal shall not require a SEPA threshold determination, preparation of an EIS,
or be subject to further review pursuant to SEPA.
G. Planned Action Permit Process. Applications for Planned Actions shall

be reviewed pursuant to the following process.
(1) Development applications shall meet all applicable requirements of the

Kent City Code (KCC). Applications for Planned Actions shall be made on forms
provided by the City and shall include a SEPA checklist, or an approved Planned
Action checklist.
(2) The Citys Planning Director or designee shall determine whether the
application is complete as provided in KCC 12.01.

SEPTEMBER 2011
(3) If the application is for a project within the Planned Action Area defined
in Exhibit A, the application will be reviewed to determine if it is consistent with
the criteria of this ordinance and thereby qualifies as a Planned Action project.
The SEPA Responsible Official shall notify the applicant of his/her decision. If the
project is determined to qualify as a Planned Action, it shall proceed in
accordance with the applicable permit review procedures specified in KCC
12.01.100, except that no SEPA threshold determination, EIS or additional SEPA
review shall be required. The decision of the SEPA Responsible Official
regarding qualification as a Planned Action shall be final.
(4) Public notice and review for projects that qualify as Planned Actions
shall be tied to the underlying permit. The review process for the underlying
permit shall be as provided in KCC 12.01.040. If notice is otherwise required for
the underlying permit, the notice shall state that the project has qualified as a
Planned Action. If notice is not otherwise required for the underlying permit, no
special notice is required by this ordinance.
(5) Development Agreement. To provide additional certainty about

applicable requirements, the City or an applicant may request consideration and
execution of a development agreement for a Planned Action project. The
development agreement may address review procedures applicable to a Planned
Action project, permitted uses, mitigation measures, payment of impact fees or
provision of improvements through other methods, design standards, phasing,
vesting of development rights, or any other topic that may properly be considered
in a development agreement consistent with RCW 36.70B.170 et seq.
(6) If a project is determined to not qualify as a Planned Action, the SEPA

Responsible Official shall so notify the applicant and prescribe a SEPA review
procedure consistent with the Citys SEPA regulations and the requirements of
state law. The notice shall describe the elements of the application that result in
failure to qualify as a Planned Action.
(7) Projects that fail to qualify as Planned Actions may incorporate or

otherwise use relevant elements of the Planned Action EIS, as well as other
relevant SEPA documents, to meet their SEPA requirements. The SEPA
Responsible Official may limit the scope of SEPA review for the non-qualifying
project to those issues and environmental impacts not previously addressed in
the Planned Action EIS.
SECTION 4. - Monitoring and Review.
A. The City shall monitor the progress of development in the designated

Planned Action Sub-area to ensure that it is consistent with the assumptions of
this ordinance and the Planned Action EIS regarding the type and amount of
development and associated impacts, and with the mitigation measures and
improvements planned for the Midway Planned Action Area.

SEPTEMBER 2011
B. This Planned Action Ordinance shall be reviewed no later than five

years from its effective date by the SEPA Responsible Official to determine the
continuing relevance of its assumptions and findings with respect to
environmental conditions in the Planned Action area, the impacts of
development, and required mitigation measures. Based upon this review, the
City may propose amendments to this ordinance or may supplement or revise the
Planned Action EIS.
SECTION 5. - Conflict. In the event of a conflict between this Ordinance

or any mitigation measure imposed thereto, and any ordinance or regulation of
the City, the provisions of this ordinance shall control EXCEPT that the provision
of any International Code shall supersede.
SECTION 6. - Severability. Should any section, subsection, paragraph,

sentence, clause or phrase of this Ordinance or its application be declared to be
unconstitutional or invalid by a court of competent jurisdiction, such decision shall
not affect the constitutionality or validity of the remaining portions of this
ordinance or its application to any other person or situation.
SECTION 7. - Effective Date. This ordinance, being an exercise of a

power specifically delegated to the City legislative body, is not subject to
referendum, and shall take effect five (5) days after its passage, approval and
publication as provided by law.

SEPTEMBER 2011
APPROVED
________________________
SUZETTE COOKE, MAYOR
ATTEST:
______________________________
BRENDA JACOBER, CITY CLERK
APPROVED AS TO FORM:
_________________________________
TOM BRUBAKER, CITY ATTORNEY
PASSED __ day of ________________, 2011
APPROVED __ day of ________________. 2011
PUBLISHED __ day of ________________ 2011
I hereby certify that this is a true copy of Ordinance No. _____

passed by the City Council of the City of Kent, Washington, and approved
by the mayor of the City of Kent as hereon indicated.
____________________________
CITY CLERK

SEPTEMBER 2011
EXHIBIT A
PLANNED ACTION AREA
TO BE PROVIDED

SEPTEMBER 2011
EXHIBIT B
PLANNED ACTION EIS MITIGATION MEASURES

Exhibit B:
Planned Action EIS Mitigation Measures
City of Kent Midway Planned Action Area
Introduction and Purpose .......................................................................................................................................................2

SEPA Terms ...................................................................................................................................................................................2
General Interpretation ..............................................................................................................................................................3
Location ...........................................................................................................................................................................................3
Planned Action Description and Phasing ..........................................................................................................................3
Alternatives ...........................................................................................................................................................................3
Planned Action Defined ....................................................................................................................................................8
Mitigation .......................................................................................................................................................................................9
Applicable Regulations and Commitments ................................................................................................................... 10
Natural Environment ..................................................................................................................................................... 10
Air Quality ........................................................................................................................................................................... 11
Land Use Patterns, Plans and Policies..................................................................................................................... 11
Aesthetics ............................................................................................................................................................................ 11
Transportation .................................................................................................................................................................. 11
Public Services and Utilities ........................................................................................................................................ 12
Noise ...................................................................................................................................................................................... 13
Public Agency Actions ............................................................................................................................................................ 13
Environmental Impacts and Mitigation Measures ..................................................................................................... 21
Natural Environment ..................................................................................................................................................... 22
Air Quality ........................................................................................................................................................................... 24
Land Use Patterns, Plans and Policies..................................................................................................................... 29
Aesthetics ............................................................................................................................................................................ 34
Transportation .................................................................................................................................................................. 39
Public Services and Utilities ........................................................................................................................................ 44
Noise ...................................................................................................................................................................................... 52
Attachment: Sewer Availability Certificate ................................................................................................................... 55
Exhibit B September 2011

1
Introduction and Purpose
The State Environmental Policy Act (SEPA) requires environmental review for project and non-
project proposals that are likely to have adverse impacts upon the environment. In order to meet
SEPA requirements, the City of Kent issued the Draft Environmental Impact Statement (DEIS) for the
City of Kent Comprehensive Plan Review and Midway Subarea Planned Action on October 22, 2010
and the Final Environmental Impact Statement (FEIS) for the City of Kent Comprehensive Plan Review
and Midway Subarea Planned Action on September 1, 2011. The Draft together with the Final
Environmental Impact Statement is referenced herein as the EIS. The EIS has identified significant
impacts that are anticipated to occur with the future development of the Planned Action area,
together with a number of possible measures to mitigate those significant impacts.
The purpose of this Mitigation Document is to establish specific mitigation measures, based upon
significant impacts identified in the EIS. The mitigation measures shall apply to future development
proposals which are consistent with the Planned Action scenarios reviewed in the EIS, and which
are located within the Midway Planned Action Area (see Exhibit A).
[Note: This Exhibit is based on the Midway Planned Action Area as defined in the EIS to be the
northern Transit Oriented Community. However, the EIS studied the entire Midway Subarea at a
level of detail such that the larger boundary could be defined as a Planned Action Area. Thus, the
original DEIS Planned Action Area boundaries may be contracted or enlarged prior to the Planned
Action Ordinance finalization. Where the Exhibit impact analysis discussion would change with the
larger subarea boundaries instead of just focusing on the DEIS Planned Action Area (i.e. the
northern Transit Oriented Community) this is noted in shaded text.]
SEPA Terms
As used in this document, the words action, planned action, or proposal are defined as described
below.
Action means projects or programs financed, licensed, regulated, conducted or approved by a

governmental Agency. Project actions involve decisions on a specific project such as a
construction or management activity for a defined geographic area. Non-project actions
involve decisions about policies, plans or programs. (see WAC 197-11-704)
Planned Action refers to types of project actions that are designated by ordinance for a specific
geographic area and addressed in an EIS, in conjunction with a comprehensive plan or subarea
plan, a fully contained community, a master planned resort, a master planned development or
phased project. (see WAC 197-11-164)
Proposal means a proposed action that may be an action and regulatory decision of an agency,
or any action proposed by applicants. (see WAC 197-11-784) Where specifically referenced as
the Proposal this refers to a DEIS Alternative.

2
General Interpretation
Where a mitigation measure includes the words shall or will, inclusion of that measure in project
plans is mandatory in order to qualify a project as a Planned Action. Where should or would
appear, the mitigation measure may be considered by the project applicant as a source of additional
mitigation, as feasible or necessary, to ensure that a project qualifies as a Planned Action.
Unless stated specifically otherwise, the mitigation measures that require preparation of plans,
conduct of studies, construction of improvements, conduct of maintenance activities, etc., are the
responsibility of the applicant or designee to fund or perform.
Location
The Midway Subarea is defined as an area located on the western edge of the City limits, generally
centered on SR 99 between S 272nd Street on the south and the Kent-Des Moines Road (SR 516) on
the north. The western limit of the Midway Subarea is the City limits, and the eastern edge extends
east of Military Road to the edge of the ridge to include the Kent Highlands and south of SR 516 to
include a cluster of commercially zoned properties. As shown in Exhibit A, the Planned Action Area
consists of the northern portion of Midway Subarea, including the portion of the subarea generally
north of S 246th Street. [As shown in Exhibit A, the Planned Action Area consists of the entire
Midway Subarea.]
Planned Action Description and Phasing

The Planned Action would amend the Citys Comprehensive Plan and development regulations
through the adoption of the Midway Subarea Plan, associated development regulations and design
guidelines, and corresponding Planned Action Ordinance.
The Planned Action includes a number of policies that are described in the EIS. These policies are
intended to address and reduce environmental impacts by providing for compact growth, improved
infrastructure including roads and drainage systems, reduced vehicle travel, urban design features,
street and landscaping amenities, and other features. These mitigating features are identified in the
proposal documents including the EIS and were considered in determining whether additional
mitigation measures were required.
The EIS is a document designed to help City decision-makers make a decision about a proposal or
alternatives. An EIS need not analyze the specific components of the final adopted action as long as
the likely impacts of the final adopted action fall within the range of the impacts assessed in the EIS.
Alternatives
The EIS studied the following alternatives:
The Proposal
3
No Action
Each is described below with a summary of what alternative features are part of the Planned Action.
The Proposal. The Proposal would amend Comprehensive Plan and zoning designations in the
Midway Subarea to implement the mission statement and goals for this portion of the City as
developed through the Envision Midway subarea planning process. The Proposal would also adopt a
planned action ordinance for a portion of the subarea called, for purposes of this EIS, the Midway
Planned Action Area (i.e. the northern Transit Oriented Community)[or, the entire Midway Subarea].
Amendments proposed for the Midway Subarea include adopting the Midway Subarea Plan as a
subarea appendix to the Comprehensive Plan, adopting one or more Comprehensive Plan Land Use
Plan Map amendments to implement the goals and policies of the Midway Subarea Plan; amending
the Zoning Districts map to be consistent with proposed amendments to the Comprehensive Plan
Land Use Plan map; and adopting zoning and development regulations, including design guidelines,
to implement the goals and policies of the Midway Subarea Plan over time.
Specific amendments to comprehensive plan, land use plan map designations, zoning, and
development regulations may include, but are not limited to:
Amendments to Capital Facilities and Transportation elements of the Comprehensive Plan to

include necessary capital improvements and a multi-year financing plan based on a minimum of
10-year transportation needs identified in the Comprehensive Plan, including improvements to
support growth in the Midway Subarea;
Changes to land uses permitted in the Transit Oriented Community (TOC) designation to allow
and encourage high density retail, office, and residential types of development while
discouraging or prohibiting stand alone big-box, drive-through, and other auto-oriented uses;
Changes to building heights, requiring a minimum of two stories. Additional height above 65 feet
is allowed through an incentive program to a maximum of 200 feet.
Development of transition regulations for areas adjoining single-family neighborhoods located

outside the northern Transit Oriented Community to address the high-intensity development
anticipated to occur within the northern Transit Oriented Community; 1
with its Land Use and Planning Board during development of the Draft EISs Proposal, they were not used in
preparation of the Proposal considered in the Draft EIS. The Draft EIS Proposals description of transition
regulations was based upon review of Draft Midway Subarea Plan goals and policies and the Draft Midway Design
Guidelines.

4
Requirement that pedestrian or vehicular throughways be developed at spaced intervals to
encourage multi-modal transportation and to connect development with public parks, trails,
streets, or other public amenities;
Establishment of design guidelines that promote a pedestrian-friendly, transit-supportive, and

unique identity of the TOC;
Promotion of environmentally sustainable building design and landscaping practices that,

among other things, take into account solar access, water and energy conservation, and
emphasize natural drainage systems;
Establishment of maximum parking requirements and other revisions to parking standards

designed to encourage use of alternative modes of transportation; and
Regulation of parking location and design to minimize the effect of parking on the pedestrian
environment.
The amendments accompanying the Midway Subarea Plan are expected to allow the City to
accommodate 11,821 households and 9,481 jobs in the Midway Subarea in 2031 compared to 2,179
households and 3,721 jobs that would be anticipated under the No Action Alternative.
No Action. Under the No Action Alternative, the City would not adopt amendments to the
Comprehensive Plan, Land Use Plan map, Zoning Districts map, zoning and development
regulations, design guidelines, or a planned action ordinance to implement the vision for this part of
the City developed as part of the Envision Midway subarea planning process.
Population and employment growth under the No Action Alternative would be limited to that which
is allowed under the current Comprehensive Plan. Growth in households and jobs would be
assumed to continue as allowed under existing Comprehensive Plan policies and zoning regulations
to the horizon year of 2031. The No Action Alternative assumes an increase of 262 households and
1,538 jobs would be accommodated in the Midway Subarea by 2031 compared to the base year. This
is 9,642 fewer households and 5,760 fewer jobs than anticipated under the Proposal. The smaller
Midway Planned Action Area (northern Transit Oriented Community) would accommodate an
increase of 129 households and 1,103 jobs in 2031 under the No Action Alternative. This is
8,024 fewer households and 5,534 fewer jobs than anticipated under the Proposal. A planned action
ordinance to facilitate development in the area proximate to the planned light rail station in the
vicinity of Highline Community College and Kent Highlands redevelopment area conforming to the
vision of the Midway Subarea Plan would not be adopted under the No Action Alternative.
The FEIS Review Alternative for the Midway Subarea assumes a phased approach to the same level
of future growth within the Midway Subarea as the Proposal. It also provides more specific zoning,

5
development regulations and design guidelines to implement the land use concept of the subarea
plan. 2
Phasing of growth is assumed due to the economic downturn and Sound Transits delay in providing
planned light rail service to the Midway Subarea. Under the FEIS Review Alternative, a low level of
growth is assumed to continue for the first ten years of the planning period comparable to what is
assumed for the No Action Alternative followed by a higher level of growth in the second ten years,
comparable to the growth assumed under the Draft EIS Proposal. Because growth is assumed to be
phased over time, the City of Kent plans to phase in its implementation of Comprehensive Plan
amendments necessary to support the higher level of growth in the subsequent ten-year period as
well.
Regarding building height, the FEIS Review Alternative still includes maximum height limits within
the Transit Oriented Community of up to 200 feet, as described in the DEIS, and also similar to the
Proposal, the FEIS Review Alternative addresses proximity of more intensive Transit Oriented
Community areas to lower intensity residential districts. The FEIS Review Alternative includes a
finer level of detail with respect to implementing regulations than the Proposal, including a
proposed new zoning designation (Midway Transit Community 1, or MTC-1); centered on SR 99
north of approximately S 245th Street and south of S 268th Street, that has a maximum building
height of 5 stories or 55 feet. The MTC-1 zone, which abuts SR 99 in the Transit Oriented
Community, as well as several areas of low intensity residential development in the City of Des
Moines, assumes the following height transitions to existing residential districts abutting the Transit
Oriented Community areas: a maximum building height of 35 feet within 20 feet of existing
residential districts and a maximum height of 45 feet within 40 feet of a residential district. The
combination of the lower maximum height in the MTC-1 zone, and the implementation of lower
transition heights when adjacent to existing residential districts, helps mitigate the effects of taller
buildings in this area. Given the presence of the I-5 freeway and topography, height transitions are
not implemented in the other Midway zones (MTC-2 and MCR) with heights up to 16 stories or 200
feet located east of the MTC-1 zone. In these zones with taller maximum heights, the
implementation of proposed Midway Design Guidelines relating to height, bulk, and scale would
help provide transitions between taller buildings, public uses and less intensive zone edges. Height,
bulk and scale design guidelines include, among others, those calling for increased building setbacks
from a less intensive zone edge, and stepping back upper stories of buildings from the original
footprint starting at the third story and once again at seven stories.
The FEIS Review Alternative differs from the Proposal for the Midway Subarea in the following
ways:
with its Land Use and Planning Board during development of the Draft EISs Proposal, they were not used in
preparation of the Proposal considered in the Draft EIS. The Draft EIS Proposal relied upon the Draft Midway
Subarea Plan and Draft Midway Design Guidelines. However, the FEIS Review Alternative is based upon the Citys
recommended options for zoning map and development regulations, in addition to updated drafts of the Midway
Subarea Plan and Midway Design Guidelines that were included in the November 22, 2010 Land Use and Planning
Board public hearing packet.

6
Refines the Draft Midway Subarea Plan reflecting public input and adds a figure (Figure 6 in the
draft Midway Subarea Plan) which identifies Midway Subarea Land Use Plan Map designations.
Changes to the Land Use Plan Map compared to the Proposal include adding a small portion of
area near the Midway Highlands west of Military Road into a Transit Oriented Community
designation.
Changes to policy language and implementing measures that provide more flexibility in the land
uses allowed to provide a transition from existing auto-oriented land uses located throughout
the Midway Subarea to a dense pedestrian-friendly form, particularly in the Transit Oriented
Community areas. For example, the FEIS Review Alternative allows new single-story
construction, rather than requiring buildings to be a minimum of two stories in height.
Amends Midway Subarea Plan transportation policy language to assume phased growth and
identifies street improvements needed for the latter half of the planning period, identifies a city-
wide transportation analysis and funding structure, and incorporates them into the Citys 2014
Comprehensive Plan update (see Policy MT-4.4). Until such a time as these improvements are
added to the Citys Comprehensive Plan Transportation Element and the Citys Transportation
Master Plan, the No Action level of growth is assumed within the Midway Subarea.
Adds additional goal and policy language that addresses transportation analysis findings,
including adding parallel north-south transportation routes that serve as an alternative to SR 99,
accounting for transportation system management (TSM) techniques, as well as adding
language on coordinating with the City of Des Moines and WSDOT on a local connection at the I-
5/SR 509 interchange, as identified in the DEIS (new policy MT-1.4).
Divides the Midway Subarea into implementing zones. Zones would be mapped in a manner in
which a new Midway Subarea zone (Midway Transit Community 1, or MTC-1) with a lower
maximum height (five stories or 55 feet) is applied to an area adjacent to SR-99 in the north and
south ends of the subarea. When the MTC-1 zone is adjacent to residential zones, for example,
lower intensity residential districts located further to the west, as well as east of the southern
TOC and at two locations abutting the Mobile Home Park (MHP) residential district, further
height restrictions of 35 feet in height within 20 feet of a residential district, and 45 feet in
height within 40 feet of a residential district are applied. Other implementing zones (Midway
Transit Community 2, or MTC-2), and Midway Commercial/Residential, or MCR), with maximum
heights or 200 feet or 16 stories, would be located farther east in the northern Midway Transit
Oriented Community or TOC.
Does not include minimum building heights or maximum parking standards though parking
provisions are addressed through design guidelines.
Overall, the FEIS Review Alternative for the Midway Subarea Plan assumes the same level of growth
as the Proposal, but phases it, and refines the approach to building heights through the
implementing zones, particularly MTC-1.

7
Planned Action Defined
The Planned Action is based on the FEIS Review Alternative, and includes two phases of growth in
approximately 10 year increments shown in Table 1. The years represent approximations of when
growth could occur.
Table 1. Midway Planned Action Area Alternatives Comparison
Phase 2
Net
Phase 1 Net Growth:
Base Year Total Net Growth Growth: 2006- 2021-
Features (2006) 2006-2031 2020b 2031 b
Midway Subarea [Maximum Potential Planned Action Area studied in the EIS]
Households 1,917 9,904 262 9,642
Jobs 2,183 7,298 1,538 5,760
Trips a 2,222 9,833 1,241 8,592
Midway Planned Action Area [Northern Transit Oriented Community, only]
Households 296 8,153 129 8,024
Jobs 691 6,637 1,103 5,534
Trips a 1,163 7,950 1,103 6,847
aTrips refer to PM peak hour vehicle trips.
bThe two right columns divide up phases based on the portion of growth already accounted in
the Citys current Comprehensive Plan (No Action Alternative) versus the maximum studied
growth in the EIS for the Proposal and FEIS Review Alternative, Phase 1 Net Growth: 2006-
2020 numbers reflect the No Action Alternative and are consistent with the Transportation
Master Plan growth figures. Phase 2 Net Growth: 2021-2031 represents the balance of growth
beyond Phase 1 associated with the Proposal and FEIS Review Alternative.
Phase 1 approximates the amount of growth assumed in the Comprehensive Plan or Transportation
Master Plan (TMP). Phase 2 represents the potential growth capacity beyond the current
Comprehensive Plan or Transportation Master Plan (TMP), which can be accommodated by the new
horizon year of regional growth targets. However, growth will occur based on market conditions
and broader economic trends. Provided the environmental analysis results and the planned action
remain valid and necessary mitigation occurs, the planned action is not tied to the specific years
shown in the phases.
Planned action projects may exceed Phase 1 levels of growth if one or more of the following
circumstances occur:
While households or job thresholds are exceeded, the level of traffic trips assumed is not
exceeded due to transportation demand measures, and provided that the impacts of that
development on the natural and built environment have been identified in the Planned Action
EIS and are mitigated consistent with this Exhibit. The City shall require the planned action
applicant to prepare a transportation impact analysis to document the number of trips and
required improvements in comparison to the EIS and the Planned Action Ordinance.

8
The City has modified its Transportation Master Plan and made any necessary consistency edits
to its Comprehensive Plan to accommodate Phase 2 growth and associated capital and
transportation improvements consistent with the timeframe of the next complete update
required by the Growth Management Act (GMA). 3
An applicant voluntarily provides improvements that address and support the Phase 2 level of
growth, through a voluntary agreement or development agreement prepared consistent with
RCW 82.02.020. Cost recovery measures such as latecomers fees may be collected from later
development applicants. The agreements may address fee-in-lieu provisions as well.
If future development proposals in the Midway Planned Action Area exceed the development
thresholds specified for Phase 2 levels of growth, such development must satisfy the following
criteria:
Shifting the total assumed land use between categories of uses will be permitted so long as the
total assumed land use does not exceed the aggregate amount of development or trip generation
reviewed in the EIS, and so long as the natural and built environment impacts of that
development have been identified in the Planned Action EIS and are mitigated consistent with
this Exhibit. The City shall require the planned action applicant to prepare a transportation
impact analysis to document the trips and required improvements in comparison to the EIS and
the Planned Action Ordinance.
Mitigation
Based on the EIS, this document identifies significant adverse environmental impacts that are
anticipated to occur as a result of development of planned action projects. Mitigation measures
identified in the EIS are reiterated here for inclusion in proposed projects to mitigate related
impacts and to qualify as Planned Action projects.
Consistency review under the Planned Action, development plan review, and other permit approvals
will be required for specific development actions under the Proposed Action pursuant to WAC 197-
11-172. Additional project conditions may be imposed on planned action projects based upon the
analysis of the proposal in relationship to independent requirements of the City, state or federal
requirements or review criteria.
Any applicant for a project within the Planned Action Area may propose alternative mitigation
measures, if appropriate or as a result of changed circumstances, in order to allow equivalent
substitute mitigation for identified impacts. Such modifications shall be evaluated by the Citys SEPA
Responsible Official prior to any project approvals by the City.
In combination, regulations applicable to each element of the environment and mitigation measures
identified in the EIS and documented in this Mitigation Document that are applied to any planned
3 A complete review cycle refers to the 7 or 10 year review cycles in the Growth Management Act, whichever
comes first. The next complete review requirement is scheduled by December 1, 2014 for King County and its
cities. As the law is subject to amendment the City should verify the Acts requirements on a regular basis.

9
action proposal will adequately mitigate all significant environmental impacts associated with
planned action proposals, except for those impacts that are identified as significant unavoidable
adverse impacts.
Mitigation measures are identified in the following sections: Applicable Regulations and
Commitments, and Environmental Impacts and Mitigation Measures.
Applicable Regulations and Commitments

The EIS identifies specific regulations and commitments that act as mitigation measures. These are
summarized below by EIS topic. All applicable federal, state, and local regulations shall apply to
Planned Actions, including the regulations that are adopted with the Proposal or FEIS Review
Alternative or equivalent action. Planned Action applicants shall comply with all adopted
regulations where applicable including those listed in the EIS and those not included in the EIS.
Natural Environment
Critical Areas Ordinance (CAO) and Surface Water and Drainage Code: The Kent Critical
Areas Ordinance (KCC 11.06) addressing wetlands, streams, wildlife and fisheries habitat,
geologic hazard areas, frequently flooded areas, and aquifer recharge areas, and Surface Water
and Drainage Code (KCC 7.07) would apply to development and redevelopment in the Midway
Subarea. The standards of the Citys Surface Water Design Manual have been adjusted to meet
equivalency requirements of the Washington State Department of Ecologys Stormwater
Management Manual for Western Washington (2005).
Environmental covenants associated with environmental cleanup of the Midway and Kent
Highlands landfills would restrict development in these areas. Only actions that do not interfere
with continued cleanup and containment of contamination at these sites would be allowed.
Remediation of potential environmental health hazards at the Kent Highlands and Midway
landfill sites located in the Midway Subarea are controlled by consent agreements between
Seattle Public Utilities and EPA and the Department of Ecology. The cleanup and monitoring of
the sites is managed by the Department of Ecology under the authority of the Model Toxics
Control Act [Chapter 70.105D RCW], the Water Pollution Control Act [Chapter 90.48 RCW], and
all other applicable state and federal laws. Land use on both former landfill sites is controlled by
restrictive covenant or deed restrictions that have been placed on both properties and run in
perpetuity with the land. Future use of both landfill sites will be consistent with the restrictive
covenants or deed restrictions and a Reuse Planning Report prepared for the City of Seattle by
E2 Inc. (February 2007).
Hazardous Substances Performance Standards: The City of Kent specifically regulates

hazardous substances or waste through performance standards contained in KCC 15.08.050.
Future site-specific activities will comply with City Fire, Building, Utility and Zoning Codes, as
well as State and Federal hazardous materials regulations.

10
Air Quality
Air Quality Permitting for Proposed New Commercial Facilities: All stationary emissions
sources associated with new commercial facilities will be required to register with Puget Sound
Clean Air Agency (PSCAA) (Regulation I and Regulation II).
Project-Level Transportation Conformity Analyses for Future Roadway and Intersection

Improvements: As part of future project-specific NEPA documentation for individual new
roadway improvement projects, the City will be required to conduct CO hot-spot modeling (as
required under WAC 173-420) for state-funded or federally-funded projects to demonstrate that
the projects would not cause localized impacts related to increased CO emissions from vehicle
tailpipes at congested intersections.
Land Use Patterns, Plans and Policies

Title 15 KCC: The Citys Zoning Code, Title 15, contains provisions to mitigate for development
impacts by addressing setbacks, site coverage, impervious surface coverage, and landscaping.
Title 11 KCC: The Citys Environmental Management Code, Title 11, contains provisions to
mitigate development impacts by addressing critical areas protection.
With adoption of the Midway Subarea Plan, the Citys existing zoning regulations would be
amended to include new zoning and development regulations applicable to the Midway Subarea.
Midway Design Guidelines establish a flexible framework of design options to create interesting
and high quality multi-family and commercial development within the Midway Subarea TOC
area.
Department of Commerce Review: As required by the GMA, the City will submit
Comprehensive Plan and development code updates for review and comment by the state prior
to final adoption.
Aesthetics
With adoption of the Midway Subarea Plan, the Citys existing zoning regulations would be
amended as part of implementation to include regulations implementing design related goals
and policies contained within the subarea plan and Midway Design Guidelines would be
adopted for the TOC area.
Transportation
Commute Trip Reduction (CTR) Program: Through Chapter 6.12 KCC, Kent requires
employers of a certain size to encourage employees to reduce vehicle miles of travel and single-
occupant vehicle commute trips. This program currently serves 35 worksites within the City.
The City manages its CTR proactively by providing public outreach to the entire business
community, not just the businesses required by law to participate in the CTR program.

11
Public Infrastructure Improvements: Chapter 6.02 KCC requires developers to install public
infrastructure improvements as conditions of permit. Infrastructure improvements include, but
are not limited to rights-of-way and paved streets, street lighting systems; curbs, gutters,
sidewalks, and landscaping; storm drainage systems; sanitary sewer systems; domestic water
and fire systems; traffic control systems; and conduit for fiber optic systems. The City has
adopted the 2009 City of Kent Design and Construction Standards (construction standards)
and all codes, standards, and provisions cited therein in Section 1.6.
Concurrency Management: Chapter 12.11 KCC sets forth specific standards providing for city
compliance with the concurrency requirements of the State GMA and for consistency between
city and countywide planning policies under the GMA. This chapter establishes a transportation
concurrency management system (TCMS) to ensure that the necessary facilities or programs
needed to maintain a minimum level of service can be provided simultaneous to, or within a
reasonable time of new development as required in the GMA.
The City of Kent Transportation Master Plan includes capital improvement projects designed
to help the City maintain transportation concurrency.
Transportation Impact Fees: Chapter 12.14 KCC requires development to pay its fair share for
capital improvement projects in the Citys Transportation Master Plan and provides guidance
for how impact fees are to be assessed.
Public Services and Utilities

Fire and Emergency Medical Services:
KCC Title 13 contains the Citys fire code and enforcement provisions.
Kent Fire Department Regional Fire Authority (RFA) establishes fire and emergency medical
services mitigation policy. Because of the intensity of development proposed by the Midway
Subarea Plan, a blanket mitigation approach capable of defining and mitigating all of the
direct impacts to public safety related approval in the Kent Midway Planned Action Area is
not possible. Upon adoption of the Plan, the RFA will begin the process of amending its
Concurrency Management Plan, capital facilities plan and Mitigation and Level of Service
Contribution policy to appropriately analyze and mitigate the direct impacts produced by
specific developments within the Midway Planned Action Area. The Mitigation and Level of
Service Contribution policy establishes a flexible framework of mitigation options that fairly
credit developers with existing capacity and offset adverse impacts to LOS. All future
development of the Kent Midway Planned Action Area will need to comply with the RFA
Mitigation & Level of Service Contribution policy to provide adequate funding and
mitigation necessary to maintain LOS.
Parks, Recreation, and Community Services: The Citys subdivision regulations include a
requirement that new single-family residential development either provide on-site recreational
space in a new subdivision, or provide a fee in lieu of providing this recreational space which

12
goes into a fund to provide for parks and recreation areas (KCC 12.04.060 and 12.04.065).
However, there are no existing requirements for multifamily or mixed-use development.
Schools: The City assesses school impact fees to help school districts pay for a developments
proportionate share of school district facilities serving the development. The City collects impact
fees for the Kent and Federal Way school districts serving portions of the Midway Planned
Action Area (KCC 12.13).
Stormwater: The City of Kents Storm and Surface Water Utility Code (KCC 7.05) applies to all
new development and redevelopment occurring within the City limits. The Citys existing 2002
Surface Water Design Manual is a modified version of the 1998 King County Surface Water
Design Manual. The City Stormwater Utility has adjusted the standards in the 2002 Surface
Water Design Manual to meet equivalency requirements of the Washington State Department of
Solid Waste: The City has a new contract for garbage, recycling and yard/food waste collection
effective April 1, 2011, which allows for more items to be recycled and also provides a yard &
food waste cart for all customers. In terms of long-range planning, the 2006 King County Solid
Waste Transfer and Waste Management Plan (King County Solid Waste Division 2007) is being
updated with the latest draft dated October 2009. Except for the cities of Seattle and Milton, all
of King County is covered by this plan and its update. The 2006 King County Solid Waste
Transfer and Waste Management Plan (King County Solid Waste Division 2007) includes
measures to help facilitate and increase the amount of recyclable materials being diverted from
the waste stream. These measures should reduce the amount of waste going to landfills via
transfer stations and residential/commercial collection. .
Noise
City Noise Regulations: Certain noise-control measures would be required to comply with
current City regulations (Chapter 8.05 KCC). These required measures would be the use of low-
noise mechanical equipment at office and retail facilities adequate to comply with the City noise
ordinance limits. If nighttime construction is requested by developers, then a noise control
study would need to be submitted for City approval, demonstrating compliance with the Citys
nighttime noise ordinance limits.
Washington State Department of Transportation Noise Criteria: Any roadway

improvements in the Kent Planning Area that use state or federal funding would be required to
prepare a traffic noise analysis to identify noise impacts at noise sensitive receivers and to
assess whether state or federal funds could be used to abate identified impacts.
Public Agency Actions

Under some elements of the environment, specific City or other agency actions are identified.
Generally, incorporation of these actions is intended to provide for consistency within the
Comprehensive Plan or between the Plan and implementing regulations; to document pending City
13
actions, such as adoption of new stormwater standards; to establish a protocol for long term
measures to provide for coordination with other agencies; or to identify optional actions that the
City may take to reduce impacts. These actions are listed below in Table 2, organized by the
pertinent EIS element of the environment in which they are discussed. Actions identified as
Proposed Synchronous Amendments reference legislative actions proposed for adoption together
with the Midway Subarea Plan and Regulations. Actions identified as short term are currently
underway or expected to be completed in 2011 or in time for the next major Comprehensive Plan
review. Longer term and other agency actions will occur in the future, depending on need. The
projected timeframe and responsible departments are identified and will be used in monitoring the
implementation of the Planned Action Ordinance.

14
Table 2. Public Agency Mitigation Measures
Short Term: Estimated Year

Next Comp of
Proposed Plan Implementation
Synchronous Amendment Long Other and Responsible
Mitigation Measures Amendments Cycle Term Agency Department
Land Use Patterns/Plans and Policies
The City will adopt 2011
Comprehensive Plan Land Economic and
Use Plan map amendments Community
within the Midway Planned Development
Action Area in support of the Department
future land use framework
outlined in the Midway
Subarea Plan.
The City will amend the 2011
Zoning Districts map that Economic and
implements a future land use Community
framework outlined in the Development
Midway Subarea Plan and is Department
consistent with amendments
to the Comprehensive Plan
Land Use Plan map noted
above.
The City will adopt Midway 2011
Design Guidelines in support Economic and
of aesthetic goals and policies Community
of the Comprehensive Plans Development
Community Design Element Department
and the Midway Subarea
Plans Urban Design goals and
policies.
Prior to exceeding Phase 1 By date of next
growth levels, amend the City complete
of Kent Capital Facilities and Comprehensive
Transportation Elements of Plan review
the Comprehensive Plan to consistent with
include necessary capital GMA
improvements and a Economic and
multi-year financing plan Community
based on a minimum of 10- Development
year transportation needs Department in
identified in the consultation with
Comprehensive Plan, the Public Works
including those supporting Department
growth in the Midway
Subarea.
Aesthetics

15
Next Comp of
The City will identify By date of next
established view corridors complete
from public areas within the Comprehensive
Midway Planned Action Area, Plan review
which may include but are consistent with
not limited to the intersection GMA
of SR 99 and S 240th Street Economic and
looking southeast (Mount Community
Rainier), to provide a Development
framework for preservation Department
of important views to Mount
Rainier, the Cascades, and
Puget Sound. Until such time
as the City identifies the view
corridors, the Midway Design
Guidelines include provisions
addressing views and this
Exhibit includes a mitigation
measure.
Police: To ensure that Short Term: By

services are provided to the date of next
level needed with future complete
growth, the City should Comprehensive
monitor growth and demand Plan review
through regular consistent with
Comprehensive Plan reviews, GMA
capital facility plan Long Term:
preparation, and budget Subsequent
process. Revenues from Annual Docket
increased employment Reviews
activity and increased Economic and
property values could help Community
offset some of the additional Development
expenditures for providing Department and
additional officers and Police Department
responses to incidents.
Police: The City should Same as above.
monitor response time LOS in
the Planned Action Area over
time and respond to any
decreases in LOS standard
through adding or adjusting
police facilities and staffing to
serve the growing population.

16
Next Comp of
Fire: The Kent Fire Regular planning
Department Regional Fire and budgeting
Authority (RFA) should process
monitor growth and demand RFA
for its services in the Planned
Action Area over time
through its regular planning
and budgeting processes and
the RFAs Mitigation and
Level of Service Contribution
policy and add fire facilities
and personnel as needed to
maintain established LOS
standards in the area.
Revenues from increased
property values could help
offset some of the additional
expenditures for providing
additional responses to
incidents.
Fire: The RFA should utilize Regular permit
its Concurrency Management application review
Plan to help assess and routing to RFA:
mitigate the impacts of new Economic and
development on fire facilities. Community
Development
Department
Permit Review
and Concurrency
Management: RFA

17
Next Comp of
Parks: The City should Short Term: By
provide adequate park land date of next
and recreation space within complete
and accessible to the Midway Comprehensive
Planned Action Area to meet Plan review
City established LOS consistent with
standards for population GMA
growth anticipated within the Long Term:
Planned Action Area. The Subsequent
City will define an Annual Docket
appropriate LOS through its Reviews
parks, recreation, and open Economic and
space plans, which may be Community
qualitative or quantitative or Development
a combination. Until such Department and
time as the City amends its Parks and
parks, recreation, and open Community
space plans, as well as its Services
Comprehensive Plan, the Department
mitigation measures in this
Exhibit apply to planned
actions.
Parks: The City should Same as above.
continue to monitor
population growth in the
Planned Action Area over
time and update its Parks and
Open Space Plan to respond
to opportunities within and
accessible to the Midway
Planned Action Area.
Parks: The City could Same as above.
coordinate with neighboring
jurisdictions, school districts,
and other entities to share
parks and recreation facilities
through joint use agreements,
and consider options for use
of other City park facilities as
a means of expanding
recreational access.

18
Next Comp of
Parks: The City should Short Term: By
conduct a feasibility analysis date of next
to determine whether the complete
landfill areas have Comprehensive
recreational value beyond Plan review
mere open space. consistent with
GMA.
Schools: The Highline, Federal Regular permit
Way, and Kent School application review
Districts should monitor routing to School
growth over the planning Districts:
period and adjust capital Economic and
facility plans relating to the Community
increased population Development
anticipated in the Planned Department
Action Area accordingly. Capital Facility
Districts can expand existing Plan Adjustments:
facilities, build new facilities, Every 6 years or
or adjust attendance sooner in
boundaries to account for association with
shifts in student population. adoption of the
In addition, school districts City budget or
can use relocatable classroom CIP: Economic and
facilities on a short-term Community
basis to address near-term Development
shifts in student population. Department in
coordination with
School Districts
Schools: The City of Kent Regular permit
collects a school impact fee application
for the Federal Way and Kent review: Economic
School Districts which serve and Community
portions of the Midway Development
Planned Action Area. These Department
school districts may use
proceeds from these impact
fees to address school facility
needs arising from increases
in population anticipated
within the Planned Action
Area.

19
Next Comp of
Schools: The Highline School Regular permit
District may consider application review
preparing an interlocal routing to School
agreement with the City to Districts:
collect school impact fees for Economic and
growth anticipated in the Community
Midway Planned Action Area, Development
similar to what is being done Department
for the Kent and Federal Way Impact Fee
School Districts. Ordinance:
Economic and
Community
Development
Department in
coordination with
Highline School
District
Sewer: The Midway Sewer Regular permit
District should monitor future application review
wastewater flows and routing to Midway
available capacity for the Sewer District:
need for a 400-foot section of Public Works
18-inch sewer pipe on 20th Department
Avenue S between S 244th Capital Facility
Street and S 244th Place. If Plan Adjustments:
increased flows are as Economic and
modeled, the district would Community
need to program Development
improvements to this section Department in
of pipe to accommodate coordination with
larger future flows. Midway Sewer
District
Sewer: The Midway Sewer Same as above.
District should monitor
capacity at its wastewater
treatment plant and consider
upgrades to this facility based
upon future wastewater flows
arising from the Planned
Action Area and the nearby
Pacific Ridge development
located north of the Midway
Subarea

20
Next Comp of
Sewer: Prior to exceeding Ongoing: Regular
Phase 1 growth levels, the permit application
City should monitor amount review: Public
and location of future Works
development within its Department
portion of the Midway Short Term:
Planned Action Area and Amend City plans
ensure additional sewer as needed by date
infrastructure is provided as of next complete
needed to meet the Comprehensive
wastewater needs of the new Plan review
development. Such consistent with
improvements may include GMA
the following identified in the Long Term:
EIS: Subsequent
Increase sewer pipe sizes in S Annual Docket
231st Way and Riverview Reviews
Boulevard, flowing north and Capital Facility
east, and Plan Adjustments:
Increase sewer pipe size in Economic and
Kent-Des Moines Road and Community
Reith Road flowing south and Development
east. Department in
Increase pump station coordination with
capacity either at the existing Public Works
location west of the Green Department
River at about 221st or at
another existing pump station
at 212th Street to
accommodate additional
flows.
In addition, an undercrossing
of Kent-Des Moines Road for
sewer flows traveling south
from the Kent Highlands
would need to be constructed
to tie into the existing Kent
Des Moines Road sewer pipes
on the south side of the road.
Environmental Impacts and Mitigation Measures

Chapter 3 of the Draft EIS, as amended in the Final EIS, identifies significant impacts, unavoidable
adverse impacts and mitigation measures for potential impacts associated with the natural

21
environment, air quality, land use, aesthetics, transportation, public services and utilities, and noise
within the Planned Action Area. The following summarizes the information found in the EIS,
including a summary of (1) significant environmental impacts; (2) significant unavoidable adverse
impacts; and (3) mitigation measures identified in the EIS. Please refer to the Draft and Final EIS for
complete text associated with each element of the environment. 4
Natural Environment
Significant Impacts
Under the Proposal and FEIS Review Alternative, there would be extensive redevelopment in the
Midway Planned Action Area [Midway Subarea] as a result of changes arising from adoption of the
Midway Subarea Plan that would create a dense, pedestrian-friendly, sustainable community that
provides jobs, housing, and services around nodes of high capacity mass transit.
Conversion of existing underdeveloped land would be greatest on the two former landfill areas
under the Proposal/FEIS Review Alternative, since most other portions of the Midway Planned
Action Area [Midway Subarea] are already developed. Some grassy areas of the former Kent
Highlands landfill could be converted to mixed-use developments, but with essentially no loss in
habitat function since this area provides little ecological function and the sites are highly altered.
Furthermore, as described in the reuse plans developed for these sites and in compliance with
development codes and conditions of restrictive covenants placed on these properties, it is likely
that large portions of both former landfill sites would remain as passive open space under both
alternatives.
Additionally, while some vacant lands would see new impervious surfaces, development in the
Planned Action Area [Midway Subarea] would likely have minimal impacts on the limited natural
resources within the Planned Action Area [Midway Subarea]; with the implementation of the Citys
stormwater standards, water quality would be protected with development of vacant sites and
water quality would improve on redevelopable properties since these were originally developed
without such standards. Focus of new development in the largely built-out Planned Action Area
[Midway Subarea] avoids impacts on most categories of environmentally sensitive areas, and in the
locations where there are environmentally sensitive features, critical area regulations would apply.
Land use conversions in the Planned Action Area [Midway Subarea] would not result in significant
loss of habitat function.
Since the Midway Planned Action Area [Midway Subarea] is largely built out with buildings, surface
parking, and other impervious surfaces dominating the environment, it is likely that even with
increases in site coverage standards under the Proposal or FEIS Review Alternative 5, redevelopment
4 Theimpacts and mitigation measures are specific to the Planned Action Area as studied in the EIS. If the City
proposes different planned action boundaries, the analysis may need to be adjusted.
5 Phase 1 growth is anticipated to be a smaller amount but similar style of development as Phase 2 growth.

22
of the subarea would replace one type of impervious surface with another (i.e., smaller building
footprint with surface parking replaced by larger building footprint with much of the parking
contained within a structure), resulting in little or no additional impervious surfaces, stormwater
volume, or runoff. Some excavation for construction would occur, but would not result in a
significant loss of vegetation or soil productivity.
[The Midway Subarea contains some wetland areas, which are assumed to remain undeveloped
under studied alternatives. This appears to be a valid assumption in consideration of the significant
mitigation requirements for impacts on wetlands.]
Following are potential impacts by topic.
Earth
Earth-disturbing construction could accelerate erosion, particularly in steep areas.
Converting open space land uses to developed land uses could result in lost soil productivity
through topsoil removal, coverage by impervious surfaces, contamination, and compaction.
Limited instances in which building in landslide hazard areas occurs would be at risk of loss or
damage because of earth movement.
Water
Impervious surfaces intercept precipitation and alter the timing and volume of discharge to
groundwater and surface water.
Impervious surfaces are generally pollutant sources. Thus, roads would receive pollutants from
vehicles, and all impervious surfaces would receive airborne pollutants.
Earth-disturbing construction could increase erosion and result in sediment discharge to

stormwater systems or surface waters.
Impervious surfaces could interrupt the recharging of groundwater by diverting natural flow
patterns.
Residential development is a potential source of stormwater and groundwater pollution through

pet waste, and use of yard care products including fertilizers and toxic biocides. High density
development could result in less pollutant loading from lawn care products, and more from pet
waste.
Plants and Animals

New development that converts open space to residential and commercial uses would generally
result in a loss of habitat or habitat quality.
Changes in surface water pollutant loading and flow regime could adversely affect fish and other
aquatic organisms, either directly or through habitat alteration.
23
Redevelopment could affect the natural environment through the same mechanisms as new
development. However, the potential for these impacts is less, since previously developed areas may
not require new excavations and generally have lower productivity soil, higher impervious surface
area, and reduced habitat compared to undeveloped land.
Unavoidable Adverse Impacts

Because of the Midway Planned Action Area [Midway Subarea]s highly developed condition, the
location and intensity of development projected, and applicable regulations, no significant
unavoidable adverse impacts on earth, water, and plants and animals would occur under studied
alternatives.
Mitigation Measures
In addition to Applicable Regulations and Commitments and Public Agency Actions, the following
mitigation measure shall be applied to planned actions:
Low Impact Development (LID)

The City will require that Planned Action applicants identify any LID techniques described in
currently available manuals (Washington State Department of Ecology 2005 6, Puget Sound Action
Team and Washington State University Pierce County Extension 2005 7 or equivalent manuals)
proposed for incorporation into the planned action and demonstrate why unincorporated LID
techniques are not feasible. Flow reduction credits provided in the Ecology stormwater manual for
use in LID facilities will translate into smaller stormwater treatment and flow control facilities over
those which use conventional methods. In certain cases, use of various LID techniques can result in
elimination of stormwater mitigation facilities entirely. As part of required land use, building, or
construction permits, the City shall, as appropriate, condition planned actions to incorporate
feasible and site-appropriate LID techniques.
Air Quality
Significant Impacts
Development within the Midway Planned Action Area [Midway Subarea] would result in a greater
increase in localized air pollutant emissions from construction activities and commercial activities
6 Washington State Department of Ecology. 2005. Stormwater Management Manual for Western Washington. April.
Available: < http://www.ecy.wa.gov/programs/wq/stormwater/manual.html>. Accessed: March 12, 2011.
Olympia, WA.
7 Puget Sound Action Team and Washington State University Pierce County Extension. 2005. Low Impact
Development Technical Guidance Manual for Puget Sound. January. Available:
<http://www.psparchives.com/publications/our_work/stormwater/lid/lid_tech_manual05/LID_manual2005.pdf>
. Accessed: March 12, 2011.

24
and regional tailpipe emissions from vehicle travel. The air quality impacts for the Midway Planned
Action Area [Midway Subarea] would be as follows:
Construction Emissions
Construction emissions include dust from excavation and grading activities, diesel-powered engine
emissions from construction vehicles and equipment, odors detectable to people in the vicinity of
construction activities (such as paving operations), and increases in general traffic-related
emissions due to delays caused by construction equipment and material hauling activity.
Construction activity and equipment must comply with relevant Puget Sound Clean Air Agency
(PSCAA) regulations. However, despite compliance with such regulations, local construction-related
emissions could cause temporary, localized impacts on air quality.
Emissions from Commercial and Industrial Operations

Emissions from commercial and industrial operations could cause air pollution issues at adjacent
residential properties, unless properly controlled. However, all new commercial and industrial
facilities would be required to register pollutant-emitting equipment with PSCAA and comply with
PSCAA standards to minimize emission. Therefore, it is unlikely that new commercial and industrial
operations would cause significant air quality issues.
Emissions from Vehicle Travel

Potential air quality impacts caused by increased tailpipe emissions are divided into two general
categories: CO hot-spots caused by localized emissions at heavily congested intersections and
regional photochemical smog caused by combined emissions throughout the Puget Sound region.
With respect to localized hot-spot air quality, it is unlikely that increased vehicle travel on existing
public roads would cause significant localized air pollutant concentrations at local intersections,
forming a hot-spot. The Puget Sound Clean Air Agency (PSCAA) has not indicated any exceedances in
its district over the past several years, and EPAs ongoing motor vehicle regulations have provided
steady decreases in tailpipe emissions from vehicles, which possibly could more than offset the
increase in vehicle traffic.
In terms of regional impacts, although population and vehicle travel in the study area would
increase under all studied alternatives, the increase in tailpipe emissions would be very small
relative to the overall regional tailpipe emissions within the Puget Sound air basin. Based on the
Puget Sound Regional Councils (PSRCs) air quality conformity analysis, forecasted regional
emissions for its 2030 planning year are far below the allowable budgets. None of the studied
alternatives would cause a substantial percentage increase in regional vehicle miles traveled (VMT)
throughout the Puget Sound air basin. Therefore, the forecasted population growth and VMT for
studied alternatives would not appear to alter PSRCs conclusion that future Puget Sound regional
emissions will be less than the allowable emissions budgets mandated by the air quality
maintenance plans.

25
Greenhouse Gas Emissions
Regional greenhouse gas (GHG) emissions could be reduced by roughly 32,167 metric tons CO2-
equivalent per year based on cumulative Phase 1 and Phase 2 growth compared to business as
usual. The GHG emission reductions would beneficially contribute to the states goal of reducing
statewide GHG emissions.

No significant unavoidable adverse impacts on regional or local air quality are anticipated for the
Planned Action Area [Midway Subarea]. The regulations described below are adequate to mitigate
any adverse impacts anticipated to occur as a result of study area growth.
Mitigation Measures
mitigation measures shall be applied to planned actions.
Construction Emission Reduction Measures

The City shall require all construction contractors to implement air quality control plans for
construction activities. The air quality control plans will include best management practices (BMPs)
to control fugitive dust and odors emitted by diesel construction equipment, including but not
limited to the following measures.
Develop a fugitive dust control plan.
Use water sprays or other non-toxic dust control methods on unpaved roadways.
Minimize vehicle speed while traveling on unpaved surfaces.
Prevent track out of mud onto public streets.
Cover soil piles when practical.
Minimize work during periods of high winds when practical.
Maintain the engines of construction equipment according to manufacturers specifications.
Minimize idling of equipment while the equipment is not in use.
Burning of slash or demolition debris will not be permitted without express approval from
PSCAA. No slash burning is anticipated for any construction projects in the study area.

26
Greenhouse Gas Reduction Measures
GHG emissions reductions could be effected by developers using prudent building design and
construction methods to use recycled construction materials, reduce space heating and electricity
usage, and reduce water consumption and waste generation.
Table 3 lists a variety of additional mitigation measures that could further reduce GHG emissions
caused by building construction, space heating, and electricity usage (Washington State Department
of Ecology 2008 8). The City shall require planned action applicants to identify the reduction
measures in Table 3 that are being implemented in their projects, and explain why other measures
found in the table are not included or are not applicable. The City shall, as appropriate, condition
planned action applications to incorporate reduction measures determined (by the City based on the
development application) feasible and appropriate for site conditions.
8 Washington State Department of Ecology (Ecology). 2008. Leading the Way: Implementing Practical Solutions to
the Climate Change Challenge. Ecology Publication #08-01-008. November.

27
Table 3. Potential Greenhouse Gas Reduction Measures

Site Design
Plant large caliper trees and mature vegetation Trees and vegetation that directly shade
near structures to shade buildings buildings decrease demand for air conditioning.
By reducing energy demand, trees and
vegetation decrease the production of
associated air pollution and greenhouse gas
emissions. They also remove air pollutants and
store and sequester carbon dioxide. Thus trees
and vegetation reduce onsite fuel combustion
emissions and purchased electricity plus
enhance carbon sinks.
Minimize building footprint. Reduces onsite fuel combustion emissions and
purchased electricity consumption, materials
used, maintenance, land disturbance, and direct
construction emissions.
Design water efficient landscaping. Minimizes water consumption, purchased
energy, and upstream emissions from water
management.
Minimize energy use through building orientation. Reduces onsite fuel combustion emissions and
purchased electricity consumption
Building Design and Operations
Apply LEED (Leadership in Energy and Reduces onsite fuel combustion emissions and
Environmental Design) standards (or equivalent) off-site/indirect purchased electricity, water
for design and operations use, waste disposal
Purchase Energy Star equipment and appliances for Reduces onsite fuel combustion emissions and
public agency use. purchased electricity consumption
Incorporate on-site renewable energy production, Reduces onsite fuel combustion emissions and
including installation of photovoltaic cells or other purchased electricity consumption.
solar options.
Design street lights to use energy efficient bulbs Reduces purchased electricity.
and fixtures
Construct green roofs and use high-albedo Reduces onsite fuel combustion emissions and
roofing materials. purchased electricity consumption
Install high-efficiency HVAC systems. Minimizes fuel combustion and purchased
electricity consumption.
Eliminate or reduce use of refrigerants in HVAC Reduces fugitive emissions. Compare
systems. refrigerant usage before/after to determine
GHG reduction.
Maximize interior day lighting through floor plates, Increases natural/day lighting initiatives and
increased building perimeter and use of skylights, reduces purchased electrical energy
clerestories and light wells. consumption.
Incorporate energy efficiency technology such as: Reduces fuel combustion and purchased
super insulation motion sensors for lighting and electricity consumption.
climate control; and efficient, directed exterior
lighting

28
Use water conserving fixtures that surpass building Reduces water consumption.
code requirements.
Re-use gray water or collect and re-use rainwater. Reduces water consumption with its indirect
upstream electricity requirements.
Recycle demolition debris and use recycled Reduces extraction of purchased materials,
building materials and products. possibly reduces transportation of materials,
encourages recycling and reduction of solid
waste disposal.
Use building materials that are extracted or Reduces transportation of purchased materials
manufactured within the region.
Use rapidly renewable building materials. Reduces emissions from extraction of
purchased materials
Conduct 3rd party building commissioning to Reduces fuel combustion and purchased
ensure energy performance. electricity consumption.
Track energy performance of building and develop Reduces fuel combustion and purchased
strategy to maintain efficiency. electricity consumption.
Transportation
Size parking capacity to not exceed local parking Reduced parking discourages auto dependent
requirements and, where possible, seek reductions travel, encouraging alternative modes such as
in parking supply through special permits or transit, walking, biking etc. Reduces direct and
waivers. indirect VMT
Develop and implement a marketing/information Reduces direct and indirect VMT
program that includes posting and distribution of
ridesharing/transit information.
Subsidize transit passes. Reduce employee trips Reduces employee VMT
during peak periods through alternative work
schedules, telecommuting, or flex-time. Provide a
guaranteed ride home program.
Provide bicycle storage and showers/changing Reduces employee VMT
rooms.
Utilize traffic signalization and coordination to Reduces transportation emissions and VMT
improve traffic flow and support pedestrian and
bicycle safety.
Apply advanced technology systems and Reduces emissions from transportation by
management strategies to improve operational minimizing idling and maximizing
efficiency of local streets. transportation routes/systems for fuel
efficiency.
Develop shuttle systems around business district Reduces idling fuel emissions and direct and
parking garages to reduce congestion and create indirect VMT
shorter commutes.
Land Use Patterns, Plans and Policies

Significant Impacts
Land Use Patterns
29
The Midway Planned Action Area [Midway Subarea] would be transformed into a more intensive,
mixed-use pedestrian-oriented center for housing and employment under the Proposal/FEIS
Review Alternative, taking advantage of the subareas proximity to the planned high-capacity transit
station location in the vicinity of Highline Community College. The FEIS Review Alternative would
phase the growth, but the ultimate transformation would be the same as the Proposal, with a
modified subarea plan that provides some differences in scale.
The Midway Planned Action Area would accommodate approximately 82% of new households
anticipated in the Midway Subarea. [Remove prior sentence and state Under the Proposal the
Midway Subarea is anticipated to grow by approximately 9,900 households and 7,300 jobs
compared to the 2006 base year if Planned Action Area is the same as the Midway Subarea.] The
amount of concentrated multifamily and mixed-use development in the Midway Planned Action
Area would create a larger residential population than that found in Downtown. The Midway
Planned Action Area would accommodate about 90% of the new jobs anticipated in the Midway
Subarea under the Proposal/FEIS Review Alternative. [Remove prior sentence if Planned Action
Area is the same as the Midway Subarea.] Existing auto-oriented commercial development in the
Midway Planned Action Area Midway Subarea] would almost entirely be replaced by pedestrian
oriented retail, service, and office commercial uses that support and are supported by the intense
concentration of households in the area, and the high capacity transit investments made along and
in the vicinity of SR 99. Commercial or residential development would either be part of a mixed-use
development, or stand alone development.
Development within the Midway Planned Action Area Midway Subarea] under the Proposal/FEIS
Review Alternative would consist of taller buildings with greater site coverage than found in either
existing conditions or the No Action Alternative. With the notable exception of areas in the Kent
Highlands designated in the Midway Subarea Plan for passive open space and less intense uses, the
majority of vacant, surface parking areas, and auto-oriented uses in the Midway Planned Action Area
Midway Subarea] would be transformed into compact buildings or structured parking under the
Proposal/FEIS Review Alternative. The Proposal/FEIS Review Alternative would also include
smaller blocks or more frequent pedestrian or bicycle connections throughout the Midway Planned
Action Area Midway Subarea] to facilitate use of nonmotorized modes of transportation and access
to the planned light rail station in the vicinity of SR 99.
Under the Proposal/FEIS Review Alternative, the Comprehensive Plan Land Use Plan map
designations for the Midway Planned Action Area [Midway Subarea] would be changed from the
current mix of designations to a new transit-oriented Comprehensive Plan Land Use Plan map
designation (Transit Oriented Community). A subsequent Zoning Districts map amendment would
also be made to rezone the Midway Planned Action Area to transit-oriented zoning in keeping with
the new Comprehensive Plan Land Use Plan map designation. [if Midway Subarea becomes the full
Planned Action Area, replace prior sentence with: A subsequent Zoning Districts map amendment
would also be made to rezone the Midway Planned Action Area to series of new zoning districts
consistent with the Comprehensive Plan Land Use Plan map designation and vision of the subarea
plan.]

30
Plans and Policies
Under the Proposal, the Midway Subarea Plan would be adopted as part of the Citys Comprehensive
Plan. The FEIS Review Alternative would also adopt the subarea plan, and thus both the Phase 1 and
Phase 2 growth levels would occur under the new policies and regulations.
Growth Management Act and King County Countywide Planning Policies

The Midway Subarea Plan concentrates households and employment into areas with facilities and
services to serve the new development, and by contrast protects environmentally sensitive areas as
called for in both the GMA and Countywide Planning Policies (CPPs).
In particular, planning additional growth near future high-capacity transit investments in the
subarea is consistent with GMA and CPP goals relating to focusing growth in urban areas with
adequate services, encouraging efficient multimodal transportation systems, and requiring adequate
public infrastructure to support planned development.
The Proposal/FEIS Review Alternative would support the Citys overall plan to accommodate
growth targets for 2031, consistent with both the GMA and CPPs. In addition, the Proposal for the
Midway Subarea includes goals and policies intended to encourage housing that supports a full
range of incomes, including more prescriptive standards for affordable workforce housing. With the
FEIS Review Alternative there are other strategies for affordable workforce housing that do not rely
on a prescriptive approach. First, the FEIS Review Alternative maintains the Mobile Home Park
(MHP) zoning on existing mobile home parks within the Midway Subarea that currently have that
zoning, representing a large portion of the existing affordable housing stock within the Midway
Subarea. By retaining the MHP zone, a property owner would be required to apply for a rezone of
the property to redevelop it with mixed-use development, providing an opportunity for public
comment and a public hearing prior to a decision on rezoning the property. Second, additional
regulations and land use policies relating to affordable housing would be part of the Affordable
Housing Task Forces work program.
The Proposal/FEIS Review Alternative would be consistent with the CPPs relating to community
character and open space since the Midway Subarea Plan includes goals and policies addressing site
and building design, as well as implementing design guidelines.
Comprehensive Plan
The Proposal/FEIS Review Alternative for the Midway Subarea would be generally consistent with
the Citys Comprehensive Plan goals and policies.

The Midway Planned Action Area focuses household and job growth in a transit oriented node and
an area that has been identified as a redevelopment opportunity proximate to the new transit
investments along and in the vicinity of SR 99. The Midway Subarea Plan includes goals and policies

31
that are consistent with and supportive of the Citys Comprehensive Plan and the more general goals
of GMA and the CPPs.
Transit investments along and in the vicinity of the SR 99 corridor and the completion of reuse land
use plans for the Kent Highlands Landfill provide the basis for the Citys plans for the Midway
Planned Action Area. These actions allow the City to develop revisions to the Comprehensive Plan
Land Use Plan map, Zoning Districts map, and policies and zoning regulations that will expand
capacity in the Midway Planned Action Area in particular. In addition, the Midway Planned Action
Area is consistent with 2004 Comprehensive Plan Policies LU-6.1 and LU-9.4, and Goal LU-7 related
to encouraging high-intensity development in centers located close to high-capacity transit noted
above. This concentration of growth also supports Policy H-2.4 related to developing housing near
transportation hubs, and policies ED 2.3 and ED-3.3 related to investment of a mix of housing and
employment opportunities in proximity to transit.
The Midway Planned Action Area would also be the most consistent with Policy LU 20.5 for an area
that would include reduced parking ratios in proximity to intermodal transit/commuter facilities,
given the geographic location in the vicinity of high capacity transit investments.
By concentrating approximately 32% of new housing and 19% of new jobs from the overall planned
growth for the Kent Planning Area in the Planned Action Area within proximity to high capacity
transit investments, this allows the City to accomplish other Comprehensive Plan goals of preserving
existing residential neighborhoods (Policy H-2.1) and protecting environmentally sensitive areas
(Goal LU-23) in other parts of the Kent Planning Area.
[If Midway Subarea is made the Planned Action Area replace the entire section above with the
following:
Midway Subarea
Under the Proposal/FEIS Review Alternative the Midway Subarea would be generally consistent
with the Citys Comprehensive Plan goals and policies.
Land Use Element. The Proposal/FEIS Review Alternative for the Midway Subarea is consistent
with City Land Use goals and policies particularly related to designation of Activity Centers in
commercial areas of the City to allow a mix of retail, office, and residential development (Goal LU-6)
and to facilitate pedestrian, public transit, and vehicular circulation (Goal LU-7). Because the
Midway Subarea is also slated for high capacity transit investments by King County Metro and
Sound Transit, the Midway Subarea Plan and implementation is also consistent with Activity Center
policies that promote development proximate to transit, and development types that support transit
investments. Examples of these policies include,
Policy LU-6.1 on the location of Activity Centers in commercial areas with surrounding medium-
density housing where the land use patterns can be intensified in support of transit.
Goal LU-7 on developing Activity Centers in such a way to facilitate pedestrian, cyclist, public
transit, and vehicular circulation.
32
Policy LU-9.4 on locating housing opportunities with a variety of densities in proximity to
transit.
Under the Proposal/FEIS Review Alternative, the City would adopt the Midway Subarea Plan,
incorporating it as part of the Citys Comprehensive Plan, consistent with Policy LU-14.1, which calls
for development of subarea plans for Activity Centers.
The Proposal/FEIS Review Alternative for the Midway Subarea includes adoption of policies
supportive of creating high quality aesthetics and designing a quality pedestrian environment
consistent with Comprehensive Plan Goals LU-8.
The Midway Subarea Plan also provides opportunities for residential development to occur within
an existing business district that will provide support for shops, services, and employment within
walking distance, consistent with Comprehensive Plan Policy LU-14.2.
The Midway Subarea Plan goals and policies are consistent with the Citys Comprehensive Plan goals
and policies. In particular, the Proposal/FEIS Review Alternatives Midway Subarea Plan includes
goals and policies to address parking policies in areas with high capacity transit consistent with
Policy LU-20.5.
Housing Element. The Proposal/FEIS Review Alternative for the Midway Subarea is consistent with
housing goals and policies of the City Comprehensive Plan, particularly those supporting
development of housing near transportation hubs and employment centers. The Proposal/FEIS
Review Alternative is also consistent with goals and policies encouraging housing, including
affordable housing, in mixed-use development in commercial settings throughout the City.
Transportation Element. The Proposal/FEIS Review Alternative for the Midway Subarea would be
consistent with City goals and polices of the Transportation Element. In particular, the
Proposal/FEIS Review Alternatives focus on providing a concentrated mix of residential and
commercial development in proximity to planned high capacity transit stations is consistent with a
number of Transportation goals and policies.
However, the Citys Transportation Element would need to be amended as described in the
Transportation Section of this FEIS, to account for additional transportation improvements
necessary to meet City concurrency standards.
Economic Development Element. The Proposal/FEIS Review Alternative for the Midway Subarea
would be consistent with the Citys Economic Development Element since the Proposal/FEIS Review
Alternative would encourage additional housing and job growth in concentrated areas proximate to
future high capacity transit investments.]

Over time, implementation of either alternative could unavoidably convert vacant, partially
developed, and developed properties in the Midway Planned Action Area [Midway Subarea] to
additional or new residential, office, and commercial, [and light industrial] uses. Because of the
densification and intensification of uses, the City would continue to add to its urban character.
33
Nevertheless, the resulting transformation of land uses from less intense suburban character to
more intense urban character is considered a significant unavoidable adverse impact.
Mitigation Measures
The City will require that Planned Action applicants demonstrate consistency with City adopted
plans and regulations, including but not limited to the Midway Subarea Plan, implementing
zoning regulations and design standards.
Aesthetics
Significant Impacts
Visual Character
Over time, the Transit-Oriented Community within the Midway Planned Action Area [northern
Transit Oriented Community] would redevelop as a high-intensity center combining residences and
a mix of commercial, office, and neighborhood service uses. Large areas of surface parking would be
discouraged in favor of transit connections, and block sizes would be reduced to facilitate walking.
The Midway Subarea Plan contains a collection of urban design goals and policies that call for
implementation of human-scaled architectural design to maintain the Transit Oriented Community
as a desirable place for pedestrians. Implementation of the Midway Subarea Plan would create a
more aesthetically pleasing visual character for the Transit Oriented Community. Existing conditions
in the Kent Highlands area, however, are far less commercially oriented than along SR 99. The Kent
Highlands area is currently far less developed than the SR 99 corridor and provides for some open
space, though the area is altered. As such, high intensity development of the kind proposed under
the Midway Subarea Plan would have the potential to significantly transform the visual character of
this area to a mixed use character.
[If the Subarea is the full Planned Action Area, add the following:
Under the Proposal/FEIS Review Alternative, the portion of the Midway Subarea south of the
northernmost Transit Oriented Community would primarily redevelop as an auto-oriented
commercial and light industrial corridor, which would continue the traditional function of
commercial development along SR 99. The uses in this portion of the subarea would be similar to
existing conditions, though density is anticipated to increase as properties redevelop to
accommodate future growth.
The Midway Subarea Plan would also integrate portions of the area between S 260th Street and S
268th Street as part of the subareas open space framework, incorporating the wetlands and other
critical areas outside the subarea boundaries on the east side of SR 99 as open space elements and
providing a link between development inside the subarea and the West Hill neighborhood
immediately to the east. As this portion of the subarea is currently minimally developed because of
34
the presence of these critical areas, changes in visual character in this portion of the subarea are
anticipated to be minimal.
The southern end of the subarea, centered on the intersection of SR 99 and S 272nd Street, would
redevelop as a secondary Transit Oriented Community, similar to the one proposed for the
intersection of SR 99 and SR 516, though covering less area. Likewise, visual character is anticipated
to be similar to the Transit Oriented Community in the Midway Planned Action Area, though slightly
less intense. As discussed for the primary Transit Oriented Community, compared to the current
visual character of the intersection, implementation of the Midway Subarea Plan would create a
more aesthetically pleasing visual character, and with the implementation of mitigation in the form
of design guidelines, no significant impacts on visual character are anticipated.]
Height and Bulk

Under the Proposal/FEIS Review Alternative, building heights in the northern Transit Oriented
Community would be up to a maximum of approximately 200 feet, which is a substantial increase
over the current maximum heights. According to City staff, the tallest buildings (up to 15 stories)
would be found in the area between S 240th Street and S 246th Street and in the Kent Highlands
area east of I-5 (Gould-Wessen pers. comm.). However, there is a five-story maximum building
height along SR-99 within the TOC land use plan map designation. The remainder of the northern
Transit Oriented Community would consist of a mix of building heights in the five- to six-story range
with taller buildings interspersed throughout. Such an increase in heights has the potential to
introduce a canyon effect for pedestrians at street level without mitigation. The Proposal/FEIS
Review Alternative uses areas of lower height to provide buffers between tall buildings and
sensitive areas, such as parks, open space, and defined pedestrian corridors (Gould-Wessen pers.
comm.). Implementation of the Midway Subarea Plan includes design guidelines focused on the
reduction of visual bulk at street level and compatibility between the Transit Oriented Community
and less intense adjacent development such as single-family residences. With mitigation
incorporated, height and bulk impacts are anticipated to be less than significant.
[If Subarea is the full Planned Action Area, add the following:
In the portion of the Midway Subarea south of the primary Transit Oriented Community and north
of S 268th Street, maximum building heights would remain at the current limit of 35 feet, with an
allowance for administrative approval of one additional story.Therefore, no height and bulk impacts
are anticipated.
The southern end of the Midway Subarea, centered on the intersection of SR 99 and S 272nd Street,
would redevelop as a secondary Transit Oriented Community, similar to the one proposed for the
intersection of SR 99 and SR 516, though covering less area. Maximum heights at this location
would increase to approximately 55 feet, which is a slight increase over the current limits because
existing regulations allow administrative approval of one additional story. However, design
guidelines implementing the Midway Subarea Plan focus on the reduction of visual bulk at street
level and compatibility between the subarea and less intense adjacent development such as single-

35
family residences. With mitigation incorporated, height and bulk impacts are anticipated to be less
than significant.]
The Proposal/FEIS Review Alternative divides the Midway Subarea into implementing zones with
variable heights that consider the character of adjacent residential areas. Zones are mapped in a
manner in which a new Midway Subarea zone (Midway Transit Community 1, or MTC-1) with a
lower maximum height (5 stories or 55 feet) is applied to the western portion of the northern
Transit Oriented Community designated lands, adjacent to lower intensity residential districts
located further to the west[ and in the southern TOC area adjacent to lower intensity residential
districts located to the east]. In addition, the MTC-1 zone would provide further height restrictions
of 35 feet in height within 20 feet of a residential district, and 45 feet in height within 40 feet of a
residential district.
No significant adverse impacts are anticipated to the pedestrian environment. At present, the
Midway Planned Action Area [Midway Subarea] provides minimal pedestrian infrastructure; blocks
are large, sidewalks are frequently interrupted by curb cuts, transit stops are not sheltered from the
elements and no on-street parking or landscaping are present to buffer pedestrians from the
adjacent highway. There are no curb, gutter or sidewalks along 30th Avenue. Under the
Proposal/FEIS Review Alternative, a set of design guidelines focused on enhancement of the
pedestrian experience would be implemented, which would encourage new development to provide
pedestrian amenities such as seating, weather protection, and human-scaled lighting. Over time, this
would result in a pedestrian environment in the Midway Planned Action Area that is more similar to
the historic core of Downtown, focused on social interaction and use of public transit.
Scenic Views
Views from public rightsof-way in the Midway Planned Action Area [Midway Subarea] are mostly
fragmentary, often screened by intervening topography, vegetation, or existing development.
However, strong views of the Cascades are available in the former Kent Highlands Landfill area, and
views of Mount Rainier and Puget Sound are available at topographically high points along SR 99
north of S 240th Street. The large increase in heights under the Proposal/FEIS Review Alternative
has a high potential to block these public views, though such development would increase the
availability of private views. The Comprehensive Plans Community Design Element calls for the
preservation of views from public rights-of-way and public areas to the greatest extent practicable.
Though the Midway Design Guidelines call for upper-story setbacks to take advantage of views, they
do not address view preservation in the same detail as they do architectural design or pedestrian
amenities. As a result, additional mitigation should be considered to prevent significant impacts on
scenic views in the Midway Planned Action Area [Midway Subarea], such as the definition of
protected public view corridors and the implementation of measures to provide viewpoints from
public areas in locations where higher topography provides views of scenic visual resources.
[If the whole Subarea is the Planned Action Area, add the following:

36
As fewer views are available in the southern portion of the Midway Subarea south of the primary
Transit Oriented Community, and building heights would not increase from what is allowed by
existing regulations, impacts on scenic views are anticipated to be less than significant. Impacts on
views would be greater in the secondary Transit Oriented Community at S 272nd Street, though the
increase in building heights would create territorial views that are not currently available at this
location and design guidelines would be applied.]
Light and Glare

Additional growth in the Midway Planned Action Area [Midway Subarea] would introduce new
sources of light and glare, such as increased numbers of automobiles, additional exterior
illumination for buildings, and new street lighting. The Kent Highlands area would be particularly
impacted by increases in illumination, as this area is currently developed at a very low intensity. The
Midway Design Guidelines focus on limiting glare and light pollution. With the implementation of
these guidelines, light and glare impacts are anticipated to be less than significant. [If the whole
subarea is the Planned Action Area, add the following: Lighting conditions outside of the TOC area,
where the Midway Design Guidelines are inapplicable, would be similar to what currently exists.
Furthermore, Kent City Code (15.08.050.A and D.4 and 15.05.090.E) regulates impacts from lighting
and glare. With the implementation of Kent City Code in the subarea and the Midway Design
Guidelines in the TOC areas, the light and glare impacts are anticipated to be less than significant.]

In urban environments, solar access and shading conditions are intrinsically linked to building
height and bulk. As building heights in the Midway Planned Action Area [northern Transit Oriented
Community] would be greatly increased over current limits, the potential for shading impacts is
high. The areas of greatest concern for shading impacts in the Midway Planned Action Area [Midway
Subarea] are south of S 240th Street, where buildings up to 15 stories in height are planned in
proximity to areas depicted as open space and pedestrian pathways in the Midway Subarea Plan.
Additionally, 15-story construction planned immediately north of S 240th Street could potentially
shade elements of the open space framework, including a proposed park.
The Proposal/FEIS Review Alternative includes draft design guidelines for the Midway TOC area
that require upper story setbacks after the third and sixth floors of a building, which will reduce
shading impacts at street level, but even with the application of these standards, solar access will be
reduced compared to the No Action Alternative. SR 99 will be the least affected street frontage, due
to its width and north-south orientation, as well as lower proposed height limits, but side streets
and pedestrian/bicycle pathways have a high potential to be impacted, particularly during winter
months, when the sun in lower in the sky and casts longer shadows.
[If full subarea becomes the Planned Action Area, add the following:
As heights along the highway commercial corridor portion of SR 99 in the southern portion of the
Subarea would not increase over current allowable limits, the shading impacts are not anticipated to
be significant over the long term.

37
The S 272nd Street Transit Oriented Community may experience an increase in shading conditions
due to slight increases in allowable building heights. The areas most likely to be adversely affected
by this increase are side streets and pedestrian pathways that form connections between
developments. To mitigate these impacts, the City should consider the implementation of additional
design guidelines focused on the preservation of solar access.]
To ensure that solar access is preserved in public gathering spaces, such as parks and plazas, and
that high-intensity development in the Midway Planned Action Area [northern Transit Oriented
Community] does not adversely affect adjacent lower-intensity zones and public spaces, including
those anticipated within the district, as well as any areas on the edges (including the City of Des
Moines) the City should consider the implementation of additional design guidelines related
specifically to parks, public gathering spaces, pedestrian/bicycle paths, and complete streets.

The overall character, significance, or magnitude of aesthetic impacts on the Midway Planned Action
Area [Midway Subarea] depend largely on the quality of the architectural and urban design features
incorporated into the development, the degree to which the overall scale and form of the
development incorporates features of the local setting, and the values and preferences of those
viewing the change. With proposed mitigation, particularly implementation of the Midway Design
Guidelines, aesthetic impacts resulting from the Proposal/FEIS Review Alternative are anticipated to
be less than significant. However, the large increase in heights proposed for the Midway Planned
Action Area [northern Transit Oriented Community] in particular has a high potential to increase
shading conditions on side streets and internal circulation routes beyond the ability of the
incorporated design guidelines to mitigate. While the Proposal/FEIS Review Alternative is
anticipated to create a visual character and pedestrian environment that is superior to existing
conditions overall, without the implementation of the additional mitigation measures related to
shading conditions and public views listed in the section below, the Midway Planned Action Area
[northern Transit Oriented Community] has a high potential to be impacted. The FEIS Review
Alternative would have lesser impacts to height than those analyzed under the initial Proposal due
to incorporation of more detailed zoning and development regulations related to transitional height
along SR 99 and near residential areas adjacent to the proposed MTC-1 zone. Should the City choose
not to adopt the draft Midway Design Guidelines, impacts associated with the Proposal/FEIS Review
Alternative would be much greater.
Mitigation Measures
The City may condition planned action applications to incorporate site design measures that
preserve significant public views from public areas consistent with scenic views analysis on
page 36 of this Exhibit B.

38
To minimize shading impacts within the Midway Planned Action Area [northern Transit
Oriented Community] in instances where adjacent sensitive land uses exists (such as a lower
intensity zone or public park), the City shall require as a condition of development, that planned
action applications place the tallest portions of new buildings or the tallest buildings on a
development site central to the property in order to maximize the distance from adjacent
sensitive land uses. This may be accomplished by application of the transitional height
standards included in the FEIS Review Alternative and through implementation of Midway
Design Guidelines relating to Site Characteristics, Transition Between Residence, Street and
Adjacent Sites, and Height Bulk and Scale, or equivalent action.
To minimize shading impacts[ in the northern Transit Oriented Community], the City shall
condition planned action projects with the following mitigation measures, as deemed
appropriate to specific site conditions:
Solar access for public pedestrian spaces, pedestrian/bicycle pathways, parks, schools and
other areas sensitive to shading shall be preserved by requiring upper-story or ground-level
setbacks for adjacent development.
Development shall include upper story step -backs at the third story and again at the
seventh story to increase sunlight at street level when adjacent to any component of the
Open Space Framework illustrated in the Midway Subarea Plan, including
pedestrian/bicycle pathways, and parks.
Coordinated design shall be encouraged between properties in the area south of S 240th
Street and north of S 246th Street to ensure that the high-intensity development anticipated
in this location preserves solar access to interior spaces and private pedestrian connections.
Transportation
This section addresses potential impacts of development in the full Midway Subarea including the
primary northern Transit Oriented Community where most of the growth would be concentrated.
Significant Impacts
Street System Impacts
The Phase 1 level of growth (consistent with the No Action Alternative) reflects the TMP, which
assumes a transportation network that meets the Citys roadway Level of Service (LOS) criteria for
all intersections along SR 99. The results of an operations analysis of the five key intersections along
this corridor under the Phase 1 levels of growth are summarized in Table 4.

39
Table 4. Phase 1 Growth Levels and Resulting Intersection Level of Service Midway Subarea
LOS (Average
LOS Delay)
ID North/South Street East/West Street Standard No Action1
1 SR 99 Kent-Des Moines Road F2 F3

(SR 516)
2 SR 99 S 240th Street F2 F (87 seconds)
3 SR 99 S 252nd Street F2 B (16 seconds)
4 SR 99 S 260th Street F2 E (78 seconds)
5 SR 99 S 272nd Street F2 F (151 seconds)
1 LOS reflects projected operating conditions with TMP projects in place (as summarized in
Table 3.5-8 of the Draft EIS).
2 The City has defined a standard of LOS F for this corridor, but as a HSS facility, the WSDOT
standard of LOS D is also applied.
3 This intersection was not analyzed by the TMP; however, forecast traffic volumes would exceed
this intersections capacity in the No Action Alternative.
Table 5 shows the projected Level of Service (LOS) for the five key intersections evaluated along the
SR 99 corridor with the total cumulative growth of Phase 1 and Phase 2 (applicable to the
Proposal/FEIS Review Alternative), and with the City of Kent TMP projects in place. As the table
shows, all five of the key intersections studied in the EIS along the SR 99 corridor would have LOS F
operations with greater overall delays than the Phase 1 level of growth (consistent with the
No Action Alternative).

40
Table 5. Phase 1 and Phase 2 Total Levels of Growth Combined Intersection Level of Service
without Mitigation
LOS (Average
Delay)
LOS with Phase 2
ID North/South Street East/West Street Standard Growth1
1 SR 99 Kent-Des Moines Road F2 F (>240 seconds)

(SR 516)
2 SR 99 S 240th Street F2 F (>240 seconds)
3 SR 99 S 252nd Street F2 F (>240 seconds)
4 SR 99 S 260th Street F2 F (>240 seconds)
5 SR 99 S 272nd Street F2 F (>240 seconds)
1. LOS reflects projected operating conditions with TMP projects in place.

2 The City has defined a standard of LOS F for this corridor, but as a HSS facility, the WSDOT standard
of LOS D is also applied.
While many of these intersections would operate at LOS F under the Phase 1 level of growth (No
Action Alternative) and the City has established an LOS F standard for this corridor, introducing the
Phase 2 level of growth (Proposal/FEIS Review Alternative) without transportation network
enhancements to support the proposed land uses would result in diminished mobility throughout
the corridor. Given the substantial increase in delay and reduction in mobility that are projected to
result from the addition of the Phase 2 level of growth, LOS impacts are identified at all five of these
key intersections.
Pedestrian, Bicycle, and Transit Facilities

By introducing substantial new residential and employment capacity into the Midway Planned
Action Area [Midway Subarea], the Phase 2 level of growth would increase demands for parking,
pedestrian, bicycle, and transit facilities. The Proposal/FEIS Review Alternative include a number of
goals and policies that support development of parking, pedestrian, bicycle, and transit facilities (see
Midway Subarea Plan). With these policies in place, no adverse impacts on parking, pedestrian,
bicycle, and transit facilities are identified.

Implementation of the Phase 2 level of growth would result in increased traffic volumes and demand
for transportation facilities in the Midway Planned Action Area [Midway Subarea]. Although the
effects of additional vehicles on traffic congestion can be lessened through construction of the
various transportation projects in the TMP and discussed under Mitigation Measures, and adoption
of the Midway Subarea Plan policies described above, the actual increase in traffic volumes under
the Proposal/FEIS Review Alternative is considered a significant unavoidable adverse impact.

41
Full implementation of the roadway mitigation measures discussed for the Proposal or FEIS Review
Alternative relies on state actions, such as completion of the SR 509 plan as well as City policy
decisions and available revenues. Because the City does not have control over the implementation
of the SR 509 project, the full mitigating effects of the Midway Planned Action Area [Midway
Subarea] mitigation projects cannot be guaranteed. Thus, all intersection and roadway impacts
identified under the Proposal or FEIS Review Alternative are considered significant unavoidable
adverse impacts.
Mitigation Measures
Level of Service Mitigation MeasuresMidway Subarea

For either Phase 1 or Phase 2 levels of growth, the City will apply its concurrency program to
proposed planned action development applications and the City will require each development to
pay its fair share contribution towards implementation of the projects listed in the Transportation
Master Plan through the Citys adopted Transportation Impact Fee program (KCC 12.14).
The TMP and Transportation Impact Fee program is expected to be updated by the next complete
Comprehensive Plan Update. At that time, the City will use the most currently adopted City plans
and policies in coordination with the State of Washington and the Puget Sound Regional Councils
most currently adopted plans and policies to forecast the Citys future transportation needs. It is
anticipated that new projects, including the projects identified in Table 6 and supporting Phase 2
growth associated with Proposal/FEIS Alternatives, would be added to any future version of the
TMP to address more intense land use and associated traffic impacts. The cost of these projects may
be added to the Transportation Impact Fee, or a more specific area charge could be developed for
areas of intense land use. Planned Action developers will then be required to pay their fair share
contribution towards the additional projects needed to mitigate that higher level of growth.
Assuming both Phase 1 and Phase 2 levels of growth combined, the impacts to operations along SR
99, as well as to Kent-Des Moines Road and the Kent-Des Moines Road/I-5 interchange, necessitate
the provision of the on-site transportation infrastructure found in Table 6 that supports the land
uses included in the Proposal/FEIS Review Alternative.

42
Table 6. Combined Phase 1 and Phase 2 Levels of Growth: Mitigation Projects for the Midway
Subarea Plan (Reference Figure 3.5-4 of the FEIS)
1 Local Street Connection Create a local street connection by extending 231st Street
from I-5 to 30th Avenue. This connection would be designed
to provide an additional link for local traffic across I-5 and is
contingent on State action.
2 30th Avenue Overcrossing Grade-separated four-lane crossing of Kent-Des Moines Road,

with right-turn access maintained between two roadways.
3 30th Avenue Complete Construct a four-lane cross-section, but initially stripe to

Streets Enhancements include two travel lanes with parking on both sides of street
from Kent-Des Moines Road to S 240th Street. Design with
traffic calming elements to reduce vehicle speeds and
encourage non-motorized travel. Roadway will be converted
to four lane operations once the Citys LOS E threshold is
exceeded.
4 Complete Street Connection Construct a four-lane cross-section, but initially stripe to

240th to 244th Street include two travel lanes with parking on both sides of street
from S 240th Street to access road provided at S 244th Street.
Design with traffic calming elements to reduce vehicle speeds
and encourage non-motorized travel. Roadway will be
converted to four lane operations once the Citys LOS E
threshold is exceeded.
The LOS D/E threshold for a two-lane arterial is 1,760 PM
peak hour vehicles, whereas for a four-lane arterial it is
2,740. Assuming that Midway developed to its full capacity,
as the Proposal/FEIS Review Alternative evaluates, PM peak
hour volumes on 30th Avenue between Kent-Des Moines
Road and S. 244th Street would be about 2,700.
5a,b Business Access Service Provide two-lane route for accessing businesses between S
Roads 244th Street and S 252nd St; and between S 252nd and S
260th Street. Conceptual alignments to be determined.
6a,b,c SR 99 Access Roads Provide three new access roads between 30th Avenue and SR
99. One would extend from S 238th Street; another would be
midway between S 238th Street and S 240th Street, and the
third would be located at S 244th Street.
7a,b Local Circulation Routes Internal roadways are provided to facilitate internal travel
among proximate uses in the Kent Highlands (since there will
be no direct access off of S 231st Street), and west of SR 99 in
the northwestern portion of the development.
8a,b,c,d New Signalized Intersections 231st Street/30th Avenue; SR 99/S 238th Street; SR 99/S
244th Street; S 259th Place/29th Avenue S.
9 New Right In/Right Out SR 99/Access road midway between S 238th Street and S
Intersection 240th Street.

43
10 240th/SR 99 Widen westbound approach from one exclusive left turn lane
and one through/right turn lane to add an exclusive right-
turn lane or right turn pocket.
11 Internal Site Intersections Five-to-six locations where either a roundabout, a signal, or

all-way stop may be appropriate based on forecasted traffic
volumes and site conditions.
The extension of S 231st Street to 30th Avenue S as a local road connection was not originally
anticipated in the Midway Subarea Plan; however, analysis indicates that it will be necessary to
address impacts to Kent-Des Moines Road and the I-5 ramp terminal intersections.
Results of the Proposal/FEIS Review Alternative LOS for the five key intersections evaluated along
the SR 99 corridor with these additional improvements in place show that many of the intersections
along SR 99 will still have LOS F operations. However, the level of delay and mobility is much closer
to what is projected under the No Action Alternative.

Significant Impacts
Police
The Police Departments adopted LOS standard is a response time of 6 minutes or less to the scene
from receipt of an emergency call. Growth in population and employment in a concentrated area in
the Midway Planned Action Area [primary northern Transit Oriented Community] is expected to
result in greater traffic congestion, particularly on routes identified in the Transportation analysis in
the DEIS (Section 3.5). The City may need to expand the existing police facilities located in and near
the Midway Subarea to provide a faster response time. While the City does not define its operational
LOS in terms of employed police officers and support staff, it can be reasonably assumed that the
number of calls for police services would increase in conjunction with the Midway Planned Action
Area [Midway Subarea]s increase in population. To maintain the ability to respond to emergency
calls in a timely manner, it may be necessary for the Police Department to hire additional officers
and support staff for a new or expanded police facility located in or proximate to the Midway
Subarea during the planning period.
Compared to the cumulative Phase 1/Phase 2 growth (comparable to the Proposal/FEIS Review
Alternative), it is unlikely that the City would need additional police service facilities for the Midway
Subarea under Phase 1 growth levels. Still, the City may need to construct new facilities or expand
current facilities to provide faster response time in light of additional congestion experienced in the
Midway Subarea.
Because the City has a mutual aid agreement with Des Moines and Federal Way for police services in
the Midway Subarea, increases in population and employment in the Subarea would also result in an

44
increase in calls for service that could affect the City of Des Moines and City of Federal Way Police
Departments.

Similar to the Police Department, the Kent Fire Department Regional Fire Authoritys (RFA) LOS
standards are related to response time. Although the Midway Planned Action Area [Midway
Subarea] represents a small portion of the RFAs service area, (it also serves the City of Covington
and areas of unincorporated King County served by Fire District 37), and an even smaller
percentage of the overall fire service area population, anticipated increases in population and
employment in the Midway Planned Action Area [Midway Subarea] would have an effect of
increasing traffic congestion, particularly on routes identified in the Transportation analysis in the
DEIS (Section 3.5). Increases in traffic congestion will have an effect of slowing response time to
emergency medical calls. In addition, the increased population and employment in the Midway
Planned Action Area [Midway Subarea] will use existing capacity of current resources. Therefore
growth anticipated under the cumulative Phase 1/Phase 2 total (comparable to the Proposal/FEIS
Review Alternative) will be expected to result in a need for additional fire and emergency response
facilities, expansion of existing facilities, relocation of fire and emergency response facilities, or a
combination of these measures to serve the larger mixed-use population without reducing existing
level of service. The Kent Fire Department RFA defines its operational LOS based upon response
time. To achieve the defined LOS response time, the availability or capacity of fire and emergency
medical units must be equal to, or greater than the adopted performance expectation during peak
hours. Reserve capacity only exists if the unit is available more than the stated LOS objective.
Because minimal capacity exists prior to implementing this Proposal/FEIS Review Alternative, it
will be necessary for the RFA to hire additional firefighters emergency medical technicians (EMTs),
and support staff during the planning period.
Growth anticipated under Phase 1 alone (comparable to the No Action Alternative) is less likely to
result in the need for additional fire and emergency response facilities, expansion of existing
facilities, relocation of fire and emergency response facilities, or a combination of these measures.
However, growth in the Midway Subarea in combination with growth in surrounding parts of the
Kent Planning Area under Phase 1 growth levels may result in the need for additional fire and
emergency medical facilities.
Because the City has a mutual aid agreement with nearby fire service and emergency medical
service providers in the Midway Subarea, increases in population and employment in the subarea
would also result in an increase in calls for service that could impact other fire and emergency
medical response providers.

The National Recreation and Park Association (NRPA) no longer recommends a standard for facility
and park land based on population ratios; however, the NRPA recommends that because every
community is different, standards should be developed by the community and used as a guide in

45
planning. Kents 2010 Park & Open Space Plan and updated Comprehensive Plan Park and Open
Space Element describe LOS standards based on 2009 population in Table 7 below.
Table 7. Parks and Recreation Level of Service Standards
Facility Type LOS Standard1

Park land 15.24 acres/1,000 population
Recreational Facilities 1.86 square feet/person
Source: City of Kent 2010b: Table 2.
1 Based on 2009 population estimates.
While the 2010 plan identified the LOS standards above, the plan also indicated that the Citys
direction is to develop a more qualitative parks and recreation standard. The 2010 Park & Open
Space Plan also includes implementation plans and acquisition plans for both the short term (2010
to 2020) and long term (2010 to 2030) that will address part of the anticipated needs under the
Proposal/FEIS Review Alternative. Some of the core themes of the plan include developing trails and
greenway corridors to connect parks, schools, and neighborhoods.
The Midway Planned Action Area would see the largest concentrated increase in households in the
entire Kent Planning Area under the combined Phase 1/Phase 2 growth levels (comparable to the
Proposal/FEIS Review Alternative). When applying numeric LOS standards to the Midway Planned
Action Area, 321 acres of park land and 39,131 square feet of recreation facilities would be needed
in that area to meet City parks and recreation LOS standards. Considering Phase 1 growth levels
alone (comparable to the No Action Alternative), only 16 acres of park land and 1,967 square feet of
recreation facility space would be needed.
[If Midway Subarea is fully made the Planned Action Area, then replace above paragraph with the
following:
The Midway Subarea would see the largest concentrated increase in households in the entire Kent
Planning Area under the combined Phase 1/Phase 2 growth levels (comparable to the
Proposal/FEIS Review Alternative). When applying numeric LOS standards to the Midway Subarea,
449 acres of park land and 57,748 square feet of recreation facilities would be needed in that area to
meet City parks and recreation LOS standards. Considering Phase 1 growth levels alone (comparable
to the the No Action Alternative), only 83 acres of park land and 10,093 square feet of recreation
facility space would be needed.]
Acre demand figures do not reflect that there are about 212 acres of open space in the overall
Midway Subarea in the form of the landfills, parks (City of Kent Park 2.7 acres), and public and
private wetlands. In addition, although there are no formal parks or recreation spaces in the Midway
Planned Action Area [Midway Subarea], several parks are located nearby, both in the City, the City of
Des Moines and the City of SeaTac. Midway Subarea Plan policies are oriented toward sharing
existing facilities with neighboring jurisdictions, school districts and other entities through joint use
agreements, and considering options for use of other City park facilities as a means of expanding
recreational access for the area. The Midway Subarea Plan also includes a number of other parks
and open space goals and policies which could be incorporated into and otherwise expand upon the
46
2010 Park & Open Space Plans Capital Improvement Program West Hill park acquisition. Midway
Subarea parks and recreation goals and policies are oriented towards acquiring, designing and
constructing civic plazas, parks, and other recreation facilities appropriate to development of a high
density Transit Oriented Community.
Given the lack of park and recreation facilities in all portions of the Midway Subarea and the Citys
intended direction to prepare more qualitative LOS standards in the future, the City could in the
interim determine an appropriate ratio of onsite park and recreation space to be provided with new
development. For example, currently, the City requires that residential subdivisions and short
subdivisions provide recreation space for leisure, play, and sport activities at a ratio of four hundred
fifty (450) square feet per dwelling unit (KMC 12.04.060), and also allows a fee-in-lieu of providing
the facility onsite (KMC 12.04.065). Applying this ratio to the growth of the Proposal/FEIS Review
Alternative in the Planned Action Area (8,153 households) would result in approximately 84 acres
of open space. This combined with the 83 acres of landfill area that are identified as part of the
Subarea Plan Open Space Framework would begin to achieve substantial park and open space
serving the increased population in the Planned Action Area as well as the overall Subarea. It is
recognized that a feasibility analysis is required to determine whether the landfill area has
recreational value beyond mere open space.
[If the Midway Subarea is made the full Planned Action Area, then replace the above paragraph as
follows:
Given the lack of park and recreation facilities in all portions of the Midway Subarea and the Citys
intended direction to prepare more qualitative LOS standards in the future, the City could in the
interim determine an appropriate ratio of onsite park and recreation space to be provided with new
development. For example, currently, the City requires that residential subdivisions and short
subdivisions provide recreation space for leisure, play, and sport activities at a ratio of four hundred
fifty (450) square feet per dwelling unit (KMC 12.04.060), and also allows a fee-in-lieu of providing
the facility onsite (KMC 12.04.065). Applying this ratio to the growth of the Proposal/FEIS Review
Alternative in the Midway Subarea (9,904 households) would result in approximately 102 acres of
open space. This combined with the 83 acres of landfill area that are identified as part of the
Subarea Plan Open Space Framework would begin to achieve substantial park and open space
serving the increased population in the overall Subarea. It is recognized that a feasibility analysis is
required to determine whether the landfill area has recreational value beyond mere open space.]
Schools
Highline School District
Under the combined Phase 1/Phase 2 growth levels (similar to the Proposal and FEIS Review
Alternative), the portion of the Highline School District located in the Midway Planned Action Area
[Midway Subarea] would experience an increase of more than 1,700 students [2,000 students] over
the planning period. This large of an increase in students, in a concentrated area, is likely to have an
impact upon Highline School District facilities, particularly at the middle and high school levels
where existing facilities are already over capacity. The Phase 1 growth levels alone (similar to the

47
No Action Alternative) would only result in an increase of 44 [50] or less students over the planning
period. Although small, the additional students generated under the No Action Alternative, in
combination with an increase in students in other portions of the Highline School District, may
result in a need to develop new facilities and/or use relocatable classrooms to accommodate the
number of new students expected.
The Federal Way School District encompasses a larger portion of the City limits, but a smaller
portion of the northern TOC than the Highline School District. Under the cumulative Phase 1/Phase
2 levels of growth (comparable to the Proposal/FEIS Review Alternative), the Federal Way School
District would experience an increase of 2,400 students over the planning period, of which
approximately 1,180 [1,450] students would be located in the Kent Highlands, part of the Midway
Planned Action Area [Midway Subarea]. The additional students generated under Phase 1 levels of
growth (similar to the No Action Alternative) are estimated at about 10 [80] in the Midway Planned
Action Area [Midway Subarea], and it is less likely that the increase in population anticipated would
result in capacity deficits for Federal Way school facilities.
Kent School District
Under the cumulative Phase 1/Phase 2 levels of growth (comparable to the Proposal/FEIS Review
Alternative), the portion of the Kent School District within the Kent Highlands would likely include
mixed-use development, including multifamily residential development. Under the Proposal/FEIS
Review Alternative, the schools in the Kent School District serving this portion of the Kent Highlands
could see an increase of approximately 400 students given the magnitude of new development
anticipated in the Kent Highlands. Phase 1 levels of growth alone are unlikely to generate more than
a handful of new students attending Kent schools.
Water
Highline Water District
With cumulative Phase 1 and Phase 2 growth (similar to the Proposal and FEIS Review Alternative)
and based upon historic water demand by residential and non-residential users the Kent portion of
the Highline Water District would increase water consumption from 0.4 to 1.7 MGD during the
planning period.
Considering Phase 1 growth only (comparable to the No Action Alternative), the Planned Action
Area [Midway Subarea] water consumption would increase from 0.4 to 0.6 [1.7] MGD. With capital
improvements anticipated in the 2008 Water System Plan in place, the Highline Water District
would be able to accommodate the growth anticipated under Phase 1 growth.

48
Sewer
Midway Sewer District
Under the combined Phase 1/Phase 2 growth levels (similar to the Proposal/FEIS Review
Alternative), the Midway Sewer Districts portion of the Midway Subarea would see an increase in
development, particularly in the Midway Planned Action Area [northern Transit Oriented
Community] portion of the service area, similar to that anticipated for the Pacific Ridge development
in the City of Des Moines. Using flow rates described in the 2008 Midway Sewer District Plan of 70
gallons/capita/day for residential and 40 gallons/employee/day for employment, this would
increase wastewater flows to the Midway Sewer system from approximately 0.42 MGD under
existing conditions to 1.76 MGD in 2030. Adding in the additional 1.34 MGD of sewage flow
anticipated under the combined Phase 1/Phase 2 growth levels would bring the districts
wastewater treatment plant up to 8.23 MGD of its 9.0 MGD capacity.
The Midway Sewer Districts consultant modeled the new growth anticipated in Kents portion of
the Midway Subarea. Based upon this analysis, the Midway Sewer Districts infrastructure is capable
of handling the increased flows resulting from the full growth anticipated in the Midway Subarea
Plan within the district. However, the model showed one area along 20th Avenue S, between S 244th
Street and S 244th Place (located west of the Midway Subarea boundary) that would be at or a little
over capacity with new flows. The district will monitor as development occurs to see if the capacity
issues actually do develop as predicted in the model, and implement facility improvements as
needed for this 400-foot section of an 18-inch pipe (Kase pers. comm.).
Considering Phase 1 growth levels only (similar to the No Action Alternative) flow would increase
above the 0.42 MGD under existing conditions to 0.52 [0.6] MGD. Existing upgrades to the sewer
collection system and pump stations contained in the 2008 Sewer System Plan would be adequate to
accommodate anticipated future flows in the subarea under Phase 1 growth levels.
City of Kent Sewer
The City provides sewer service to the area in and around the Kent Highlands property. Because the
bulk of this property is an undeveloped former landfill site, it is likely that sewer lines would need to
be extended to serve portions of the anticipated development.
Under the combined Phase 1/Phase 2 growth levels, the Kent Highlands part of the Midway Planned
Action Area [Midway Subarea Plan] is expected to have more than 3,900 households and 550 jobs
located on it, in comparison to 6 households and 70 jobs under existing conditions. Since this large
of an increase in population and employment was not anticipated in developing existing wastewater
infrastructure, it will result in the need to extend sewer facilities and provide upgrades to existing
sewer facilities in the vicinity of the Kent Highlands.
Considering Phase 1 growth levels only, only about 26 households and 235 jobs are anticipated. This
is not expected to result in a significant impact. The City will review development proposals for
consistency with its service requirements.

49
Stormwater
The Kent Stormwater Utility provides service to the Midway Planned Action Area [Midway Subarea].
Growth under the combined Phase 1/Phase 2 growth levels is expected to result in higher levels of
impervious surfaces compared to existing conditions, as vacant land is developed over the planning
period. As impervious surface area increases, there would be a greater need for stormwater facilities
to convey and store stormwater flows. However, because most of the Midway Planned Action Area
[Midway Subarea] is already developed with buildings, surface parking, and other impervious
surfaces, with little undeveloped land currently in existence, increases in impervious surfaces are
expected to be small. New development would be subject to the Citys stormwater regulations. The
City Stormwater Utility adjusted the standards of the 2002 Surface Water Design Manual (a
modified version of the 1998 King County Surface Water Design Manual) to meet the equivalency
requirements of the Washington State Department of Ecologys Stormwater Management Manual for
Western Washington (2005). (See also the discussion of impervious surface and water quality
under the Natural Environment discussion above.)
Considering Phase 1 growth levels only, there would be slightly higher levels of impervious surfaces
compared to existing conditions, and compliance with City codes would be required.
Solid Waste
Under the combined Phase 1/Phase 2 levels of growth, the Midway Subarea, including the Planned
Action Area [northern Transit Oriented Community], is expected to experience a six-fold increase in
households and more than four times the amount of employment over the planning period, with a
consequent increase in solid waste generation. Using the 3 pounds per capita per day solid waste
generation rate used by City and regional entities, the Midway Subarea would produce
approximately 21,565 tons of solid waste per year compared to an estimated 3,850 tons of solid
waste per year in the 2006 base year. Phase 1 growth levels alone would produce approximately
5,055 tons of solid waste per year.

The Midway Planned Action Area [Midway Subarea] is anticipated to experience significant growth
during the planning period. The projected population and employment increases would increase
the need for public services and utilities serving the Midway Planned Action Area [Midway Subarea].
Given the length of the planning period, and the amount of time for redevelopment of the Planned
Action Area [Midway Subarea], the City and service providers have an opportunity to update plans
and respond accordingly. With application of mitigation measures identified below, no identified
significant unavoidable adverse impacts are anticipated.
Mitigation Measures

50
Police
The City shall require planned action applicants to demonstrate how they have achieved site
design that complies with the City of Kent Downtown Design Review Guidelines (November
2003) Site Design for Safety Standards (Section I., Site Planning, Subsection E. Site Design for
Safety), or equivalent standards to result in security-sensitive design of buildings, lighting, and
landscaping.
The City shall monitor response time LOS in the designated Planned Action Area over time and
respond to any decreases in LOS standard through adding or adjusting police facilities and
staffing to serve the growing population.

The Kent Fire Department Regional Fire Authority (RFA) shall monitor growth and demand for
its services in the designated Planned Action Area over time through its regular planning and
budgeting process. Revenues from increased property values could help offset some of the
additional expenditures for providing additional responses to incidents.
The RFA shall utilize its Concurrency Management Plan and Mitigation and Level of Service
Contribution policy to help assess and mitigate the impacts of new development on fire facilities
and resources, and provide adequate funding necessary to maintain LOS.

The City will require planned actions to provide both of the following:
Recreation space for leisure, play, and sport activities at a ratio of four hundred fifty (450)
square feet per dwelling unit. A recreation space may consist of a playground, sport court; or
any other recreation facility proposed by the applicant and approved by the parks and
community services director.
A pedestrian-oriented plaza or open space at a ratio of one percent (1%) of the site or
building area, whichever is greater. A pedestrian-oriented space is one that contains visual
and pedestrian access (including barrier-free access) to the abutting structures from the
public right-of-way or a nonvehicular courtyard; paved walking surfaces of either concrete
or approved unit paving; on-site or building-mounted lighting providing at least four (4)
foot-candles (average) on the ground; and seating area.
Through a negotiated voluntary agreement the City may apply the above parks and recreation
measures to a specific project and allow one or more of the following: 1) a portion of recreation
space to be a community building; 2) a portion of the recreation space to be accomplished
offsite; 3) a higher or lower ratio dependent on the demand caused by the proposed
development; and 4) a fee-in-lieu of providing the recreation or pedestrian-oriented space.

51
Schools
See Public Agency Actions
Sewer
Development applicants shall complete the sewer availability certificate in the Attachment, and
shall submit it to the City and the Midway Sewer District, where applicable, to determine
whether any improvements are required.
Planned Action developers shall be required to meet infrastructure standards and requirements
of the appropriate sanitary sewer service provider.
Stormwater
The City shall apply the requirements of its adjusted and adopted Stormwater Manual to new
planned action development. See also Natural Environment mitigation measures regarding LID
practices.
Solid Waste
See Public Agency Actions.
Noise
Significant Impacts
Redevelopment within the Midway Planned Action Area [Midway Subarea] would require
construction activity, which would produce temporary increases in noise levels. The City noise
ordinance would prevent the nighttime construction activities and commercial operations from
causing noise impacts at existing residences. However, temporary daytime construction activity is
exempt from the City noise ordinance limits and could cause annoyance and speech interference at
outdoor locations adjacent to the construction sites and could cause discernible noise for several
blocks away from the development site.
In addition, increases in commercial operations and vehicle travel are also expected to result in
increased noise impacts within the Midway Planned Action Area [Midway Subarea]. In addition,
RapidRide service, future light rail service, and the proposed growth may result in increased
demand for bus service in the subarea. Therefore, the proposed mixed-use residents and existing
residences adjacent to SR 99 and the future light rail station would potentially be affected by the
noise generated from increased traffic, buses and the future light rail.

With implementation of mitigation measures noted below, no studied alternative would cause
significant unavoidable adverse noise impacts in the Midway Planned Action Area [Midway
Subarea].
52
Mitigation Measures
In addition to Applicable Regulations and Commitments, the following mitigation measures shall be
applied to planned actions.
Construction Noise Abatement

If nighttime construction operations are required, then the City shall consider noise abatement
on a case-by-case basis to ensure that noise levels at the nearest residences would be within the
Citys nighttime noise limits. According to the City code, temporary daytime construction
activities are exempt. Regardless, based on site specific considerations at the time of
construction permit review, the City may at its discretion require all construction contractors to
implement noise control plans for construction activities for daytime activities.
Construction noise could be reduced by using enclosures or walls to surround noisy stationary
equipment, installing mufflers on engines, substituting quieter equipment or construction
methods, minimizing time of operation, and locating equipment as far as practical from sensitive
receptors. To reduce construction noise at nearby receptors, the following mitigation measures
will be incorporated into construction plans and contractor specifications:
Locating stationary equipment away from receiving properties will decrease noise from that
equipment.
Erecting portable noise barriers around loud stationary equipment located near sensitive
receivers will reduce noise.
Limiting construction activities to between 7:00 a.m. and 10:00 p.m. will avoid sensitive
nighttime hours.
Turning off idling construction equipment will eliminate unnecessary noise.
Requiring contractors to rigorously maintain all equipment will potentially reduce noise
effects.
Training construction crews to avoid unnecessarily loud actions (e.g., dropping bundles of
rebar onto the ground or dragging steel plates across pavement) near noise-sensitive areas
will reduce noise effects.
New Commercial Operation Noise

At its discretion, the City may require all prospective planned action developers to use low-noise
mechanical equipment adequate to ensure compliance with the Citys daytime and nighttime
noise ordinance limits. Depending on the nature of the proposed development, the City may
require the developer to conduct a noise impact study to forecast future noise levels and to
specify appropriate noise control measures. Compliance with the noise ordinance would ensure
this potential impact would not be significant.

53
Traffic Noise Mitigation
Although traffic noise is exempt from City noise ordinance, based on site-specific considerations,
the City may, at its discretion, require new residential development to install triple-pane glass
windows or other building insulation measures using its authority under the Washington State
Energy Code (KCC 14.01.010).
Bus Stop Noise Mitigation

Buses decelerating, accelerating, and idling at bus stops would increase ambient noise and could
impact existing and future residences immediately adjacent to these bus stops. The City could
mitigate the impacts by not locating bus stops adjacent to residential land uses. If bus stops
have to be installed in front of residential land uses, the City may, at its discretion, mitigate the
impacts by requiring installation of triple-pane windows at these residential developments
during permit review.
Light Rail
The anticipated light rail segment would increase ambient noise and could affect existing and
future residences adjacent to the station and rail track. Sound Transit will conduct a project
environmental review for extension of light rail and will provide reasonable and feasible noise
mitigation to reduce noise levels at affected properties to below the Federal Transit
Administration (FTA) or City criteria, similar to that provided for the Airport Link. The main
form of noise mitigation for transit projects is installing noise barriers along the elevated
guideways or park-and-rides. In accordance with Sound Transit policy, if noise walls are not
considered a reasonable and feasible form of noise mitigation, sound insulation of affected
structures may also be considered (Sound Transit 2005).

54
Attachment: Sewer Availability Certificate

55
56
Appendix B
Draft Midway Subarea Plan
ATTACHMENT A - LUPB PUBLIC HEARING 11/22/10
41
CITY OF KENT
Midway Subarea Plan
Ordinance No. ### - Effective ####

42
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43
ACKNOWLEDGEMENTS
The City would like to acknowledge and thank those who contributed to the development of Envision Midway
(the Midway Subarea Plan). In addition to those listed below, numerous individuals provided insight, expertise,
and other contributions that informed this plan.
Kent City Council
Mayor Suzette Cooke and John Hodgson, Chief Administrative Officer
Jamie Perry, President; Debbie Raplee, former President; Elizabeth Albertson; Ron Harmon; Dennis Higgins; Deborah
Ranniger; Les Thomas; Tim Clark, former Councilmember; Bob OBrien, former Councilmember
Kent City Staff
Ben Wolters, ECD Dir, Fred Satterstrom, AICP, Planning Dir and Gloria Gould-Wessen, AICP, GIS Coordinator/Planner
Other Kent City Staff: Charlene Anderson, AICP, Plng Mgr; Kurt Hanson, Econ Dev Mgr; Bob Hutchinson, Bld Official;
Renee Cameron, Admn Asst; Katie Heinitz, Plnr; Matt Gilbert, Prncpl Plnr; Diamatris Winston, Plnr; William D. Osborne,
AICP, Plnr; Ion Arai, Plng Intern; Pamela Mottram, Admn Sec; Miya Hadlock, Plng Intern; Tim Laporte, Public Wks Dir;
Chad Bieren, City Engr; Mike Gillespie, Engrg Dev Mgr; Mark Howlett, Design Engrg Mgr; Mike Mactutis, Env Engrg Mgr;
Kelly Peterson, Env Cnsrvtn Supervisor; Beth Tan, Env Engr III; Steve Mullen, Trnsp Engrg Mgr; Cathy Mooney, Sr. Trnsp
Plnr; Kurt Palowez, GIS Spvsr; Sarah Burns, GIS Analyst; Jeff Watling, Prks and Community Srvs Dir; Katherin Johnson,
Hsg & Hmn Srvs Mgr; Merina Hanson, Sr. Hsg & Hmn Srvs Plnr; Jason Johnson, Hsg & Hmn Srvs Plnr; Tom Brubaker,
City Atty; Kim Adams Pratt, Asst City Atty; Robert Nachlinger, Fncl Srvs Dir; Robert Goehring, Fncl Srvs Audit Mgr; Brenda
Jacober, City Clk; Mike Carrington, Info Tech Dir; Curt Ryser, Systems Mgr; Dea Drake, Multimedia Mgr; John Humphreys,
frmr Systems Grp Mgr; Pattie Garcia, Creative Art Dir/Coordinator; Kevin Casault, frmr Sr Systems Specialist; Sacha
Coughran, frmr Multimedia Spclst II; Seth Frankel, frmr Video Prgm Coordinator; Mark Ciavarella, Multimedia Spclst II; Jim
Schneider, Fire Chief; Jon Napier, Div Chief/Fire Marshall; Steve Strachan, Police Chief; Brendan Wales, Police Officer;
Mark Gustafson, Police Sgt; Bob Holt, frmr Police Lieutenant; Cesi Velez, Public Ed Specialist
Kent Land Use & Planning Board Members
Dana Ralph, Jack Ottini, Navdeep Gill, Jon Johnson, Aleanna Kondelis-Halpin; Steve Dowell, Barbara Phillips and Alan Gray
Des Moines City Council & Administration
Mayor Bob Sheckler, Tony Piasecki, City Manager, Scott Thomasson, Carmen Scott, Dan Sherman, and Dave Kaplan
Des Moines Staff
Grant Fredricks, Director of Planning, Building and Public Works and Denise Lathrop, AICP, Planning Manager
Other Des Moines City Staff: Steve Schenzel, GIS Coordinator; Jason Sullivan, Land Use Planner II; Brandon Carver,
Associate Transportation Engineer; Kevin Tucker, Police Commander; Cass Prindle, Planning Agency Member
Stakeholder Participants
Sam Wentz, GIS Coordinator, WA State Dept. of Commerce formerly Community Trade & Econ Dev; City of Sea Tac -
Dennis Hartwick, & Michael Scarey- Sr Plnrs; Scott Kirkpatrick, Transit-Oriented Dev Mgr, Eric Chipps, Prj Mgr, Office of
Planning & Policy, and David Goldberg, Project Dev Coordinator with Sound Transit; Tom Washington, Sr. Transportation
Plnr, Urban Plng Ofc, and Susan Everett, Engr Mgr & Urban Corridors Prj Dev Engr with WSDOT; Katie Chalmers, Transp
Plnr II, and Jack Latteman, Transportation Plnr with King County Metro; Larry Yok, VP Admn Srvcs, Pete Babington, Dir of
Fac, Jack Birmingham, Pres, and James Peyton, Community Educ - Highline Community College; Rod Sheffer, Proj Mgr,
Fac Srvs, Highline Schl Dist #401; Doug Corbin, Community Srvs Puget Sd Energy; Norman Abbott, Dir Growth Mgmt
Planning, Puget Sound Regional Council; Melvin Roberts and David Hoffman with Kent Bicycle Advisory Brd; Kathi Jones,
The Lakes Nghbrhd Assoc; Bridget Myers, Salt Aire Hills Ngbrhd Assoc, Bob Loeliger, West Hill Ngbrhd Cncl; Bob
Larson, LA Plaza Prj Mgr, Clearpath, LLC; Matthew Chan, Prop Owner, Sunway Srvs; John Muscatel, Prop Owner, Dollar
Store; Steve Rodrigues, Olympic Forum; Scott Thomson, Strider Capital Mgmt Group; Sarah Campbell, Mgr Key Bank;
and Randy Welk Mgr, Fred Meyer
Developers Forum Participants
Robert Slattery, Mondo Land Development, Peter Battuello, Steve Fuller, and Kurt Easthouse with Parametrix; Robert
Cryan -Cryan Properties LLC; Rich Wagner with Baylis Architects; Ryan Hitt Dev Mgr with Tarragon; Andy Langsford with
Venture Real Estate Group; Sean McDonald, Program Dir with City of Seattle Public Utilities; Karen Williams Suburban
Cities Outreach Dir with Housing Dev Consortium; Tory Laughlin-Taylor, Deputy Dir, Housing Resources Group; Dan
Rosenfeld, with Urban Partners; Dorothy Lengyel, Exec Dir with D.A.S.H. & University Heights Community Ctr; Catherine
Benotto with Weber Thompson; Alex Martinac with CBRE Real Estate; Gary Young with Polygon NW; Bruce Lorig with
Lorig Assoc; Brian Steinburg with Weber Thompson Architects; Dawn Banfield, West Hill Community; Dorsey Chester,
Chester Dorsey Auto Salons; Mark Gulbranson, Deputy Exec Dir, Puget Sound Regional Council; Andrea Johnson, Exec
Dir Facilities with Highline School Dist; Lim Hau Kim, Prop Owner; Dallas Radford, VP, Greenfield Park Community; and
Brad Corner- Prop Owner
Consultant Team
Eric Schmidt & David Saxen with Cascade Design Collaborative; and Fauna Doyle with Berk and Associates
Thank you!
44

45
Table of Contents
Acknowledgements i
Chapter One: INTRODUCTION 1

Purpose 2
Overview 3
History of Development 4
The Present 5
Chapter Two: EXISTING CONDITIONS 7

Environmental 7
Demographics and Economics 9
Population Trends 10
Housing Types and Values 10
Household Income and Jobs 11
Community Services 12
Police and Fire 12
Water and Sewer 12
Education 12
Parks and Open Space 12
Library 13
Growth Forecast 15
Chapter Three: THE VISION 22

The Next Generation Midway in 2050 22
Building Partnerships and a Vision 25
Vision Process 25
Visioning Products 26
Visioning Outcomes 32
Chapter Four: FRAMEWORK FOR MIDWAY 36

Midway Subarea Plan Goals & Policies 37
Overall Goal 37
Land Use 37
Urban Design 40
Housing 44
Transportation 45
Park & Open Space 49
Implementation 51
Inter-jurisdictional Coordination 51
Land Use Plan Map 52
46
List of Figures
Figure 1 Drainage Basins and Existing Wetlands 8
Figure 2 Community Services 14
Figure 3 Envision Midway Three Light Rail Station Concepts 29
Figure 4 East SR-99 Light Rail Station Option 31
Figure 5 Land Use Plan Scenario 4.0 34
Figure 6 Land Use Plan Map 53
List of Tables
Table 1 Housing and Employment 16
Table 2 2005 Baseline Land Uses by Kzone 19
Table 3 2031 PSRC Forecast Land Uses by Kzone 19
Table 4 Capacity Based on Land Use Scenario 4.0 21
Appendix A Employment and Housing Growth 17

(note this will move to the back of the document when final)
47
Midway Subarea Plan
Chapter One
Introduction
The Midway Subarea Plan (the Plan) conveys a range of actions that prepares the
area for the future high capacity light rail transit. The Plan illustrates the potential
of Midway and is intended to inform decisions of public and private entities. The
implementation of the Plan will be through design guidelines, development
regulations and incentives, capital investments, and other public and private
strategies along the transportation corridor of Pacific Highway South and for the
transit nodes. Kent will complete a Planned Action Ordinance to encourage
redevelopment in the area, most particularly around the light rail transit station
node anticipated to be located in the vicinity of Highline Community College.
The Midway Study AreaSubarea (the Subarea) contains the commercial spine for
Kents West Hill residents, as well as residents from the City of Des Moines. The
shared geography and common interests in the future of Midway prompted
leadership from both communities to engage in a collaborative visioning effort,
called Envision Midway, which resulted in the Midway Subarea Plan. The City of
Midway Subarea Plan/Revisions post 11/23/09 LUPB Public Hearing 1

48
Des Moines is developing a similar document. Together these planning documents

will guide the cities in creating regulations that are consistent and that will facilitate
future redevelopment, particularly for property owners east of Pacific Highway
South (SR-99). The overall thrust of the Midway Subarea Plan is a new direction
toward a walkable compact community, consisting of a mix of uses that thrive in an
economically and environmentally sustainable future supported by high capacity
transit. The existing highway commercial corridor will continue to support retail
and burgeoning light industrial uses while accommodating pedestrian and transit
users.
This document contains the following sections: Introduction of The the Plans
Purposepurpose,; with an Overview overview of the study areaSubarea and history
of development patterns; Existing Conditions of the environment, demographics
and economics, community services, and land use growth forecast; The Vision
starting with a look into the future followed by details of the public outreach
process and the results; and Framework for Midway which includes the Policies
policies and Goals goals for the Midway Study AreaSubarea.
Purpose
Envision Midway Mission Statement:

To transform the Midway community into a sustainable urban area
which enhances commercial development and optimizes its
geographic location, wide range of transportation options,
educational institutions, and views.
The prospect of high capacity light rail transit prompted the Cities of Kent and Des
Moines to undertake a major planning effort called Envision Midway. The mission
and goals of Envision Midway were established collaboratively by the City Councils
of the two cities and guided extensive public involvement. The outcomes from the
visioning efforts of Envision Midway guided the Midway Subarea Plan.
Envision Midway Goals:

1. Provide a mix of land uses that increase revenues, job opportunities, and
housing choices.
2. Reconcile development standards along the border between the Cities of
Kent and Des Moines to be consistent and reflect the vision for the study
area.

49
3. Provide for public participation in the development of land use policies,

development regulations, and implementation strategies within the study
area.
4. Provide appropriate land uses and regulations that support Bus Rapid
Transit within the Pacific Highway corridor.
5. Identify preferred alignments for light rail and the associated station and
stop locations within Kent and Des Moines.
6. Ensure design that provides a safe and inviting pedestrian environment.
Overview
The Midway Subarea Plan (the Plan) focuses on an area is located along the
extreme western portion of Kent along a north/south ridge line sandwiched
between the Duwamish/Green River Valley and Puget Sound. The Subarea abuts
the City of Des Moines along the
entire western border. It also shares
boundaries with the Cities of SeaTac
and Federal Way, and
Unincorporated King County. The
Subarea is bound to the north by SR-
516 (a.k.a., Kent-Des Moines Road)
and to the south by South 272nd
Street. Generally the landscape is
gently rolling with the highest point
located in the northern third of the
study areaSubarea, affording the
potential to capture views of Puget
Sound and the Olympic Mountains to
the west, and views of the Kent
Valley, Mt. Rainier and Cascade
Mountains to the east (see Figure 1
Midway Study Area). The Midway
Study Area abuts the City of Des
Moines along the entire western
border. It also shares boundaries
with the Cities of SeaTac and Federal Way, and Unincorporated King County.
The name Midway was a marketing tool devised in the 1930s to denote the areas
location halfway between Seattle and Tacoma. Location remains a key asset for

50
Midway. It is less than 5 miles south of Seattle-Tacoma International Airport.

There is direct access to Interstate-5, connecting to Seattle, Tacoma and beyond.
The Kent industrial valley is located minutes away off SR-516, as are recreational
opportunities of golf, ice skating, and entertainment at the ShoWare Center. To the
west is the City of Des Moines large marina and beach park along Puget Sound.
Completion of the I-5 SR-509 Corridor Completion and Freight Improvement
Project will link the Port of Seattle to Midway.
Different portions of the study area have historically been known by different
names, including Midway, Saltair Hills, and Woodmont. These neighborhood
boundaries were never formalized and so sometimes overlapped. Midway is
centered around the intersection of Kent-Des Moines Road and Pacific Highway
South and runs south to Saltair Hills. Saltair Hills is defined by the single-family
neighborhood west of SR-99 between South 248th Street and South 252nd Street
and was part of the 1958 Saltair Annexation. The southern half of the study area is
part of the area known as Woodmont, which extends between S 252nd Street and
beyond South 272nd Street.
Highway 99 (a.k.a. Pacific Highway South) defines Midway. The highway drew
commerce to its edges, and like its northern counterpart Aurora Midways street
network creates large blocks ranging from 1/2 to 3/4 of a mile long. Some
properties are so large there are no streets other than direct access off SR-99.
Interstate-5 also serves the Midway Study Area, with future connections provided
by an extension of SR-509 from nearby Seattle-Tacoma International Airport,
approximately 4 miles to the north.
History of Development:
The name Midway was a marketing tool used to denote the areas location halfway
between Seattle and Tacoma. Highway 99 (a.k.a. Pacific Highway South or SR-99)
defines Midway. Back in the 1930s and 1940s, the new highway brought people
from around the region to the Spanish Castle (located at the intersection of SR-99
and Kent-Des Moines Road [SR-516]) for a
night out with Gordon Greens Orchestra. The
Spanish Castle continued operating into the
late 1960s where it became a place for teens
to dance to local bands like The Wailers, Paul
Revere and the Raiders, Sonics and national
acts like Jerry Lee Lewis and the Beach Boys.
Jimi Hendrix played there as a teenager and

51
later wrote Spanish Castle Magic, a hit in the 1960s. Another icon was the Midway
Drive-in Theater which operated from the 1940s to the mid-1980s. The huge neon
sign on the back of the gigantic screen was as iconic regionally as the Hollywood
sign in Los Angeles.was the largest single screen drive-in theater in the area. Once
closed, it the drive-in theater became an off-site parking lot for Highline Community
College students and on weekends a huge flea-market.
The Midway area has constantly been evolving. Many of the historic motels and
small businesses that once served the weary traveler have made way for the new a
newer auto-oriented development, namely strip malls and big box stores with large
expanses of parking. The most recent historic use to give way to progress was the
Midway Drive-in Theater. Its huge neon sign was as iconic regionally as the
Hollywood sign in Los Angeles. Along with the typical auto-oriented retail shopping
areas, one will find there are light industrial operations, outdoor storage yards,
long-haul truck sales and service, mobile home parks and a couple of small
apartment complexes. Highline Community College (HCC) is tucked behind the
commercial corridor in the City of Des Moines and is a major presence serving
18,000 students and providing 1,200 jobs., located off S 240th just west of SR-99 in
the City of Des Moines, was dedicated in January 1963 and recently Recently HCC
completed a master plan to grow the campus in partnership with Central
Washington University. There are two (2) closed landfills located in the Subarea
(i.e., Midway and Kent-HighlandsKent Highlands Landfills). They are that are
being prepared for reuse and redevelopment by the property owner, City of Seattle
Public Utilities (SPU).
The Present:
A new wave of redevelopment in Midway started approximately three (3) years
agoin 2006 when Kent (along with adjacent cities) completed the Pacific Highway
Rehabilitation Project. Kent invested $21 million dollars to build sidewalks, street
trees, pedestrian scale lighting and a re-designed left-turn lane that gives way to a
planted median, turning SR-99 into a safe
and attractive roadway. Two (2) HOV
lanes were added to the existing five (5)
lane highway for the purpose of
accommodating King Countys Transit
Now program and its Bus Rapid Transit
(BRT) system. Scheduled to begin service
Beginning in October 2010, BRT uses
technology to provide a fast and reliable

52
transit system that connects riders with the SeaTac Airport Light Rail Station. One
of the first redevelopment projects was a Lowes Home Improvement super store
where the old Midway Drive-in was located. Fred Meyer at South 252nd Street
remodeled their existing store. Both projects constructed additional retailing space
that abuts the highway for a more pedestrian-friendly atmosphere. There have also
been a couple of 3 Three-story office buildings have been constructed one to
accommodate Highline Community College and the other housing the Carpenters
Union.
The catalyst for the next phase of development in Midway will be the expansion of
Sound Transits light rail service south from SeaTac Seattle-Tacoma International
Airport. Funding to expand light rail to 55 miles was approved by Central Puget
Sound voters in November, 2008. The
additional 36 miles will extend rail north
from Seattle to Lynnwood, east to the
Redmond Overlake Transit Center, and
south from the SeaTac Airport Station to
Star Lake/Redondo Transit Center located
at South 272nd Street. Expansion of the
southern route is expected sometime in
the next 10 to 20 years.

53
Chapter Two
Existing Conditions
A thorough examination of existing conditions is essential to understanding
opportunities and challenges in the Midway Study AreaSubarea. This section
examines the environmental conditions, followed by demographics and economic
conditions, overview of community services, and concluding with existing land uses
and regulationsgrowth forecasts.
Environmental
Midway The Study AreaSubarea is largely developed, but there are areas that are
restricted from development due to steep slopes, wetlands, or undevelopable closed
landfills. Generally, the study areaSubarea sits at a high point of a gently
undulating ridge that is contained by Puget Sound approximately 1 one mile to the
west and the Kent Valley to the east. The steep slopes and unstable soils on the
northeastern edge of the study areaSubarea have constrained development and
this area remains wooded with predominately deciduous second growth trees. The
topography of the study areaSubarea provides view opportunities in some locations.
There are two (2) large former
landfills that provide a sense of open
space due to the open grassy fields
and undeveloped nature of these
properties. The Midway Landfill is
surrounded by development and can
be seen from I-5. The Kent-
HighlandsKent Highlands Landfill,
however, is contiguous with the
wooded steep slopes on the eastern
edge of the study areaSubarea and
adds to a relatively large habitat.
There are natural open spaces within the study areaSubarea that contain wetlands
and are a part of the Puget Sound and Green River Watersheds. The flows of these
watersheds are illuminated by their names and contain two (2) basins related to the
Midway Study AreaSubarea (see Figure 2 1 Midway Subarea Drainage Basins and
Existing Wetlands). The Puget Sound Watershed is located west of SR-99 to South
240th Street where it runs to the east, taking in the subarea to the south.

54
Figure 21: Midway Subarea - Drainage Basins and Existing Inventoried

Wetlands.

55
Within this watershed is the McSorley Creek Drainage Basin consisting of 811 acres
with 25.7% (~209 acres) as impervious.1 There is one wetland in the study
areaSubarea located off SR-516. It that is considered the headwaters of Massey
Creek and flows into Puget Sound. A rather large wetland (> 10 114 acres) is
located just outside the Subarea along the southeastern corner. It is the
headwaters for McSorley Creek and flows through Saltwater State Park into Puget
Sound. Both are wooded wetlands. The Green River Watershed is located east of
SR-99 to South 240th Street and then continues south generally along the east side
of Military Road. This watershed contains the Midway Creek Drainage Basin which
consists of 933 acres with 34.6% (~ 35 acres) as impervious. At the base of the
Kent-HighlandsKent Highlands Landfill are associated wetlands; however, they are
outside the study areaSubarea.
Pacific Highway South (SR-99) runs through the Midway Study AreaSubarea, and
Interstate-5 flanks much of its eastern border. Seattle-Tacoma International
Airport is located 4 miles to the northwest. The noise and pollution from the
various modes of transportation moving through the study areaSubarea have an
impact. Other pollutant sources are the closed landfills. Seattle Public Utilities
have created and implemented a mitigation plan for the toxins within the landfills,
and the United States Environmental Protection Agency has not yet taken them off
the National Priorities List of hazardous waste sites. Additional properties within
the study areaSubarea have been identified on State and Federal brownfield lists.
To date, there has been no assessment or testing of these additional properties or
testing conducted to better understand their status as brownfields.
Demographics and Economics
South King County plays a major role in the economic vitality of the Puget Sound
BasinRegion, and the City of Kent is a large contributor to that prosperity.
However, economic and demographic information specific to the Midway Subarea is
limited. Demographic information is available from the 2000 U.S. Census and the
areas economic vitality can be assessed from business license data. This section
attempts to provide an understanding of the demographics and economics of the
Midway Study AreaSubarea.
1
City of Kent Drainage Master Plan September 2008Surface Water Design Manual
Storm Drainage Service Area, 2002.

56
The City of Kent recently participated in a study that looked at growth rates of key
economic indicators as well as housing affordability and employment
demographics.2 The analysis collected 2008 economic and financial statistics from
business databases as well as state and local government records and compared
the South King County region as a whole to all of King County and the State of
Washington. The data on Kent represent true growth rather than growth as a
result of annexations. The following provides a profile of the City of Kent based on
specific indicators, along with information on Midway from the 2000 U.S. Census.
Population Trends:
Kent is the second sixth largest city in the State and the third largest city in South
King County with an estimated population of 88,380114,000 (in July 2010).and in
In 2008, South King County was home to 25.9% of the total population in King
County. Between 2006 and 2008, Kents population grew by 1.55%. During the
same time, King Countys population grew by 2.66%. The median age for residents
in Kent is 34.91 years.
Based on the 2000 Census, the median age in the Midway Study areaSubarea was
31.8 years. It is lower than the citywide data represented above. There are is a
high percentage of families with young children living in the study areaSubarea. As
the population in Kent has grown, one of the most notable changes has been an
increase in ethnic diversity. As often occurs with the settlement patterns of recent
immigrants, there are concentrated communities of kinship and social networks.
The study areaSubarea is home to a growing Latino population. The
Hispanic/Latino population citywide is approximately 7-8% of the total population,
but and nearly 20% within the study areaSubarea.
Housing Types and Values:

In 2008, Kent had 36,045 housing units. Kent grew between 2006 and 2008 by
0.43% with single-family units growing at an annual rate of 1.34%. During the
same time, King County was adding housing at an annual rate of 0.63%. The
percent of owner occupied housing units (46.7%) and renter occupied housing units
(49.08%) in 2008 is skewed to rental units, which include apartments, rented
condominiums and single-family homes.3 New construction of multi-family housing
units in Kent (0.15%) is very slow compared to South County as a whole (4.59%).
2
South King North Pierce County Economic Region ECONOMIC ANALYSIS & STATISTICAL
PROFILE, Herbert Research, Incorporated September 2008.
3
These statistics do not include mobile home ownership.

57
The median value of all owner-occupied housing units in the City of Kent was
$281,566 in 2008.4
Although there is significant single-family housing to the east and west, there is
little housing within the Midway Study AreaSubarea itself, and all could be
considered affordable. There are seven (7) mobile home parks with 222 238
spaces for mobile homes or recreational vehicles and eleven (11) associated
apartments. There are five (5) six (6) apartment complexes consisting of 123 131
apartments. And there are seventeen (17) single-family homes, some of which are
used for housing and others used for business.
Household Income and Jobs:

In 2008, Hebert Research conducted a review and analysis of economic conditions
for South King County. The average mean household income within South King
County increased between 2000 and 2008 from $56,104 to $66,000, roughly 2.2%
annually. As of 2008, the City of Kents average mean household income was
$62,475, slightly lower than the overall average for South King County (i.e.,
$66,000). The share of total population in Kent that is of working age (i.e., 16-64)
is was 67%, similar to South King Countys working age population of 66.7%. The
number of jobs per working-age person in Kent is 1.27, a little higher than the
average for South King County at 1.22 jobs per person. In 2007, there were
76,758 jobs in Kent with 28% of those jobs in the manufacturing sector.
Based on the 2000 U.S. Census, the median household income in the Subarea was
$27,284 while the median household income in the City of Kent was $46,046. The
number of Subarea households living below poverty level in 2000 was 34.6% while
in the State of Washington it was 7.6%.
The employment sector within the Midway Study AreaSubarea is dominated by

retail and composed of mainly small businesses (with the exception of Lowes and
Fred Meyer). A small segment of employment is manufacturing (i.e., boat building,
cabinetry, counter tops) and there are a variety of rental businesses for fleet
vehicles, trucks and heavy equipment. In 2005, Puget Sound Regional Council
(PSRC) provided employment data that identified 3,721 jobs within the Subarea.
Highline Community College has a large presence in Midway and employs 1,217
1,200.
Based on the 2000 U.S. Census, the median household income in the study area
was $27,284 while the median household income in the City of Kent was $46,046.
4
Data are from the State Office of Financial Management.

58
The number of households living below poverty level in 2000 in the study area was
34.6% while in the State of Washington it was 7.6%.
Community Services
The Cities of Kent and Des Moines share a common yet irregular city boundary line
which complicates the provision of public services to the Midway Study
AreaSubarea. The line is an artifact of an unconventional annexation process that
would not be possible today. The result is that Des Moines and Kent Police and Fire
support each other in ways that ensure service is provided no matter on which side
the emergency call originates. Three school districts serve the Subarea and parks
are provided by several cities. The Community Services within the Midway Subarea
are illustrated in Figure 23.
Police and Fire:

The City of Kent has one substation located within the study areaSubarea and
another located nearby. The Midway Substation located at 25440 Pacific Highway
South provides a presence along SR-99. The West Hill Substation located at 26512
Military Road South houses police, as well as Fire Station 73 with three (3) engines.
Water and Sewer:

Highline Water District provides potable water to the Midway Study AreaSubarea.
Midway Sewer District provides sewer service to the area. Both agencies have their
headquarters located in the study areaSubarea at 23828 30th Ave South.
Education:
Kent, Highline, and Federal Way School Districts serve the area with public
education for grades K-12. Highline Community College serves a diverse student
population that is primarily commuter based.
Parks and Open Space:

There are several parks and recreational open spaces within or adjacent to the
study areaSubarea. Des Moines Parkside Park, located at S 244th Street and 25th
Avenue S is a 4.4 acre park with a play area for children and a walking path close
to an extensive wetland within the park. Saltair Vista Park, located at S 246th
Street and 26th Place in Kent, is a small neighborhood park with a play area for
children, picnic tables and benches. There are no parks located east of SR-99.

59
Library:
King County Woodmont Library is located at 26809 Pacific Highway South in Des
Moines and serves the residents of the Midway Study AreaSubarea.

60
Figure 23: Midway Subarea - Community Services.

61
Land Use ProfileGrowth Forecast
A measure of existing conditions requires examination of the potential for future

development. Development capacity is an estimate of the amount of development
that could be accommodated on vacant and redevelopable land. The allocation of
the regions growth targets is tied to the regional
growth strategy adopted in Vision 2040 which
builds a strategy for the central Puget Sound
region to absorb an additional 1.5 million more
people and 1.2 million jobs by 2040.5 The
strategy guides the location of future population
and employment growth with an increased role
for metropolitan cities and larger core cities like
Kent to accommodate growth.
The City of Kent has a target growth of 13,200 jobs and 7,800 housing units by
2031.6 The additional density encouraged by the Plan will ensure that high capacity
transit nodes will play a large role in absorbing future growth. For more details on
the methodology, data sources, and outcomes of employment and housing growth,
refer to Appendix A.
The methodology to determine the Subarea capacity is based on the Midway vision
and reflects a modified buildout at the transit nodes. The Plan proposes to increase
the capacity by changing the Land Use Plan Map, Zoning District Map, and
development regulations associated with the refinement of land use options
explored during Envision Midway (see Chapter Three: The Vision Visioning
Outcomes).
Most properties in Midways Transit Oriented Communities were considered

redevelopable with capacity determined by a modified buildout scenario of 5-story
structures with a maximum of 15-story structures (i.e., 200 maximum). The
model assumes little surface parking with most parking enclosed or underground.
Table 1 compares the Plan capacity for Midway with analysis conducted in 2006 for
the Transportation Master Plan (TMP) which established a 2005 Baseline and a 2031
5
Vision 2040 - Puget Sound Regional Council (PSRC), 2009.
6
King County Growth Targets (2006-2031) Countywide Planning Policies approved
January 25, 2010.

62
Forecast.7 The 2006 Baseline for Midway suggests a near 50/50 split of housing
and jobs. When compared with the 2006 Baseline, the TMP 2031 Forecast has a
14% increase in housing and a 71% increase in employment within Midway. The
Plan Capacity results in increases of 334% in employment and 517% in households
compared with the 2006 Baseline.
Table 1
Midway Housing and Employment
2005 Baseline TMP 2031 Forecast Plan Capacity

Housing Units 1,917 2,178 11,821
Employment 2,183 3,721 9,481
7
2006 Baseline was provided by Puget Sound Regional Council (PSRC) and represents
existing uses and the TMP 2031 Forecast was provided by PSRC utilizing forecasted
numbers from the State Office of Financial Management.

63
Appendix A
Employment and Housing Growth
This section takes a closer look at the distribution and location of various uses of
land within the Midway Study Area in order to better understand what exists today
and to consider the capacity for future growth in households and employment. The
Midway Study Area has been described as consisting of auto-oriented strip malls
and big box retailers; light industrial uses; sales and repair of automobiles, RVs,
long haul trucks, and heavy equipment; office; hotels; and affordable housing (i.e.,
mobile home parks and small apartments). Highline Community College, located in
the City of Des Moines, is a significant presence in Midway. The majority of these
land uses are housed within single story buildings with only a handful of multi-story
buildings serving the study area.
The City utilizes various data resources and methodologies to predict future growth
of employment and households. For the 2004 Comprehensive Plan, staff used
Buildable Lands Program methodology which generally determines capacity for
growth based upon land use intensity achieved by actual development within the
previous five (5) years. The 2008 Transportation Master Plan (TMP), adopted June
17, 2008 (Ordinance 3883), utilized existing and forecast employment and
household numbers from the Puget Sound Regional Council (PSRC). The PSRC
forecast relies on existing zoning and recent development to allocate forecast
numbers. The Midway Subarea Plan (the Plan) is utilizing utilizes a modified
buildout scenario that relies on capacity for new development based on the vision
for Midway rather than forecast or achieved development.
2006 Baseline and 2031 Forecast data of households and employment are provided
in two different formats. The 2006 Baseline (a.k.a. existing) data are provided as
geo-coded point data based on address and applied to Kzones.8 The 2031 Forecast
data are provided within the geography of PSRC Transportation Analysis Zones
(TAZ). Distribution of the 2031 Forecast to the smaller geography of Kzones is
accomplished mathematically based on percent of Kzone within a TAZ. The forecast
numbers reflect market trends within the region and do not represent the capacity
available to absorb households and employment. The most recent analysis of
8
Employment baseline data were provided by PSRC and originate from the Washington
State Employment Security Department, 2005 extract. Household baseline data were
extracted from housing permits submitted by the City of Kent as of 2005 and geo-coded by
PSRC. PSRC relied on existing zoning and recent development to determine growth forecast
to 2031. A Kzone is a geographic area used for transportation modeling.

64
employment and households citywide was conducted for the 2008 Transportation
Master Plan (TMP) and established a 2005 Baseline and a 2031 Forecast. The data
for the TMP were distributed to Kzones (i.e., Kents transportation analysis zones)
for the transportation model.
The Kzone geography was adjusted to reflect the Subarea. The Midway Subarea
Plan proposes new roads a pedestrian-friendly urban environment and additional
density of uses, within the Transit Oriented Community nodes, which requires new
roads. The the existing Kzones to be are divided into smaller areas. Kzones 405,
406, 407, and 408 are new. Kzones 87 and 110 are not completely within the
Subarea. The data from the 2005 2006 Baseline and 2031 Forecast used in the
TMP are distributed to these smaller areas based on percent area. of the new
Kzones to original Kzone
The 2005 baselineBaseline data (i.e., existing land uses) used in the TMP were
extracted from various sources. Employment baseline data were provided by PSRC
and originate from the Washington State Employment Security Department, 2005
extract, based on standard industrial classification code (SIC) or the North
American Industry Coding System (NAICS). PSRC also provided household baseline
data extracted from housing permits submitted by the City of Kent as of 2005 and
geo-coded by PSRC. The 2005 2006 Baseline land use data in Table 2 were
produced for the Transportation Master PlanTMP and suggest a near 50/50 split of
housing and jobs (see Table 1). Puget Sound Regional Council (PSRC), in
conjunction with the State Office of Financial Management (OFM), provided a
forecast for housing and employment used in the TMP. When compared with the
2006 Baseline, the 2031 PSRC Forecast in Table 3 has a 14% increase in housing
and a 71% increase in employment within the Subarea.

65
Table 21
Midway Study AreaSubarea
2006 Baseline Land Uses by Kzone
KZONE SFDU MFDU RETAIL FIRES GOV EDU WTCU MANU UNIV HOTEL
25 1 66 49 57 19 0 24 1 0 7
87 43 475 132 518 20 0 9 1 0 0
110 592 511 261 159 0 0 10 197 0 185
405 6 0 52 6 2 0 12 0 0 0
406 1 81 60 70 23 0 30 1 0 9
407 1 61 46 53 18 0 23 0 0 7
408 20 59 39 40 12 0 15 7 0 9
TOTAL 663 1254 639 903 94 0 123 207 0 217
TOTAL HOUSING 1,917

TOTAL JOBS 2,1831,966
Puget Sound Regional Council (PSRC), in conjunction with the State Office of
Financial Management (OFM), provided a forecast for housing and employment
used in the Kent TMP (see Table 2). When compared with the 2005 Baseline, the
2031 Forecast in Table 2 has a 14% increase in housing and a 78% increase in
employment within the study area.
Table 23
Midway Subarea
2031 PSRC Forecast Land Uses of Midway by Kzone
KZONE SFDU MFDU RETAIL FIRES GOV EDU WTCU MANU UNIV HOTEL
25 1 94 149 202 12 0 12 20 0 7
87 88 544 347 168 39 0 217 4 0 0
110 611 511 364 494 30 0 30 49 0 185
405 19 7 29 102 27 59 16 1 0 0
406 1 117 184 249 15 0 15 25 0 9
407 1 88 139 189 12 0 12 19 0 7
408 21 76 105 142 9 0 9 14 0 4
TOTAL 741 1437 1317 1545 145 59 312 131 0 212
TOTAL HOUSING 2,178

66
2005 Baseline and 2031 Forecast data are provided in two different formats. The
Baseline (a.k.a existing) data of households and employment are provided as
geocoded point data based on address and applied to Kzones. The 2031 Forecast
data are provided within the geography of PSRC Transportation Analysis Zones
(TAZ). Distribution of the2031PSRC household and employment forecasts to the
smaller geography of Kzones is accomplished mathematically based on percent of
Kzone within a TAZ. The forecast numbers reflect market trends within the region
and do not represent the capacity available within the zoning district to absorb
households and employment.
It should be noted that the Midway Study Area is not completely contained within
the geography of the Citys Kzone system. Kzone 25 and the new 405, 406, 407,
and 408 Kzones are completely within the study area, however, Kzones 87 and 110
are not.
The Midway Subarea Plan proposes to increase the capacity in the study
areaSubarea by changing the Land Use Plan Map, Zoning District Map, and
development regulations associated with the Transit Oriented Communities
refinement of land use options explored during Envision Midway (see Figure 3
Land Use Scenario 4.0). The allowable higher density of land uses will support the
future high capacity transit planned by Sound Transit. Compact high density uses
are envisioned for the transit node in the vicinity of Highline Community College.
The station location near South 272nd Street has far less potential for the City of
Kent to accommodate growth due to a large wetland that reduces the buildable land
area. within the City of Kent and relatively new development. Growth can will
likely occur within the Cities of Des Moines and Federal Way near the South 272nd
Street transit node.
The methodology to determine the Subareas capacity is based on the Midway

vision and reflects buildout at the transit nodes. Most properties are considered
redevelopable, with the exception of LaPlaza Shopping Center, Lowes, the new
office building housing Highline Community College and the gas stations. The
vision considers the norm to be 65-story structures with a maximum of 1615-story
structures. The model also assumes little surface parking with most parking
enclosed or under ground. One parking garage associated with the light rail station
is considered. Infrastructure at the Midway Transit Oriented Community near
Highline Community College assumes 6.3 acres of new parks, 9.3 acres in regional
surface water retention/detention facilities, approximately 2,601 linear feet of new

67
roads and sidewalks and 2,085 linear feet of improvements to 30th Avenue. There
is no new infrastructure at the 272nd Street transit node. Floor-area-ratio (FAR) is
applied to determine buildout for new construction, and land uses are divided into
residential (i.e., an average of 900 sq. ft. per dwelling unit) and employment (i.e.,
500 sq. ft. per job). The employment is distributed by sector based on PSRC
distribution percentages for the 2031 Forecast. The result is that the Midway Land
Use Scenario 34.0 (see The Vision for details) provides an increase of 329334% in
employment and an increase of 517% in households from the 2005 Baseline. This
capacity reflects a modified buildout that may not be absorbed by 2031 (see Table
34).
Table 34
Midway Study AreaSubarea
Capacity Based on Envision Midway Land Use Scenario 34.0 by Kzone
KZONE SFDU MFDU Retail FIRES GOV EDU WTCU MANU UNIV HOTEL
977
25 0 1330 302 1007 47 0 152 0 0 0
87 99 632 347 167 40 0 217 4 0 0
110 638 2003 446 272 32 0 303 138 0 186
405 0 3924 91 133 0 0 27 0 0 306
406 0 831 516 928 0 0 103 0 207 309
407 0 1693 544 744 0 0 143 0 0 0
408 0 671 177 1504 0 0 889 0 0 0
4725
TOTAL 737 11084 2423 4754 119 0 10334 142 207 802
TOTAL HOUSING 11,821

The State Office of Financial Management (OFM) and the PSRC recently revised the
2031 forecast of households and employment, establishing new targets for the
Central Puget Sound region to use for planning purposes in determining its ability to
absorb the projected growth. Presently, the The King County suburban cities along
with the Cities of Seattle and Bellevue, and King County are workingcollaborated on
the allocation of these 2031 growth targets to local jurisdictions. The resulting will
ultimately revise household and employment targets for Kent basically absorb all of
the capacity determined by using the Buildable Lands Methodology. Providing
additional capacity in the Midway Subarea will help Kents ability to absorb future
growth targets.

68
Chapter Three
The Vision
The vision for Midway was conceived from a series of workshops, meetings and
design charrettes held in 2008 and early 2009. This visioning effort brought
together diverse stakeholders to consider what the future would look like. Envision
Midway was both the process and the product, and the narrative below illuminates
the vision.
The Next Generation Midway in 2050
Midway continues to draw business, families and visitors because of its central
location in the Puget Sound Basin, convenient rapid light rail transit service, and
spectacular views. Midway is an interesting, inviting and safe urban
communityplace where buildings hug the edge
of generous sidewalks filled with people
mingling with neighbors and shop owners,
window shopping and sitting at open air
cafsthat allow commerce to spill out onto
them, making them interesting, inviting and
safe public spaces. Buildings are constructed
out of quality materials and designed with
consideration to human scale, while taking full
advantage of views to Puget Sound, the
Olympic and Cascade mountain ranges, Mt.
Rainier and the Kent Valley. With its emphasis
on architectural details, Midway is a safe,
comfortable and aesthetically pleasing
environment that projects a sense of
permanence. Welcoming plazas and pedestrian
thoroughfares connect private activities with public amenities. The grid of streets
off the highway move traffic at a slow pace. The sights, smells and sounds make it
a place to linger and enjoy.
There is diversity in the built form in Midway and the uses that are housed within.
Buildings are located in clusters near active intersections, with Retail retail shops,
restaurants, and local services can be found on the first floor. There are Offices
offices are located on the second and third floors with housing layered on top, and

69
occupants capture views toward the mountain and the water from a variety of five
and six story buildings. In some areas, the buildings contain one use like housing
or Class-A Ooffice and they stretch to the height of 200 feet. Offices are filled with
businesses immersed in international commerce that take advantage of the
proximity to Seattle-Tacoma International Airport. The combined mix of uses
creates a 17/7 place where a broad spectrum of people live, work, shop, and play.
The Link Light Rail light rail transit station, located across from Highline Community
College, is the center of this bustling urban community known as Midway with a
station. located near the combined campus of Highline Community
College and Central Washington University. An elevated pedestrian-
bridge connects the campus to the business and residential
community located east of SR-99. Light rail connects the
areaMidway to Seattle and beyond to Shoreline and Lynnwood, and
east into Bellevue and Redmond, lessening the need for an
automobile and the obligatory parking. Utilizing SR-516, METRO
brings riders to the Midway transit station along the SR-516 spine
west from Des Moines, Normandy Park,
and parts of Burien, and east from the
east Kent, Covington, Maple Valley, and
Auburn. Bus Rapid Transit continues to
serve as an express service along SR-99
connecting Federal Way, Des Moines,
and Kent residents to light rail.
Because students ride transit more and student housing is available nearby,
Highline Community College and their partnership with Central Washington
University have expanded the campus into the old eastern parking lot., The
intellectual capital generated by these institutions has attracted a variety of
companies focused on technology and medical innovation. Theproximity of Seattle-
Tacoma International Airport and international commerce has generated the need
for office spaceMidways transit oriented urban village transitions to a more auto-
oriented area around South 246th where regional retail and light industrial uses
dominate. Upon reachingSouth 272nd Street, the light rail line ends at the Star
Lake/Redondo transit station and another transit node emerges complete with a
mix of uses and pedestrian activities.

70
Urban parks serve this diverse community, supporting a healthy

lifestyle. Across from the Midway light rail station is an urban park.
The parks with expansive hard surfaces to accommodate heavy
uses and a quick transition into a large green open space that slows
down the pace of life in this urban community. A broad walkway
shaded by large trees meanders through the park and large shade
trees connects the public to a more linear path that heads south
about one-half mile. Here people can walk, run, skate, or ride their
bicycles next to a series of naturalized stormwater
detention ponds. Eventually one reaches a smaller
park overlooking Puget Sound and Mt. Rainier.
From here one One can access the recreational
activities located at the reclaimed Midway Landfill or
watch wildlife at the wetlands farther to the south,
using public pedestrian and bicycle connections
through private developments.
Just east of Midway is the Kent Highlands community. The neighborhood stands
alone, perched on the eastern edge of the ridge, but is connected to Midway and
the light rail station by regular shuttle buses. With fabulous views of the Cascades
and a grassy open space accessible for passive recreation, a tall hotel and
condominium community dominates the landscape. Because of the excellent
visibility from Interstate-5, a thriving regional shopping center has also emerged.
Midways transit oriented urban community near Highline Community College

transitions south from 240th to a more auto-oriented area at around South 246th.
This is where regional retail and light industrial uses dominate. Many new
developments have multiple stories to maximize the efficient use of their
commercial sites, with some providing live-work spaces. Upon reaching South
272nd Street and the Star Lake/Redondo transit station, another transit node
emerges complete with a mix of uses and pedestrian activities primarily in the
adjacent Cities of Des Moines and Federal Way.

71
Building Partnerships and a Vision
From the onset of the subarea planning effort, the need to cultivate partnerships
was clear. The primary partnership was between the City of Kent and the City of
Des Moines and was driven by the possibility that light rail would serve Midway. An
interlocal agreement between Kent and Des Moines laid out a set of deliverables
that were tied to a Growth Management Grant from the State Department of
Community, Trade and Economic Development (now named Department of
Commerce). The direction from Kent and Des Moines City Councils was a
commitment to build a livable, long lasting community that was economically and
environmentally sustainable.
There were other significant Envision Midway partners from transportation

agencies, large property owners such as Seattle Public Utilities (SPU), Highline
Community College and adjacent cities. All were invited to participate in the
Envision Midway Stakeholders Committee. The development community was also
included. Progressive developers with regional and national experience in mixed
use and transit oriented development, and local housing experts were invited to a
Developers Forum to provide
feedback on the initial public
visioning and a follow-up Developers
Forum confirmed the vision was
achievable. All of these partnerships,
together with input from residents,
property owners, and businesses
within the Midway Subarea are the
foundation for Envision Midway and
will be critical in the successful
implementation of the Midway
Subarea Plan.
Visioning Process:
The visioning process was iterative and attempted to reach all constituents. The
outcomes of each meeting were shared to ensure participants could benefit from
the larger discussion, evaluate and revise ideas generated by others, and remain
engaged as the project moved forward. The Stakeholders Committee and the
public were asked to consider land uses, regulatory and design standards, and were
charged with identifying light rail station locations and rail alignment options. In an
effort to reach as many community members as possible, a project website was

72
developed where meeting schedules, materials and results and other materials
were posted.9 The intent was to ensure project transparency and to solicit
comment from the greater community. A unique opinion poll posted on the
Envision Midway website was based on a computer generated video that reflected
the vision for Midway and allowed the viewer to walk through a virtual reality of
Midway at a light rail station near Highline Community College.
A total of nine (9) meetings were held in 2008 and 2009 with the public and
stakeholders, and by early in 2009, six (6) meetings were held with decision
makers in an effort to develop a land use scenario that reflects the communitys
wisdom and vision for Midway. Additional meetings will be held that will refine the
Plan further.
Visioning Products:
The first products from the visioning process were three distinct (3) land use
alternatives for the Envision Midway Study Area. The alternatives illustrated the
potential land use patterns; identified a vehicular, pedestrian, and bicycle
circulation framework; and considered public spaces. The alternatives are briefly
described as follows:
Alternative 1 Transit Oriented Village: The high intensity mixed-use transit

supportive development stretched from South 216th Street to South 240th
Street and all land uses south of 240th were auto-oriented and called an
Employment Village.
Alternative 2 Transit Oriented Centers: High intensity mixed-use transit

supportive land uses were located at nodes where high capacity transit
stations were located at South 216th Street, just north of at South 240th
Street, and at South 272nd Street. In Des Moines, Mixed-Use defined the
area between the first two nodes and in Kent there were Mixed-Use and
Employment Village land uses between the nodes.
Alternative 3 Transit Oriented Corridor: High intensity mixed-use transit

supportive land uses stretched from South 216th Street to South 246th Street
and another node was located at the South 272nd Street transit station.
Between the two transit oriented nodes was Transit Supportive Mixed Use.
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The project website is www.EnvisionMidway.com.

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The above alternatives were evaluated by a group of progressive developers with

regional and national experience, local housing experts, and large property owners
(i.e., SPU and HCC) at a Developers Forum. From their critical review, staff created
a new land use option. The new alternative Land Use Scenario 1.0 condensed
the mixed-use areas into nodes around future light rail stations. The intent was to
strategically focus an intensity of uses around the stations and maintain a large
portion of the existing auto-oriented retail and light industrial uses. This land use
pattern would minimize sprawl of strip commercial development and allow an urban
community to mature as envisioned. Land Use Scenario 1.0 was further refined to
reflect additional comments from Envision Midway workshops and meetings.
Based on Sound Transits planning efforts to date, the first station south of SeaTac
Airport would be South 200th, followed by a station near Highline Community
College, with the line ending at South 272nd. Participants in Envision Midway
considered three (3) light rail station and rail alignment options. To facilitate public
discussion, the focus was on the station in the vicinity of Highline Community
College. Detailed conceptual illustrations were created, listing the advantages and
disadvantages of the different alternatives (see Figure 3 Envision Midway Three
Light Rail Station Concepts). All options contained a 500-stall parking garage as
considered by Sound Transit. The following options were entertained:
The SR-99 station Station option generally represented one that Sound
Transit considered for budgeting purposes. Their rail alignment was located
along the west side of SR-99 as an elevated structure, with thenear Highline
Community College. , Station supported by a 500-stall parking structure and
a new traffic signal for pedestrians to cross SR-99 safelyThe vision expanded
Highline Community College campus into the east parking lot with a
pedestrian bridge to provide safe access across SR-99. New roads break up
the existing street grid and a regional detention facility manages stormwater
runoff. Bridges over SR-516 and I-5 would connect neighborhoods. Based
on Sound Transits planning, the first station south of SeaTac Airport would
be South 200th, followed by a station near Highline Community College, with
the line ending at South 272nd. Sound Transit had not considered a station
at South 216th in Des Moines.
The 30th Ave South Stationstation option came out of the public process. The
alignment would be at grade through the station area, becoming elevated
south of S 240th St. The roads, detention facility, and campus expansion
found in the SR-99 concept are also proposed here. Both the public and the

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Stakeholders Committee thought a 30th Ave alignment could create a more

pedestrian friendly environment, where the train and automobiles moved at a
slower pace than would be the case along SR-99. A large amount of right of
way would be needed to accommodate multiple modes of transportation on
30th Ave.
The I-5 station Station option was considered because the Cities of Des
Moines and Federal Way Comprehensive Plans express the desire for locating
future light rail on I-5 and not on SR-99. The trains would move along a
combination of elevated and at-grade rail alignments. The roads, detention
facility, and campus expansion found in the SR-99 concept are also proposed
here. There would be an uphill climb to SR-99 and the college, and limited
opportunity for development to the east of the station.

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Figure 3: Envision Midway - Three Light Rail Station Concepts.

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After completing the Envision Midway public outreach and compiling the feedback, a
fourth station option was developed. This fourth option reflects the additional
comments from representatives of Highline Community College who wish to
preserve their east parking lot, thereby negating transit oriented development
within their boundaries. The fourth option places the light rail station on the east
side of SR-99, connecting the station directly to an area poised for transit
supportive development (see Figure 4 East SR-99 Light Rail Station Option). The
vision includes parks, a multi-purpose trail adjacent to an enhanced regional
stormwater detention facility. Public and private circulation is pedestrian-friendly
and connects to the trails and parks. The East SR-99 station option reflects the
desires of the college, as well as some local businesses.

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Figure 4 East SR-99 Light Rail Station Option.

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Visioning Outcomes:
Land Use Scenario 34.0 reflects the conclusion of the Envision Midway public
visioning process and is used for Kents Midway Subarea Plan (see Figure 4 5
Envision Midway Land Use Scenario 4.0). There are five (5)three (3) categories of
land uses identified in Scenario 3.0, three of which pertain to the City of Kent.
1. The Transit Oriented Village Community land use represents nodes of intense
transit-supportive mixed use that are pedestrian-friendly with a mix of
services, office, and residential activities.
2. The Kent Highlands Landfill Mixed Use and surrounding area is identified as
mixed use that accommodates automobiles and supports pedestrian-
oriented uses at a high density, but is also auto-accommodatingand has a
residential bias.
3. The Highway Commercial Corridor allows a wide range of auto-oriented uses

including retail, light manufacturing, and housing.
The public believed it was important to connect the surrounding residential

communities to the new light rail station. I-5 and SR-516 are barriers for
pedestrians and vehicles. Scenario 43.0 connects the community located to the
east of Midway over I-5 with a bridge that provides a safe multimodal option link to
the transit station. A bridge over SR-516 connects 30th Ave South and the
community to the north and opens a possible connection to the I-5/SR-509 Corridor
Completion and Freight Improvement Project. A pedestrian sky-bridge over SR-99
would provide a safe and comfortable alternative to crosswalks.
Another outcome from Envision Midway was identification of a preferred station

location and alignment. The Stakeholders Committee selected a preferred station
location and alignment. Participants were asked to review and discuss three (3)
hypothetical light rail station locations and rail alignments (see Visioning Products).
Eighteen committee members were each given five (5) large dots to place on one
or more options, indicating their preference. SR-99 was the preferred station
location (50 dots), followed by 30th Ave (15 dots), and I-5 (4 dots). The public
also preferred the SR-99 alignment, with 30th Ave coming in second. An alignment
along I-5 was seen as antithetical to the tenets of transit oriented development by
separating limiting the potential transit oriented development along SR-99 from ato

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only west of the station along the interstate. The East SR-99 Station option
developed from comments at the final Envision Midway meetings was not
considered during the preference voting.
There were several key results that resonated throughout the public process. There
was desire for this transit oriented development to be built well, with excellent
materials and design. There was agreement that tall buildings would fit into
Midway and capture the spectacular views to the east, west, and south. There was
consensus that housing should be diverse and affordable for a range of economic
groups. Participants recognized the need for public spaces which included generous
sidewalks, plazas, parks, and trails. Connecting the surrounding neighborhoods to
the transit station area was important. The participants also saw the need for the
Cities of Kent and Des Moines to work together in the future to ensure services are
coordinated and development regulations are compatible.

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Figure 5: Midway Subarea Land Use Scenario 4.0.

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Figure 3: Envision Midway Land Use Scenario 3.0.

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Chapter Four
Framework for Midway

The planning effort for Midway was guided by principles outlined in the Growth
Management Act and Kents Comprehensive Plan. The public investment in high
capacity light rail transit drove the Midway Subarea Plans early visioning efforts.
The framework below reflects a synthesis of statements made at Envision Midway
public workshops, Stakeholders meetings, and workshops held for elected officials
and provides guidance for the goals and policies of the Midway Subarea Plan:
A flourishing economy: Midway will be home to a range of employment

opportunities that are synergistic with programs at Highline Community
College and Central Washington University and unique to the businesses and
employment needs of international trade, and the Kent Valley research and
industry, and regional retail.
Vibrant mix of neighborhoods: Midway will contain a broad range of housing

types for a broad range of incomes. Shopping, services and transit will be
conveniently located within walking distance from residences.
Supportive parks and open space: Midway will have parks to serve the
nearby residents, employees, and visitors. The large open spaces that are
undevelopable within the Kent-HighlandsKent Highlands and Midway landfills
will be converted, wherever possible, to passive use wherever possible. If
possible, the large wetlands will be used both for passive recreation and
education.
A sense of place: Midways neighborhoods will be distinct from Kents

Downtown and East Hill business areas. Midway will build on its roadside
past and ethnic heritage, with eyes toward the future. Public investment in
street lights and furniture at the Transit Oriented Communities will be
consistent and coordinated with the City of Des Moines.
Multimodal transportation system: Midways improved public transportation

system with Bus Rapid Transit (BRT) and Sound Transit light railLink Light
Rail will provide convenient and fast access to the north and south. With
greater demand, reliable east/west transit connections will be provided. SR-

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99 will continue to act as a highway and accommodate pedestrians, while the

side streets will be bicycle- and pedestrian-friendly.
Views: Midway will be dotted with high-rise buildings that ensure views are
maintained and access to sunlight is available.
Sustainability and design: State-of-the-art techniques, materials, and design

will be used to enhance and support the built and natural environment and
create a moresustainable and livable community.
Midway Subarea Plan Goals & Policies

The Midway Subarea Plan is guided by Kents Comprehensive Plan Framework
policies and the goals and policies of elements in the Comprehensive Plan. The
following goals and policies are specific to Midway and are the result of extensive
community visioning efforts. These goals and policies set the stage for developing
implementation measures to achieve the goals.
Overall Goal:
Create a dense, pedestrian-friendly, sustainable community that provides jobs,
housing, services and public open space around nodes of high capacity mass transit
while maintaining auto-oriented uses between the transit oriented nodes.
Land Use:
The community vision for the Midway Subarea is
one that supports high capacity transit stations
with compact, high density uses. The uses
include retail, office, education, research,
medical, and residential. These high density
transit station nodes are served by a series of
small, walkable blocks and pedestrian
throughways that not only move people, but act
as the public square for commerce, relaxation
and entertainment. The more auto-oriented
portion of the subarea outside of the transit
nodes is enhanced to make pedestrian movement
more comfortable and appealing. The goal of the
Midway Land Use Policies is to structure the

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activities around the high capacity transit station nodes with a land use designation
of Transit Oriented Community and the auto-oriented portion Pacific Highway
commercial transportation corridor of the Midway Study AreaSubarea.
Goal MLU-1: Increase employment opportunities and

housing choices in support of rapid light rail and mass
transit options within areas designated Transit Oriented
Communitythe Pacific Highway South (SR-99)
Transportation Corridor.
Policy MLU-1.1: Focus Designate where high

density retail, office, and residential development
will be focusedwithin designated Transit Oriented
Communits where future light rail stations and
mass transit services are located.
Policy MLU-1.2: Allow stand-alone land uses as part of a mix of uses near
and within Transit Oriented Communit, with the exception of single-family
residential land use which should be in vertically mixed structures.
Policy MLU-1.3: Provide flexibility in land uses and density as the market
transitions from auto-oriented development form to a dense pedestrian-
friendly development form.
Disallow additional stand-alone big box, drive-through, or other auto-
oriented development within designated Transit Oriented Communities,
although drive-through development other than food services may be
allowed along Pacific Highway South.
Policy MLU-1.4: Disallow outdoor storage of trucks, heavy equipment, and

contractor storage yards, and mini-storage as an accessory or primary use
within designated Transit Oriented Communities.
Policy MLU-1.5: Establish a minimum building height in designated transit

oriented Urban Villages. Disallow drive-through food services within the land
use designation of Transit Oriented Community.
Policy MLU-1.6: Establish a minimum and maximum floor area ratio (FAR)
or other mechanism to ensure levels of development supportive of future
light rail transit investments within designated Transit Oriented Communities.

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Goal MLU-2: Promote a mix of land uses that support local and regional needs in
an auto-oriented commercial and light industrial area along the Pacific Highway
South (SR-99) Transportation commercial transportation Corridorcorridor not
designated Transit Oriented Community.
Policy MLU-2.1: Designate areas forAllow a mix of retail, light industrial or

live-work uses that are accessible from SR-99.
Policy MLU-2.2: Allow big box and drive-through uses along the Pacific
Highway South (SR-99) Transportation Corridor and outside the designated
Transit Oriented Communities.
Policy MLU-2.3: Allow outdoor storage of autos, boats, trucks, heavy

equipment, and contractor storage yards.
Goal MLU-3: Establish a multimodal street circulation network within areas

designated Transit Oriented Community that is safe, interesting and encourages
walking, bicycling and transit use, and connects to surrounding neighborhoods.
Policy MLU-3.1: Create a network of attractive and

identifiable pedestrian and bicycle linkages within
commercial and residential uses to nearby public
amenities, transit facilities, and streets.
Policy MLU-3.2: Create Ensure pedestrian or

vehicularmultimodal public or semi-public
throughways at a minimum of every 400 feet to
connect commercial and residential uses with
public parks, trails, streets or other public
amenities.
Policy MLU-3.3: Identify and designate streets

as multimodal within areas designated Transit Oriented
Communityiesas multimodal.
Policy MLU-3.4: Establish north/south connectivity for

pedestrians and bicyclists from SR-516 to S 272nd Street
as a safe alternative to Pacific Highway South.

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Policy MLU-3.5: Establish north/south connectivity for pedestrians and

bicyclists through the area designated Transit Oriented Community located
east of I-5.
Urban Design:
The built environment is the framework where
urban life occurs. A successful urban
environment is a place that pays attention to
design details. There is a pedestrian scale,
where the first floor provides interest and the
opportunity for interaction. From a distance,
buildings become more abstract and are seen
more as a piece of art. The Transit Oriented
Communities will look and feel like urban
centers. Buildings will be constructed close to
the sidewalks making it imperative they are interesting and constructed of quality
materials. The Urban Design Element of the Midway Subarea Plan focuses on these
details to ensure that Midway becomes a desirable place where people want to live
and do business.
Goal MUD-1: Create a place that is distinctive,

aesthetically beautiful, evokes permanence of the built
environment, and supports social interaction in the
dynamic urban center of the areas designated Transit
Oriented Communityies.
Policy MUD-1.1: Ensure quality and durable

materials and interesting architectural details are
incorporated into new and remodeled structures,
including structures for parking, mechanical
services, or solid waste collection.
Policy MUD-1.2: Provide an interesting built

environment by encouraging a diversity of
building heights and footprints, continuous building faades that are
modulated, windows located at ground floor, and shelter for pedestrians from
inclement weather.
Policy MUD-1.3: Create public plazas, building

entrances, and pathways that are integrated into the

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private and public realm to encourage social interaction and to facilitate the
use of public transportation.
Policy MUD-1.4: Establish methods to vertically

layer the height and size of development and stagger
high-rises to maximize view potential and sun access.
Policy MUD-1.5: Use screening to minimize the

visual impact of mechanical systems at street level or
from adjoining high-rise buildings roofs.
Policy MUD-1.6: Provide visual interest at entrances to stand-alone or

internal structured parking facilities.
Policy MUD-1.7: Reduce the visual impact of surface parking by using

measures such as minimizing curb cuts, enhancing the landscaping at
entries, and prohibiting surface parking between buildings and sidewalks.
Policy MUD-1.8: Encourage public and private art in public open areas and
on buildings.
Goal MUD-2: Create an urban form that is environmentally

sensitive and sustainable a in areas designated Transit
Oriented Communityies based on urban form that is
environmentally sensitive and sustainable.
Policy MUD-2.1: Promote environmentally sustainable

building design that takes into account sun orientation,
water and energy conservation, and practices such as
the US Green Building Council LEED
certification.
Policy MUD-2.2: Emphasize natural

drainage systems wherever feasible,
including, but not limited to, green roofs
or walls, rain gardens and so forth.
Policy MUD-2.3: Apply landscaping standards that

emphasize environmentally sustainable practices through

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plant selection, horticultural practices, and water retention, diversion and

conservation.
Goal MUD-3: Create streetscapes that provide for ease of movement, personal
safety, pleasant aesthetics, and a stage for public engagement within areas
designated Transit Oriented Community.
Policy MUD-3.1: Design streets to be urban in

character, easy and safe for pedestrians to
cross, and where vehicular movement is slowed
by design utilizing street calming measures such
as on street parking, chicanes, elevated
pedestrian crossings or other methods .
Policy MUD-3.2: Ensure a safe and attractive

pedestrian environment along the street system
through the use of streetlights, street trees, plantings, minimized number of
curb cuts and other streetscape elements.
Policy MUD-3.3: Establish a pallet of easy-to-maintain

streetscape elements and features that are unique to
the Transit Oriented Communities.
Policy MUD-3.4: Provide pedestrian amenities along

the public and private sidewalks such as seating, human
scale lighting, transit shelters, and shelter from the
weather within the designated Transit Oriented
Communities.
Policy MUD-3.5: Build pedestrian areas large

enough for commercial activities to spill out onto
the sidewalks without significantly impeding
pedestrian movement in designated Transit
Oriented Communities.
Policy MUD-3.6: Ensure a network of pedestrian

public access through private development to assure pedestrian connectivity
to adjacent public open spaces.

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Policy MUD-3.7: Disallow drive-through features in new development in

designated Transit Oriented Communities and phase out grandfathered drive-
through uses during redevelopment.
Policy MUD-3.86: Establish sign

regulations for the designated Transit
Oriented Communitiesthat acknowledge
the human scale and the slower vehicular
movement along 30th Avenue South, other
internal street systems and internal
pathways.
Policy MUD-3.97: Establish sign regulations for the designated Transit

Oriented Communitiesthat acknowledges the more auto-centric environment
for development adjacent to SR-99 while maintaining the overall urban
character of the designated Transit Oriented Community.
Policy MUD-3.108: Work with Puget Sound Energy and other utility
providers to underground or relocate overhead wires along 30th Ave South
and South 240th Street.
Goal MUD-4: Support transit use and the pedestrian

environment through parking management, design, and
standards within areas designated Transit Oriented
Community.
Policy MUD-4.1: Establish methods to

encourage the use of alternative modes of
transportation, including maximum parking
standards and shared parking agreements.
Policy MUD-4.2: Reduce the supply of surface parking supply in designated

Transit Oriented Communities transit.
Policy MUD-4.3: Encourage structured parking in designated transit

oriented development areas.
Policy MUD-4.4: Reduce surface parking adjacent to the sidewalk.

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Housing:
Housing is key to the success of the Transit
Oriented Communities anticipated in the
Midway Study AreaSubarea. Housing is also
important within the auto-oriented Pacific
Highway commercial transportation
corridorportions identified in the Midway
Subarea Plan. Redevelopment at the Transit
Oriented Communities may eliminate existing
affordable housing, displacing families and the elderly. The
community who participated in the vision for Envision Midway was
adamantemphasized that replacement housing be created so that
people did not have to move far from the community where some
have lived for over 30 years.
Goal MH-1: Promote a diversity of housing types that supports a full range of
incomes and household structures within the Midway Subarea.
Policy MH-1.1: Encourage market rate and workforce housing. in the

designated Transit Oriented Communities within mixed use buildings or as
stand-alone multifamily residential development.
Policy MH-1.2: Create an Affordable Housing Commission Task Force by

2012 to consider options, policies, and partnerships for resolving issues
surrounding the potential displacement of existing affordable housing.
Policy MH-1.3: Promote Utilize affordable workforce housing in new housing

stock, with a target of 50% of new owner or rental units affordable for
households earning 120% of median income or less. Regulatory regulatory
incentives, public investments, and other strategies will to assist in realizing
a mix of housing types to create a diverse transit-supported community.
Policy MH-1.4: Provide for live-work housing options at medium densities

within the auto-oriented Pacific Highway Commercial commercial
transportation Corridorcorridor.

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Transportation:
In the 21st Century, transportation will consist of
several components cars, transit, trains, bicycles
and pedestrians. In Midway, all modes of
transportation will need to work together to reduce
greenhouse gas emissions by reducing vehicular
trips. To support a pedestrian-friendly Transit
Oriented Community, a new street grid system
consisting of small walkable blocks needs to be
created. There exists an excellent north/south
spine in 30th Ave South requiring only some
east/west connections to create a system of public
spaces where those who work, live, or visit can move safely, easily, and enjoyably.
Extending 30th Ave south to South 246th St. with connections west to SR-99 will
support the anticipated development surrounding the high capacity transit coming
to the areavicinity of Highline Community College. Other opportunities to relieve
traffic pressures from new development need to be explored, like bridging over SR-
516 along 30th Ave and then connecting with the I-5/SR-509 Corridor Completion
and Freight Improvement Project. Shared trails through public and private
properties can connect communities outside the Midway Subarea to the anticipated
high capacity transit.
Goal MT-1: Establish a connected street system that

encourages walking and bicycling, ; supports
transportation investments, including existing and
future mass transit, ; and connects surrounding single-
family neighborhoods to Midway while protecting them
from the impacts of spillover traffic.
Policy MT-1.1: Design and develop streets

within the designated Transit Oriented
Communities transit that provide a safe
experience that has and have aesthetic value to all users of the public right
of way.
Policy MT-1.2: Consider a bridge to connect the West Hill single-family

neighborhood east of I-5 to the Transit Oriented Community located near
South 240th Street.

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Policy MT-1.3: Work with the City of Des Moines and Washington State
Department of Transportation to consider connecting the Pacific Ridge
Neighborhood north of SR-516 to Midway via a 30th Ave South bridge over
SR-516.
Policy MT-1.4: Work with the City of Des Moines and Washington State
Department of Transportation to consider a local connection to the
interchange for the I-5 SR-509 Corridor Completion and Freight
Improvement Project off 30th Ave South.
Policy MT-1.45: Identify and designate particular

streets to be shared with bicycles.
Policy MT-1.56: Identify and, where feasible,

connect local and regional bicycle and pedestrian
trails to the Midway Pedestrian & Bike Path
Framework system in Land Use Scenario 4.0to the
designated Transit Oriented Communities.
Goal MT-2: Create design guidelines for a street hierarchy

within the designated Oriented Community that addresses the
pedestrian and environmental needs in the areas designated
Transit Oriented Community.
Policy MT-2.1: Establish pedestrian-friendly design standards for streets,

sidewalks, and lighting.
Policy MT-2.2: Design and build green streets where street trees,
landscaping and sustainable stormwater drainage systems enhance the
public and private domain aesthetically and environmentally as identified in
Land Use Scenario 4.0.
Policy MT-2.3: Provide safe mid-block pedestrian crossings

passage-ways to public amenities on internal streets when
urban block sizes areexceed 600 400 linear feet or
greaterand through-block passages every 400 linear feet for
pedestrian connectivity to public amenities within the
designated Transit Oriented Communities located near S
240th St.

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Policy MT-2.4: Provide on-street parallel parking that ensures promotes a

safe pedestrian environment in the areas designated Transit Oriented
Community (except along SR-99). within the designated (not along SR-99)
Policy MT-2.5: Work with transit agencies to

ensure safe access to local and regional transit,
including but not limited to covered bus shelters
and sky-bridges.
Policy MT-2.6: Work with the City of Des Moines

and SeaTac to ensure access connections to
existing or proposed multi-modal trails within
their jurisdictions.
Goal MT-3: Integrate high capacity light rail transit service and associated station
locations into the urban design and functionality of the street systems.
Policy MT-3.1: Work with Sound Transit during all

phases of planning for the extension of light rail into
Midway to ensure Kents preferred rail alignment and
station location are realized.
Policy MT-3.2: Work with Sound Transit and other

entities to provide an elevated pedestrian crossing
over Pacific Highway South SR-99 at the proposed
light rail station near Highline Community College.
Policy MT-3.3: Work with Sound Transit and additional partners to establish
a shared parking structure in the vicinity of associated with the future light
rail station proposed in the vicinity of Highline Community Collegeat Midway.
Policy MT-3.4: Integrate any proposed parking structure associated with the
light rail station into the urban landscape by adding commercial uses at
ground floor, an active pedestrian plaza, and art to enhance the pedestrian
environment and minimize the impact of vehicular traffic.
Policy MT-3.5: Work with transit agencies and private entities to ensure
communities, businesses, and park & ride facilities located outside of the

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one-half mile radius around the future light rail stations are connected to the
high capacity transit system.
Policy MT-3.6: Ensure proposed development is compatible with future light

rail improvements by identifying and preserving rights of way necessary for
future transportation projects.
Goal MT-4: Design and fund street improvements identified through the Midway
Planned Action Ordinance (PAO) and accompanying Environmental Impact
Statement (EIS) to serve the areas designated Transit Oriented Community and
Kent Highlands area.
Policy MT-4.1: Develop a new street grid system of local public streets
consisting of small pedestrian friendly sized blocks no larger than 400 feet
within the PAOdesignated Transit Oriented Community located near S 240th
Street.
Policy MT-4.2: Establish methods to achieve significant increases in non-

SOV (single occupancy vehicle) trips from and within the Transit Oriented
Communities.
Policy MT-4.32: Whenever possible, limit access along South 231st Way,
state routes and highways, using instead local streets or private internal
circulation roads to connect land uses and public amenities within the
PAOarea.
Policy MT-4.43: Work with Washington State Department of Transportation

on improvements to SR-99 identified in the PAO/EIS and on the extension of
SR-509 as identified in the PAO/EIS to best serve the surrounding
community.
Policy MT-4.4: Integrate identified street improvements into a 10 year city-

wide transportation demand analysis and funding structure, and incorporate
results into the Kent Comprehensive Plan update of 2014.
Goal MT-5: Utilize transportation system management (TSM) techniques in support

of pedestrian-friendly streets.

95
Policy MT-5.1: Provide adequate access to adjacent land uses by adopting

Access Management strategies, including but not limited to consolidating
driveways, limiting the number of driveways, and connecting parking lots.
Policy MT-5.2: Allow new driveways on internal streets only ( i.e., 30th Ave
South).
Policy MT-5.3: Establish methods to achieve significant increases in non-

SOV (single occupancy vehicle) trips.
Park & Open Space:

Dense, compact mixed use urban areas require public places for
social interaction and personal relaxation. The vision for
Midways Transit Oriented Communities acknowledges the need
for open space and identifies several public and private
development options for providing exercise, relaxation, and
gathering places.
Goal MP&OS-1: Create an aesthetically

pleasing, functional, and effective parks and
open space system in areas designated
Transit Oriented Community iesthrough
public, private investments and other
partnerships.
Policy MP&OS-1.1: Wherever possible, integrate city

owned properties that have recreational or educational potential with public
parks and plazas.
Policy MP&OS-1.2: Utilize undeveloped right-of-way right of way for a

linear park with multi-purpose trail.
Policy MP&OS-1.3: Identify, acquire, design

and construct a large civic plaza/park to serve
employees, residents and visitors in the
Transit Oriented Community located near
South 240th Street.

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Policy MP&OS-1.4: Work with Seattle Public Utilities property owners of

the Kent Highlands and Midway landfills to design and develop passive or
active public recreational opportunities on portions of the landfills identified
as undevelopable.
Policy MP&OS-1.5: Provide Consider access to wetlands at South 272nd

Street for educational and passive recreational opportunities.
Policy MP&OS-1.6: Engage with neighboring jurisdictions, school districts,

and others in an effort to share existing facilities through joint use
agreements.
Policy MP&OS-1.7: Work with private and public property owners,

agencies, and surrounding jurisdictions to establish and link the Midway
Pedestrian & Bike Path Framework to regional facilities.
Policy MP&OS-1.8: Consider shuttle service from Midway to Kent park

facilities located in the valley in an effort to expand recreational access.
Goal MP&OS-2: Create a joint-use regional drainage infrastructure

for development and recreational purposes.
Policy MP&OS-2.1: Consider the opportunities for a regional

stormwater detention facility to contribute aesthetically,
recreationally and environmentally to the urban landscape of
the designated Transit Oriented Community at South 240th
Street.
Policy MP&OS-2.2: Establish a funding mechanism

to build the detention pond and associated
recreational and aesthetic features in the designated
Transit Oriented Community at South 240th Street.
Policy MP&OS-2.3: Program the detention facility as a community focal

point for ecosystem education and neighborhood adopt-a-park.
Policy MP&OS-2.4: Encourage natural drainage systems in public and

private development where feasible, as an alternative or offset to traditional
stormwater treatment and controls.

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Implementation:
The vision for Midway is ambitious, transforming the existing auto-oriented retail
activities into a more compact, dense, transit supported urban community where
light rail transit stations are planned. The subarea plan Plan identifies new roads
and bridges, parks and trails, and a regional stormwater detention facility for the
Transit Oriented Communities located at South 240th Street and South 272nd Street.
These changes and improvements will come over time, and a successful
implementation strategy will require a city funding strategy utilizing existing
revenue sources and new financing tools.
Goal MI-1: Provide an effective process and appropriate tools that will implement
the vision for the Midway Subarea Plan.
Policy MI-1.1: Implement the Midway Subarea Plan using a combination of

development regulations and incentives, capital investments, and other
public and private strategies.
Policy MI-1.2: Establish a mechanism that identifies needed infrastructure

and amenities to support the designated Transit Oriented Community at
South 240th Street and create a financial strategy that shares the
development cost for those improvements across the various parties that
directly benefit from the improvements.
Policy MI-1.3: Utilize tools such as master planned development,

development agreements or other processes to facilitate site planning and
permit process.
Inter-jurisdictional Coordination:
Envision Midway was a joint visioning effort by the Cities of Kent and Des Moines,
engaging numerous agencies and institutions that have a stake in the outcome.
The shared city boundary on the west side of SR-99 needs to be consistent to
facilitate future development. Continued discussion and coordination needs to
occur since many of the changes anticipated in this plan will take decades to be
realized.
Goal MIC-1: Reconcile regulatory differences between the City of Kent and the City
of Des Moines along the shared city boundaries to facilitate economic growth and
stability.

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Policy MIC-1.1: Continue to work with the City of Des Moines to create
consistent land use regulations along the shared boundary west of SR-99 and
within the Transit Oriented Community located at South 240th Street.
Policy MIC-1.2: Wherever possible, ensure design guidelines and

development standards are consistent with the City of Des Moines.
Policy MIC-1.3: Enter into interlocal agreements to facilitate development

where private properties are within both the City of Kent and the City of Des
Moines.
Goal MIC-2: Continue coordination with regional and state transportation agencies
on matters of transportation investments, planning and construction.
Policy MIC-2.1: Coordinate with Sound Transit, King County METRO,

Washington State Department of Transportation, and Puget Sound Regional
Council to ensure facilities and services are provided over time.
Land Use Plan Map
The Land Use Plan Map for the Midway Subarea Plan establishes the framework for
amendments to the Citys official Zoning District Map. There are several different
land use designations within the Subarea and only one is new (see Figure 6
Midway Subarea Land Use Plan Map Designation). All designations will be
incorporated into the Kent Comprehensive Plan Land Use Plan Map and all
freedoms and constraints associated with the Comprehensive Plan are applicable.
Transit Oriented Community (TOC)

This designation allows retail, office, and multifamily residential uses together in the
same area or as a stand-alone use. This area allows high-density uses in support
of rapid transit investments.

ATTACHMENT B - LUPB PUBLIC HEARING 11/22/10
99
Figure 6 Midway Subarea Land Use Plan Map.

100

Appendix C
Draft Midway Design Guidelines
167
CITY OF KENT
Midway Design Guidelines
Ordinance No. ### - Effective ####

168

169
Table of Contents
INTRODUCTION 1
DESIGN GUIDELINES 3
Overview of Character 3
Site Design 4
Site Characteristics 4
Heart Locations 6
Topography 7
Street Compatibility 7
Human Activity 9
Pedestrian 10
Transition between Residence, Street and Adjacent Sites 12
Parking and Vehicle Access 13
Screening of Dumpsters, Utilities and Service Areas 14
ARCHITECTURAL DESIGN 16
Height, Bulk and Scale 16
Architectural Context and Features 18
Exterior Finish Material 21
Human Scale 22
Commercial Entrances 23
Residential Entrances 25
Blank Walls 26
Parking Near Sidewalks 27
Personal Safety and Security 29
Signage 30
Lighting 32
Landscaping and Open Space 34
DEFINITIONS **
170

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Midway Design Guidelines
Introduction
The purpose of the Midway Design Guidelines (the Guidelines) is to establish a
flexible framework of design options for creating interesting and high quality
commercial, and multi-family residential projectsand public projects. The
Guidelines focus onapply to the Rapid Transit Community (RTC) land use
designations, pedestrian-oriented places located around Sound Transit light rail
stations planned near Highline Community College and near the intersection of
South 272nd Street and Pacific Highway South (SR-99) with a Midway Transit
Community 1 (MTC-1), Midway Transit Community 2 (MTC-2) or Midway
Commercial/Residential (MCR) zoning district, and on the more auto-oriented
highway commercial uses in between. The intent of the Guidelines is to
establish a consensus of quality, unity, and conformity illustrated in a menu of
design options that define a minimum condition for approval. For continuity
Midway Design Guidelines/Revisions post 12/14/09 LUPB Public Hearing 1

172
along our shared boundary, the Midway Design

Guidelines will have a counterpart in the City of
Des Moines.
The Midway Design Guidelines reflect the vision

found in the Midway Subarea Plan. In addition to
their application to private development projects,
the Guidelines will be applied to street
improvements, parks and other public facilities in
an effort to create a setting that is special,
dynamic and safe for civic activities. The
Guidelines are not intended to slow or restrict
development. Instead, they provide predictability
and consistency to the development review
process.
Midway Subarea

173
Design Guidelines
Overview of Character:
The vision for Midway is an active place where commerce, education and cultural
events are integral to the fabric of the community; it is a place where broad
spectrums of people live. This new urban center is built around a light rail
station, making the automobile less of a necessity for those who live or work
there. Parks and outdoor gathering places provide a common ground where
people meet and where nature rejuvenates the body and spirit. These green
spaces, whether located on roof tops and terraces or on the ground, provide a
sustainable method for managing stormwater runoff from this urban landscape.
Midway is a walkable place where pedestrian circulation is convenient, attractive

and safe. Designated pedestrianPedestrian-oriented streets provide a high-
quality environment where the spatial and functional integration of sidewalks
and building elements complement each other. There is an ease of movement,
and linkages are easily identifiable for the pedestrian.
While The the automobile continues to have a presence, particularly along

Pacific Highway South (SR-99), the pedestrian has an equal status. Street and
building design elements are integrated for walkability and to promote the
identity of Midway. , with a gateway Gateways sign identifying Midway and the
cities of Kent, and Des Moines, and Federal Way. The location of the Midway
RTC along a highpoint of a ridge provides scenic Development can capitalize on
scenic views to the Puget Sound Basin that should be protected and enhanced.

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The following overarching design concepts represent the intent of the Midway
Design Guidelines.
Promote Architectural Compatibility

Reflect the 21st Century.
Establish Gateways and Neighborhood Identity

Create a unique identity for those who live and work in Midway, along with those
who pass through, while smoothing the transitions from a mixed-use commercial
environment to the surrounding single-family neighborhoods.
Protect and Enhance Views

Promote the view potential of Midway and Kent-Highlands by siting and
designing new construction in a manner that maximizes capturing territorial
views iconic to the Puget Sound Basin.
Site Design:
Site design is the arrangement of buildings, landscaping, open
space, circulation elements, and other features in response to
unique site features and surrounding context.
Site Characteristics
Overview: Buildings The built environment should be oriented
to respond to specific site conditions and opportunities such as proximity to
prominent intersections, topography, significant vegetation and views, or other
natural features such as sunlight.
Intent: To locate the built

environmentbuildings strategically to
create a sense of place, encourage
synergy with its surroundings, and
optimize sustainable design.

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Guidelines:
Reinforce established community gateways through the use of
architectural elements, streetscape features, artwork, landscaping,
signage, or references to the history of the location.
Provide outlooks and overlooks for the public to view

public open space or territorial views of mountains or
water bodies. (i.e., parks, multi-modal trails, and
enhanced storm detention) and
opportunities to view Mt. Rainier,
the Cascade Mountains, Kent Valley,
or Puget Sound and the Olympic
Mountains.
Minimize shadow impacts to public

parks and multi-modal trails.

Configure the development to lower its impact on
the environment through:
o Solar orientation
o Storm water run-off,
detention and filtration
systems
o Sustainable landscaping
o Versatile building design for
adaptive reuse during the
buildings life cycle
Reinforce community gateways through the use of
architectural elements, streetscape features,
artwork, landscaping, signage, or references to the
history of the location. The following locations are gateways in Midway:
o SR-99 & Kent-Des Moines Road
o SR-99 & South 246th
o 231st & Military Road
o SR-99 & South 272nd

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Heart Locations
Overview: Heart Locations serve as the
perceived center of commercial and social
activity within a neighborhood. These
locations have an identity and are anchors for
the community.
Intent: To enhance and promote the central character of Heart

Locations through appropriate site planning and architectural
treatments, giving high priority for improvements that focus
on the public realm.
Guidelines:
Provide design treatments to respond to identified Heart Locations as
listed below:
o Light rail station
o Parks and plazas
o Commercial intersection nodes Intersections along 30th Ave South
o Intersection of 30th Ave South and South 246th Street
Provide primary entry treatments and faade amenities to

respond to centers of commercial and social activity at
Heart Locations. Amenities Primary entries shall provide a
minimum of four (4) amenities to consider arelisted below:
o Pedestrian weather Weather protection

o Pedestrian level windows
o Pedestrian lighting Lighting
o Public art
o Special paving
o Landscaping
o Additional public or semi-public open space
provided by curb bulbs and entry plazas

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Topography
Overview: The built environment should reflect, rather
than obscure, natural topography.
Intent: To respond to topographic conditions of the site

and its neighbors:
Guidelines:
Step buildings up slopes to accommodate significant
changes in elevation.
Where neighboring buildings have responded to

similar topographic conditions in their sites in a consistent and
positive way, consider similar treatment for the new structure.
Utilize topographic considerations to reduce the visibility of parking

garages.
Street Compatibility
Overview: The character of a street
defines the human experience; from the
eyes of the pedestrian, the street with
its sidewalks and related spaces is
perceived as individual rooms and.
the The sidewalk and related spaces need to
be safe, welcoming, and easy to navigate.
Buildings and other structures play a
significant role in creating this pedestrian
friendly environment.
Intent: To site buildings in a way that

acknowledges and reinforces the desirable
spatial characteristics of the right- of- way and pedestrian realm.

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Guidelines:
Establish entries that are clearly identifiable and visible
from the street, and create a sense of human scale as
exemplified in the Golden Ratio.
The total length of a+b is to the longer
segment as a is to the shorter segment b.
Two quantities are in the Golden Ratio if
the ratio of the sum of the quantities to
the larger quantity is equal to the ratio of
the larger quantity to the smaller one. The
Golden Ratio is often denoted by the
Greek letter phi.
Provide spaces for street level uses that vary in

size, width, and depth.
Where appropriate, consider a reduction in the
amount of commercial and retail space at the
ground level to create transition zones between
commercial and residential areas. Transition
zones may include:
o Locating office uses adjacent to residential
o Locating parking niches as a buffer to residential uses
o Locating plazas or alcove entryways between uses
o Orienting retail entries away from residential uses
Provide a minimum sidewalk area of 12 feet with eight (8) feet for
sidewalk and four (4) feet for street trees, landscaping and other
pedestrian amenities.
Design for a network of safe and well-lit pedestrian

connections between buildings to encourage human activity
and link existing activity areas at a minimum of every 400.
Discourage closed campuses by keeping

pedestrian connections open.

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Human Activity
Overview: Lively street edges make for safer
streets. Ground floor shops and services
needed by residents attract market activity to
the street and increase safety
through informal surveillance.
Intent: To encourage human

activity on the street through
site planning, architectural
design and business activity.
Guidelines:
Consider accommodating outdoor dining opportunities,

by setting portions of the building back and providing
plazas, generous walkways, or open windows to bring
the activity to the street public sidewalk edge.
Create activity clusters through appropriate co-location of uses.
Encourage commercial activities to spill out at a

maximum of two (2) feet onto the public sidewalk,
maintaining five (5) feet of clearanceadequate
clearances for pedestrian movement.
Provide street level transparency to encourage

interaction between people and the activities within the
interior of a building. The following examples of
undesirable design treatments are prohibited:
o Windowless walls
o Mirrored or non-transparent glass
o Backs of display cases in windows

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o Window frame bottoms located above waist level as measured from a

non-sloping street
o Interior walls, equipment, or functional layout that hampers the intent
of transparency as stated above.
Pedestrian
Overview: Successful pedestrian-
oriented places require convenient,
safe and interesting circulation
opportunities.
Intent: To create a rich, attractive, and

safe pedestrian-oriented environment that
facilitates movement and provides interest.
Guidelines:
Provide a pedestrian-friendly
streetscape with connectivity,
interest and amenities that
emphasize details and quality
materials, such as:
o Short blocks
o Safe and well lit crosswalks
o Wide walkways for easy passage
o Tree grates
o Seating
o Lighting

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o
Provide a generous amount of weather protection along sidewalks or
other walkways adjacent to buildings to enhance the pedestrian
environment.
Buildings over 200 feet in length and

contiguous with public parks or open
space shall provide a wide, safe, and
interesting pedestrian thoroughfare
connecting the community with the
adjacent public amenity.
Maintain a continuous and safe public streetscape for the

pedestrian considering the following design techniques:
o Provide generous sidewalks (minimum 12 wide) for
pedestrians to easily pass potential commercial activities
spilling outside the business establishment
o
o Limit gaps in the streetscape by restricting parking
access to the minimum width required by code.
o
o Set buildings as close as possible to the sidewalk, with
ground floor display windows that provide views to the
interior.
o
o Provide pedestrian interest every 25 feet
using display window, entrances, awnings and
overhangs, pedestrian-oriented signs, or
exterior light fixtures that also complement
the building architecture, plantings, or
artwork.
o
o Define an amenity zone for understory plantings,
street trees, benches, trash and recycling
receptacles, bike racks and the like (note: bundle
newspaper dispensers, delivery service drop boxes
to minimize clutter, having no more than four
(4) dispensers per block).

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o
o At corners where buildings are set back: provide a
generous pedestrian space, ensuring the area contains
sufficient edges, amenities and activities to support a
place for people to gather (i.e., seating, planting,
lighting, trash receptacles, etc.).
Provide way-finding signs for pedestrians to

navigate the neighborhood.
Provide a safe, attractive, pedestrian-friendly environment

within shopping centers to facilitate movement internally and
to adjacent uses, such as:
o Landscaped pedestrian walkways
o Seating
o Lighting
Transition between Between

residenceResidence, streetStreet, and
adjacent Adjacent sitesSites
Overview: For residential projects, the
space between the building and the
sidewalk should provide security and
privacy and encourage social interaction
among neighbors. Buildings should
respect adjacent properties, particularly
less intensive uses.
Intent: To create a safe, attractive, and comfortable transition between private

and public spaces for residential uses.

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Guidelines:
Step back the upper floors, or increase the
side or rear setback, so that window and
balcony areas are farther from the
property line.
Stagger residential windows to not align with adjacent windows.
Encourage site planning to create the following:

o Courtyards
o Common gardens
o Common pathway
o Front entrance stoops/rear
at-grade access
o Small private garden
o
Accommodate a variety of
residential uses such as townhouse,
live-work, apartment, student and senior living.
Parking and Vehicle

Access
Overview: Parking lots,
garages and driveways
can have a negative
impact on the pedestrian environment and adjacent properties and should be
minimized to maintain a level of pedestrian compatibility and human scale.

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Intent: To reduce the impact of surface parking lots, garages and driveways
through site planning.
Guidelines:
Locate surfaceSurface parking shall be located at rear or side lotsof
building site.
Surface parking lots shall not exceed thirty (30)

stalls per building complex within the Midway
Transit Oriented Community 2 District.
Minimize number and width of driveways and

curb cuts.
Share driveways with adjacent property owners.
When building sites are sloped, locate parking in lower level or less visible
portions of site while maintaining views to the parking from nearby
buildings.
Provide car-sharing opportunities to lower parking requirements.

Provide adequate security and lighting of parking areas, avoid
encroachment of vehicles onto the sidewalk, and minimize the visual
clutter of parking lot signs and equipment.
Screening of Dumpsters, Utilities and Service Areas

Overview: Unsightly service elements can detract from
the visual aesthetics and compatibility of new projects
with the community and create hazards for pedestrians
and vehicles.
Intent: To site the service elements like trash dumpsters, loading docks and
mechanical equipment of new buildings away from the street front where
possible. When these elements cannot be located away from the street front,
they should be situated and screened from view and shall not be located in the
pedestrian right- of- way.

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Guidelines:
Locate service elements like trash dumpsters, loading docks and
mechanical equipment away from the street front where possible. When
such elements cannot be located away from the street
front, they should be placed and screened from view
using the following techniques:
Locate utility meters, dumpsters, mechanical units

and service areas away from the street front.
Screen dumpsters, mechanical units and

services are behind a screen wall or fence
so that it is not visible from the building
entrance.
o
Use durable materials that complement
the building for screening.
o
Incorporate landscaping to create a more effective screen.
o
Locate the opening to the service area away from the
sidewalk.
o
Prohibit the location of service elements like mechanical equipment, signal
controls, and utility meters at or above grade in the pedestrian right- of-
way.
Utilize principles of Crime Prevention through Environmental Design when

siting service elements.

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Architectural Design:
Architectural design, choice of construction materials,
and how the built form sits within the context of its
surroundings influence the sense of place. A well-
designed building should be welcoming, add human
interest, and allow opportunities for meaningful social
interaction.
Height, Bulk and Scale

Overview: Projects should be compatible with the
scale of development anticipated by the applicable
Land Use PoliciesZoning Districts for the surrounding
area and should be sited and designed to provide a
sensitive transition to nearby, less intensive zones as
well as the pedestrian environment.
Intent: Projects located along different zone edges or next to public spaces or
which have unusual physical characteristics such as large lot size, unusual
shape, or topography, should be developed in a manner that creates gradual
transition in perceived height, bulk, and scale.
Guidelines:
Consider a variety of factors to address
height, bulk and scale impacts on
adjacent properties with different zoning
district designations, including the
following:
o Distance from the edge of a less
intensive zone

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o Differences in development standards between

abutting zones (allowable building height, width, lot
coverage, etc.)
o Effect of site size and shape
o Type and amount of separation between lots in the
different zones (i.e., separation by only a property
line, by a street, or by other physical features such
as grade changes).
Utilize careful siting techniques and design

treatment to achieve compatibility with
surrounding arealand uses, including the
following:
o Architectural style
o Details (such as rooflines or
and window treatments)
o Color and materials
o Creative use of
landscapingLandscaping or
other screening
o Location of features on-site to facilitate transition,
such as locating required open space next to a
lower intensity zone where appropriate
o Treatment of topographic conditions in ways that minimize impacts
on neighboring uses and create a more human scale to a project,
such as using a rockery with landscaping rather than a retaining
wall.
o Co-locate Siting of uses near compatible existing uses or zoning
districts edges.
o
Reduce height, bulk and scale of the
proposed structure as needed to
mitigate adverse impacts to adjoining
public amenities, including sidewalks,
parks, and open space and to achieve
an acceptable level of compatibility,
by including the following:

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o Articulate the ground floor building facade

vertically or horizontally in intervals that conform
to new neighboring structures with a maximum
ratio of 2:1.
o
o Step back building upper levels from original footprint starting at
the third story and once again when the building exceeds 6 stories
to take advantage of views, increase sunlight at street level, and
create a pedestrian scale.
o
o Set back buildings located at street
intersection corners to promote visibility and
encourage pedestrians to gather.
o Increase building setbacks from a less

intensive zone edge.
Increase building
setbacks from a less intensive zone edge.
Use architectural features to reduce building scale, such as:

o Landscaping, trellis.
o Variety of complementary building
materials.
o Detailing, accent trim, fenestration,
or modulation.
Architectural Context and Features

Overview: Building design elements, details and
massing should create a well-proportioned and
unified building form, exhibit an overall
architectural concept, exhibit features
identifying the functions within the building,
complement physical conditions of existing development, and if appropriate
pioneer and establish a pattern or identity from which future development can
take its cues.

189
Intent: To focus on the design consideration of organizing the many

architectural elements of a building into a unified whole, so that details and
features can be seen to relate to the structure and not appear as add-ons, and
the building form derives from its function and integrates into the surrounding
architectural context.
Guidelines:
Create a well-proportioned and unified building form that exhibits an
overall architectural concept expressed in distinct architectural features
and details.
Architectural features may shall include a minimum of three (3) of the

following:
o Building modulation or articulation
o Bay windows or balconies
o Corner accent, such as a
turret or clock tower
o Garden or courtyard
elements (such as a
fountain or gazebo)
o Rooflines
o Building entries
o Building base
o
Architectural details may shall include a

minimum of five (5) of the following:
o Treatment of masonry - such as
ceramic tile inlay, paving stones, or
alternating brick patterns
o Treatment of siding - such as wood
siding combined with shingles
o Articulation of columns
o Sculpture or art work
o Architectural lighting
o Detailed grills and railings
o Special trim details and moldings
o Trellis or arbor
o Awnings or canopies

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Exhibit building form and features

that identify the functions within
the building, such as:
o Grand entry for financial
institution
o Balconies for residential
o
Clearly distinguish roofline or top of the
structure from the buildings facade.
Ensure new buildings are compatible with

existing architectural features that have set
an aesthetic pattern, including the following:
o Fenestration patterns
o Building proportions
o Complementary buildingBuilding
materials
o
Support the human scale and provide visual
interest in the structure by including the
following:
o Step back or extend forward a portion of the faade.
o Provide porches, patios, decks or covered entries.
o Provide balconies or bay windows.
o Change the roofline by alternating dormers, stepped roofs, gables
or other roof elements to reinforce the modulation or articulation of
the structure.

191
o Change the materials with a change in the building plane, making

the store front or ground floor distinct.
o Provide lighting fixtures, trellises, trees or other landscape features
to support human scale.
o
Design and organize the fifth elevation the roofscape rooftop
elements to minimize visual impacts from surrounding buildings.
Exterior Finish Material

Overview: Building exteriors should be constructed of
durable, sustainable, and maintainable lasting,
renewable, and easy to maintain materials that are
attractive even when viewed up close.
Intent: To encourage the use of durable and

sustainable building materials that have texture,
pattern, or lend themselves to a high quality of detailing.
Guidelines:
Use materials that by their nature, provide a sense of
permanence, and can provide texture or scale that
helps new buildings fit better into their surroundings.
Examples of these exterior building materials include
the following:
o Stained or painted wood siding
o Shingles
o Brick
o Stone
o Ceramic and terra-cotta tile

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o
Provide entries, plazas, or other
semi-public or public spaces
with a visually interesting
ground plane, such as:
o Use of local materials
o Recording history and tradition
o Designs that delight
Human Scale
Overview: The term "human scale" generally refers to
architectural features and site design elements oriented to
human proportion and activity. A building has a good
human scale if its details, elements and materials allow
people to feel comfortable using and approaching it.
Features that give a building human scale also encourage
human activity (see Golden Ratio in glossary).
Intent: To design new buildings and public spaces that incorporate architectural
features, elements and details that achieve a good human scale.
Guidelines:
Utilize the following building elements to achieve human scale:
Distinctive ground floor building materials from upper
stories.
Alternation of dormers, stepped roofs, gables or other

roof elements to reinforce the modulation or articulation
of the structure.
Pedestrian weather protection in the form of

canopies, awnings, arcades or other elements
wide enough to protect at least one person.

193
Pedestrian-oriented open space such as a courtyard, garden, patio, or

other unified landscaped areas.
Bay windows that reflect an internal space such as a room or

alcove.
Large areas of glazing separated through the use of

moldings or door jambs.
Trim or molding that appears substantial from the

sidewalk and is separated from adjacent windows
by a vertical element.
Large areas of glazing separated through

the use of moldings or door jambs.
Windows with small multiple panes of glass.
Window patterns, building articulation and other treatments

that help to identify individual residential units in a multi-family building.
Upper story setbacks.

A porch or covered entry.
Pedestrian weather protection in the form of canopies, awnings, arcades
or other elements wide enough to protect at least one person.
Visible chimneys.
Commercial Entrances
Overview: The space between the
building and the public right-of-way may
be conducive to pedestrian or resident
activity. In a business district, where
pedestrian activity is desirable, the
primary function of open space between
commercial buildings and the sidewalk is
to provide visual and physical access to
activities such as vending, sitting or dining, as well as convenient and attractive
access to the building. Whether for commercial activity or user access, the

194
semi-public and private space should ensure comfort and security, be sufficiently
lighted, and entry areas should be protected from the weather.
Intent: To provide opportunities in commercial and mixed-use buildings for

entrances and associated spaces that are lively, attractive, comfortable, and
secure for the pedestrian or resident.
Guidelines:
Where there is sufficient distance between the building and
the public right-of-way, provide the following features:
o Walking surfaces with attractive pavers
o Pedestrian-scaled site lighting
o Area for commercial display or

activities
o
o Landscaping that screens undesirable
elements or that enhances the public
space and architecture
o Signage which identifies uses and
shops clearly but are scaled for the
pedestrian
o
o Site furniture, artwork or amenities
such as fountains, benches,
pergolas, kiosks, etc.
o
o Other methods that meet the intent of these criteria
o
Ensure special detailing or architectural
features at entrances, such as the
following:
o Ornamental glazing, railings or
balustrades
o Awnings or canopies
o Decorative pavement and lighting

195
o Seating
o Architectural molding
o Planter boxes, containers, or
trellises
o Artwork signs and visible building
address
Residential Entrances
Overview: Whether housing is mixed in with
commercial projects or stand alone, entries need to
provide security, a sense of privacy, and identity for
the occupants and their visitors.
Intent: To provide safety, privacy and visual interest

for residential uses.
Guidelines:
In residential mixed-use buildings, enhance the character
of the streetscape and create a transition between the
public sidewalk and private entry by providing the
following:
o Recessed or courtyard entries
o Small gardens
o Weather protection and/or grand
canopies
o Stoopeds entries or grand stairways
o Change in glazing or window frame
o Contrasting trim or distinctive
surrounds
o Lighting
o Distinctive addressing
o Accented paving
o Other methods that meet the
intent of these criteria

196
Create unique unit entries in townhouse/rowhouse

residential buildings by providing the following:
o Entrances with stoops
o Covered porch or entry
o Transitional spaces such as portals or arcades
o Distinctive paving of on-site walkways
o Surrounds around entry doors
using color, texture and building
material
Locate multi-family/mixed-use main
entrances on the primary pedestrian
corridor within commercial areas and
ensure they are clearly identifiable.
Ensure adequate transition between
public and private space in multi-family/mixed-use entries while
remaining inviting to pedestrians by providing the following:
o Recessed or courtyard entries
o Stooped entries or grand stairways
o Contrasting trim or distinctive surrounds
o Lighting
o Weather protection and/or grand canopies
o Accented paving
Blank Walls
Overview: In the pedestrian-
oriented Transit VillageMidway
Overlay DistrictsTransit Oriented
Community, every effort should be
made to buildings should avoid
large blank walls to increase
pedestrian interest and reduce
opportunities for taggers or other
graffiti.

197
Intent: To ensure a friendly streetscape, blank walls should be avoided, and if

they are unavoidable, they should receive design treatment to increase
pedestrian comfort, interest, and visual aesthetics.
Guidelines:
Avoid large blank building walls especially near public
and private sidewalks and pedestrian pathways.
Avoid retaining walls that extend higher than eye level

near a public sidewalk and between properties.
Provide special treatment for blank walls longer than
twenty (20) feet and visible from pedestrian

walkways, parking areas, and adjacent properties.
The following treatments may be used:
o Vertical trellis in front of the wall with supporting
climbing vines or plants materials.
o A landscaped planter Planter bed in front of the
wall back, planted withcontaining a rich
assortment of plant materials that vary

in height, texture, and color.
o Pedestrain-orientedArt art (mosaic,
mural, decorative masonry pattern,
sculpture, relief, etc.) over a
substantial portion of the blank wall
surface.
o Small setbacks, indentations, change of
building materials or other means of breaking up the wall's surface.
o Other methods that meet the intent of these criteria.
Parking Near Sidewalks

Overview: Parking below grade or structured parking is
preferredpreferred; within the Transit Community Overlay
District (TCOD); however, some surface parking lots near
sidewalks are expected. Parking lots near sidewalks are similar

198
to blank walls, adding little interest to the pedestrian experience. Minimally

parking lots should provide adequate security and lighting, avoid encroachment
of vehicles onto the sidewalk, and minimize the visual clutter of parking lot signs
and equipment.
Intent: To design parking facilities that are pedestrian-friendly, safe, and easily
maintained to maximize a lively street front.
Guidelines:
Separate surface parking lots or carport areas
adjacent to public rights- of- way by a low screen
wall with plantings or plantings alone 24 to 36
inches high (and per KCC 15.07 and Kent Design &
Construction Standards)(utilizing treatments and
features listed under Blank Wall section of
Architectural Design).
Separate surface parking lots or car port areas adjacent

to public rights-of-way by a continuous hedge 24 to 36
inches high at maturity (within 7 years) contained within
curbing.
Ensure parking structures at-grade and
accessory parking garages are
architecturally compatible with the main
structure and streetscape using
architectural detailing (i.e., frieze,
cornice, canopy, overhang, trellis or other
devices to cap the parking structure).
Design a parking structure to provide visual interest

to the streetscape or adjacent property by
providing the following:
o Commercial uses at the ground floor.
o Dense landscaping that provides variety,
height, texture, and color.
o Landscaping and architectural features to
parking entrances.
o Techniques found in the Blank Walls
section of Architectural Design.

199
o
Ensure pedestrian walkways, ramps, and stairways associated withthat
surface parking areas andor parking structures, pedestrian walkways,
ramps, and stairways are well-lit for safety with non-glare lighting to
respect adjacent uses (see Kent Design & Construction Standards).
When the uses surround the parking structure, utilize some or the
entire top of a parking structure for open space, recreation, or patio.
Prohibit encroachment of vehicles onto the sidewalk or into landscaped
areas by providing wheel stops about two (2) feet from the sidewalk or
landscaping.
Personal Safety and Security

Overview: New projects should consider
opportunities to enhance personal safety and security
for the residents, workers, shoppers and visitors who
enter the area.
Intent: To reduce crime and create an increased

feeling of personal safety and security through increased activity at street level
using building design elements and improved pedestrian gathering places.
Guidelines:
Enhance public safety to foster 18-hour public activity. To
accomplish this goal, utilize the following methods:
o Strategically locate pedestrian and streetscape
lighting.
o Focus on key functional or aesthetic elements such
as doorways, windows, signage, and architectural
details.
o Design public spaces to have clear
sight lines.
o
Use reduced glare security lighting fixtures
so as not to hamper the vision of
pedestrians, bicyclists, drivers or adjacent
property uses.

200
Consider motion-detector lights in areas not needing constant night lights.
Use semi-transparent security screening, rather than opaque walls,

wherever appropriate.
Avoid blank, windowless walls that attract graffiti and that do not permit
residents or workers to observe the street.
Use landscaping that maintains visibility, such
as short shrubs and pruned trees, so there are
no branches below head six (6) foot height at
10 years after installation.
Use creative ornamental grille as fencing or

over ground floor windows wherever
appropriate.
Eliminate structures that provide hiding places for criminal activity.
Design parking areas to allow natural surveillance by

maintaining clear lines of sight both for those who park
there and for occupants of nearby buildings.
Encourage "eyes on the street" through

placement of windows, balconies and
street-level uses.
Ensure natural visibility of children's play

areas and other semi-public spaces.
Signage
Overview: There are two environments within
the Midway Transit Community Overlay District
(TCOD). One fronts SR-99 and is auto-
orientedHighway Oriented with large volumes

201
of traffic moving at relatively high speeds. The other environment is the more
pedestrian-oriented Pedestrian Oriented andstreets located on streets to the
east and west of SR-99 where the streets are narrow, vehicular speeds are
greatly reduced, and the pedestrian is dominant. While different, both are
treated as pedestrian-oriented by providing visual interest and human dimension
to street-level building facades. The following are additional guidelines for
signage.
Intent: To create signs that are engaging, creative, and effective for a variety of
user groups and respond to a variety of pedestrian and vehicular environments.
Guidelines:
Design signage as an integral part of the building faade and
architecture adding interest for the pedestrian and integrity
in building design.
Encourage creative and individual expression in the design

and placement of signs.
Encourage creative, sculptural, and neon signs.
Placement of signage shall not obscure or

overlap architectural elements.
Glass buildings shall incorporate a sign band

into the building design to accommodate
signage.
High-rise buildings shall consolidate multiple

signs.
Use lighting to accent signs.

For development over 2 acres in size, create a
Master Sign Plan shall be created that is in
keeping with the objectives of the Midway
Design Guidelines.
Provide the following signs when associated
with parking:
o Individual parking-stall signs should be
no higher than a car bumper.
o Parking management signs should be
placed no higher than 6 from ground
level.

202
Encourage creative, sculptural, and neon signs.
Size & Placement

Highway Oriented:
One freestanding lighted and double-faced identification sign, is allowed
per parcel or complex for use by the tenants of a shopping center. The
sign shall not exceed 15 feet in height and shall be integrated with
landscaping.
Monument signs shall be below 10 feet in height measured from the top
of the sign to the ground plane, provide a substantial base, be integrated
with landscaping and reflect the character of the associated building.
Directional signs for parking shall be limited to one sign per entrance and
shall not extend more than 12 above the ground for parking garages.
Cabinet signs may be lit from behind.
Signs should be building-mounted.
Pedestrian Oriented:
Use high quality, creative, and expressive sign design for individual
business.
Flashing, moving or animated signs are not permitted.
Mount signs on buildings, hung from canopies, or traditional such as
barber poles placed at a height appropriate in a pedestrian environment
(no higher than 15 feet).
Monument signs shall be no taller than seven (7) feet in height measured
from the ground plane and shall be integrated with landscaping.
Cabinet signs shall be lit from above or reverse pan channel.
Freestanding pole signs are prohibited
Identification and directional signs for parking shall be limited to
one sign per entrance and shall not extend more than 12 above
the ground for parking garages.
Lighting
Overview: Lighting plays a critical role in the character of a
place as well as for safe movement of

pedestrians and vehicles. Well designed lighting
limits glare and light pollution while providing
security. Light can also provide visual interest
by accenting trees, building facades, or
providing fanciful ambient light.

203
Intent: To provide artificial lighting that promotes visual interest and a sense of
security for people in commercial and residential areas during evening hours.
Guidelines:
Encourage illuminating distinctive features of
the building, such as entries, signage, and
areas of architectural detail and interest.
Ensure lighting fixtures complement the

building faade.
Utilize energy-saving night lighting (see Personal Safety and Security in

the Architectural Design section).
Utilize downward-directed lighting at entries and

along walkways so as not to cast glare into right
of way and neighboring uses (see Kent Design &
Construction Standards.
Consider motion-detector lights in areas not

needing night lights.
Encourage illuminating distinctive features of the building, such as
entries, signage, and areas of architectural detail and interest.
Backlighting plastic or fabric covered awnings is not allowed.
Public and semi-public

Street Lighting within the TCOD and east of SR-99 shall be
non-glaring with cut off fixtures to minimize light spilling over
onto adjacent properties or public ROW as specified for
Residential Collector Street Classification found in Kents
Design & Construction Standards Manual (KDCS). If these
guidelines and the Construction Standards ManualKDCS
conflict, the guidelines control.

204
Pedestrian- oriented lighting shall be used in all parks, plazas, or

pathways to provide safety while minimizing light spillover on to adjacent
properties.
Private
Ensure flood lighting in delivery areas is directed downward to limit glare
and is active only during the time of delivery; otherwise, security lighting
in delivery areas or high risk areas shall be low wattage and directed
downward to be sensitive to adjacent uses.
Ensure accent lighting is appropriate to and

complements the overall character of the public or semi-
public setting.
Minimize building facade lighting to be sensitive to
residences and drivers.
Ensure accent lighting is appropriate to the overall
character of the public or semi-public setting.
Landscaping and Open Space

Overview: Landscaping and green
open spaces within the Transit
Villageland use designated Midway
Transit Community Overlay District
softens the urban form by integrating
the building into the natural
environment and creating public and semi-public
spaces for human interaction.
Intent: To create an intimate and human scale environment through the use of
hardscape or greenscape which reinforces, complements and enhances the
public streetscape and public open spaces and contributes to the natural
environment while discouraging oversized spaces that lack containmenthuman
scale.

205
Guidelines:
Landscaping includes living plant
materials, special pavements, trellises,
screen walls, planters, site furniture
and similar features that enhance the
overall project design. Utilize the
following guidelines:
o Select plant materials based on
soil conditions and light exposure
first, followed by form, texture and color to ensure an interesting
landscape that will thrive within the niche in which they have been
planted.
o When selecting plant materials, utilize drought tolerant species and
plants that support wildlife by creating habitat.
o Use similar landscape construction materials, textures, colors or
elements to fit into the surrounding content context to achieve
design continuity.
o
Create plazas and courtyards that are welcoming and
comfortable for human activity and social interaction while
moving through, as well as sitting and standing within.
Amenities to consider are:
o Planters and trees
o Seating benches, tables & chairs,
low seating walls
o Special paving
o Bollards and intimateor other
pedestrian lighting that accents the
building and landscape, and
facilitateswhile facilitating pedestrian movement
o Public art
o Water feature
Take advantage of special on-site conditions such as slopes, view

corridors, significant trees, nearby publicly owned greenbelts or open
space, or adjacent private open space in the following manner:

206
o Support the creation of a passive and active open space that may
include pooling on-site open space requirements to create larger
spaces.
o Whenever possible, link semi-public spaces with adjacent public
open spaces to facilitate movement from one place to another.
o Wherever possible, retain existing mature trees in a manner that
ensures longevity; otherwise replace significant trees with a
minimum three (3) inch diameter at breast height (DBH) caliper
trees if deciduous or six (6) foot tall if coniferous.
o Street trees shall not be planted within 20 feet of any street light
(see Kent Design & Construction Standards).
o If a street has a uniform planting of street trees, or a distinctive
species, install street trees that match the existing tree form or
species (per KCC 6.10).
Enhance the built form through the use of plant

materials, paving, and other features such as the
following:
o Emphasize entries with special
planting, decorative paving and
lighting.
o Consider special features
within a courtyard such as a
fountain or pool.
o Consider integrating artwork into
publicly accessible areas to evoke a
sense of place.
o Distinctively landscape open areas
created by building modulation
o Incorporate upper story planter boxes
and roof planters.
o Encourage water features, including
natural marsh-like installations.
o Where wheelchair ramps are provided on the street front, include a
planting strip next to the sidewalk.

207
Definitions
Articulation Where built elements connect.
Balcony A balcony projects from a building and is enclosed by a railing,

balustrade, or parapet.
Bay Window A bay window protrudes from an exterior wall.
Blank Walls A blank wall is over five feet (5) in height measured from finished
grade at the base of the wall and longer than 20 measured horizontally, and does
not have any significant building feature, such as a window, door, or other special
wall treatment along that surface.
Courtyard A courtyard is an open space that is enclosed on three or more sides

by walls or a building, and that is open to the sky.
Faade Generally, a faade refers to one side of the exterior of a building,

especially the front since it is the most important from a design standpoint and
typically contains the primary public entry and faces the public street.
Fenestration Fenestration is the design and arrangement of openings in a building

envelope, such as windows, doors, and skylights.
Gateways Key intersections that are entranceways into the Midway Subarea.
Golden Ratio The golden ratio is a mathematical constant and used in the arts by
architects and artists in an effort to proportion their works to be aesthetically
pleasing. The following is the algebraic expression of the geometric relationship:
a + b/a + a/b =
Pedestrian-friendly Pedestrian-friendly, or walkability, is a measure of how
friendly an area is for walking. Factors influencing walkability include the presence
or absence and quality of footpaths or sidewalks, traffic and road conditions, land
use patterns and their intensity, building accessibility, and safety, among others.
Pedestrian Scale Pedestrian scale is the perceived height and bulk of a building
relative to other forms in its context.
Service Areas Service areas refer to enclosed or open areas, containing

equipment and uses such as ground level mechanical equipment, utility vaults,
loading zones, outdoor storage areas, and trash and recycling areas.
Site Planning Site planning is the organization and arrangement of structures,

land form, circulation, parking, landscaping, drainage, privacy, public open spaces,
and other facilities on a specific site. Good site planning will result in a cohesive
208
site design concept and take into consideration natural features, slope, hydrology,
vegetation, land ownership, orientation, the uses and design of neighboring sites,
and other features in the immediate vicinity of the site.
Streetscape The streetscape is the visual character and quality of a street as

determined by various elements located between the edge of the street and the
building face, such as trees and other landscaping, street furniture, artwork, transit
stops, utility fixtures and equipment, and paving. Where there are frequent and
wide spaces between buildings, the streetscape will be defined by the pattern of
building and open space and the character of that open space.
Surface Parking Surface parking is single level vehicular parking located at ground
level.
Structured Parking Structured parking is a multiple level structure designed

specifically to be for automobile parking, in whole or in part.
Appendix D
Draft Midway Zoning Map
ATTACHMENT B - LUPB PUBLIC SHEARING 11/22/10
249
228 ST
ST
TH
S 228 PL
S 23 PL
U
229
ND
S
ER
S 230 ST
BIR
S 230 ST
27 AV S
D
AV
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S
S 231
RD
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AV
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S 23 2
1 ST
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S2
32 ER
PL LG
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S 232 ST
S 233 ST
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S 234 ST EXIT
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149B
S 234 ST
e
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ng
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EXIT
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30 AV
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PACIF
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DES MOINE
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23 23
35 L S
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9
P
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43 AV
S2
S 239 PL
S 240 ST
38 P
ST
18 PL S
S 241 ST
S RD
28 AV S
R
A GE
S 242 ST
FR
26 AV S
39 AV
S 242 ST
S 243 ST S 243 PL
21 AV S
MILITARY RD
S
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K
EE
S 243 ST CR
25 AV S
S 244 ST
22 AV S
22 PL S
35 PL S
24 AV S
AV
PL
23 AV S
AY
MIDW
S 244 PL S 244 ST
G
S 244 ST RE
EN
27
S 245 CT
26
35 AV S
S 245 PL
S 246 CT
S 246 ST
36 AV S
46 ST ST
S 247
48
CT
S 247
PL
S 248 ST
S
S 248 ST
S 248 ST S 248 ST
20 AV S
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S 249 PL
ng
51
PL
OPTION #3 - ZONING
L PL
AV S
PL P 35
PL
49 48 9
6
S S2 S2 24 S 249 ST
34
ha
19
S
S
AV
AV
99
DISTRICT DESIGNATION
RD
35 PL S
S
22
SR
251 S 250 ST S 250 ST

C
S ST
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AV
AV S
AV
42 AV S
S 250 PL
o
23 PL S
19 PL S
S 251 ST
25
S 251 ST
N
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21
FENWICK RD
43
S 252 ST
21 PL S
REIT
S 251 PL
LEGEND 251
30 AV S
S 252 ST S 252 ST CT PONDS
38 AV S
S 252
S 253 ST PL 37 PL
ZONING S 252 PL
S
S S 252 PL
LS
S 253 PL S 253
ST S 253
43 P
AV S
S 254 ST
36 PL S
AV
ST
Midway Transit Community 1 (MTC-1)
45 PL S
LS
S 25 S 253
4 S 254
45
17 P
ST PL
S
S
31 AV
22 AV S
LS
S 254
S
ST
34 PL S
S 254
33 PL
PL
PL
ST 2
Midway Tansit Community 52 P
255 4
(MTC-2) 42
29
PL
39 PL S
PL
38
S 255 ST S 255 PL S
S 256 256 ST
S 255
LAKE
S 256 ST
Midway Commercial/Residential (MCR)
AV S
46
32
35 PL S
S 256
256
CT PL S
S 257
S 257 PL
PL
ST
Community Commercial
S (CC)
18 AV S
257
19 AV S
20 AV S
1
45
27 PL S
S 258 ST
257 ST
33 AV S
34 AV S
FENWIC
PL
S 258 PL
CT ITH RE D
S 259
ST
Commercial Manufacturing
R
2 (CM-2) 258 PL
S 259 ST
K
5 9
S2 S 259
LS
Mobile Home SPark (MHP)

P
S 260 ST S 260
36
260 ST
42 AV S
ST
RD
AV S
LAKE
MIDWAY STUDY AREA
25 AV
S 261 PL S 261 ST
FENW
S 261 PL
POTENTIAL
S 262 ST ANNEXATION AREA
S
ICK
19 AVE S
PL
18 AV
43 PL
44
ng
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P
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CITY LIMITS
L
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AV
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LS
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P
63 PL
39
41
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AV S
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AV
ha
YALE
PL
AV S
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34
CT
EATON
40
S 264 ST
CT
SOMERSET
CT
KENT
CT
C
S 265 PL E
MANCHESTER
S 265 ST G
ID SOMERSET
BR HAMPTON CT
19 PL S
CT
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S 266 M
PRINCETON AV
CA
AV
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CAMBRIDGE CT
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18 PL S
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28 AV S
CT
S 268 ST BURY LN
RD
33 AV S
STANFO
S 268 ST ICK CT
FENW
40 AV S
35 PL
CARNABY
CT
17 PL S
PRIV. 269 S 269 ST

WY
52

ST
ARDEN CT
ON
DOWNING
YS
AV
36
SA X
AVON
Midway Subarea
270
HW
AV
51
S 270
35 AV S
CARDIFF AV
ST S 270 ST
37 AV S
IFIC
ST
PL S
36
1"=1,600'
PL
PAC
46 AV S
ST
31 AV S
71
36
S2
271 S
S
39 AV S
LN
AV S
This map is a graphic aid only and is not a legal document. The City of Kent
41 PL S
PL no warranty to the accuracy of the labeling, dimensions, contours,

36 LN
PRIV.
makes
PRIV.
35
S property boundaries, or placement S 272 ST

or location of any map features depicted
ST
AR thereon. The City of Kent disclaims and shall not be held liable for any and all
PL S
damage, loss, or liability, whether direct or indirect, or consequential, which

S

LN
42 PL S
43 CT
33 PL S
S
45 PL
Source: City of Kent Planning Services

S
S 273 PL
24
24
ST
48 AV S
S 274 ST S 273
S
V
250

Appendix E
Draft Midway Zoning and Development Regulation Amendments
Op3_LURes 214
Option #3 - Kent City Code 15.04 District Regulations

(Amend as Preliminarily Approved by the LU&PB in Public Hearing April 26, 2010)
Chapter 15.04 City of Kent Land Use Tables
Option #1 & #2 Midway
Overlay District New
Key Zoning Districts Existing Zoning Districts
P = Principally Permitted Uses
M-TC-1 Midway- Transit
Manufacturing-2 District
Commercial/Residential

M-TC-2 Midway Transit
S = Special Uses
Community- 2 District
Community-1 District
Commercial District
C = Conditional Uses
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
KCC 15.04.020 Residential Land Uses
One single-family dwelling per lot P
One duplex per lot
One modular home per lot
Duplexes
Multifamily townhouse units P P P P(2)
Multifamily dwellings P P P P(2)
Multifamily dwellings for senior citizens P P P P(2)
Mobile homes and manufactured homes P
Mobile home parks P
Group homes class I-A C P P P P C
Group homes class I-B C P P P C
Group homes class I-C C C C P C
Group homes class II-A C C C C C
Group homes class II-B C C C C C
Group homes class II-C C C C C C
Group homes class III C(23) C(23) C(23) C(23) C(23)
Rebuild/accessory uses for existing dwellings P(6) P(6) P(6) P(6) P(6)
Transitional housing P(7) P(7)
Guest cottages and houses
Rooming and boarding of not more than three (3) persons
Farm worker accommodations
Accessory uses and buildings customarily appurtenant to a
permitted use A A A A A
Accessory dwelling units
Accessory living quarters A(14) A(14) A(14) A(14) A(14)
Live-work units P(28)
Home occupations A(11) A(11) A(11) A(11) A(11) A(11)
Service buildings A
Storage buildings and storage of recreational vehicles A
11/15/2010 S:\Permit\Plan\COMP_PLAN_AMENDMENTS\2007\CPA-2007-4_MIDWAY\LUPB\Regulations\Midway_Regs090210.xls 1 of 3
Op3_LURes 215


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
Drive-in churches; welfare facilities (including emergency
shelters); retirement homes, convalescent homes, and
other welfare facilities whether privately or publically
operated, facilities for rehabilitation or correction, etc. C(12) C(12) C(12) C C(12)
Designated manufactured home P(25)
15.04.030 Residential land use development conditions (excerpts relevant to above table)
(2) Multifamily residential use shall be permitted only in the mixed use overlay when included within a mixed use
development.
(6) Existing dwellings may be rebuilt, repaired, and otherwise changed for human occupancy. Accessory uses for
existing dwellings may be constructed. Such uses are garages, carports, storage sheds, and fences.
(7) Transitional housing facilities, limited to a maximum of twenty (20) residents at any one (1) time and four (4)
resident staff.
(11) Customary incidental home occupations subject to the provisions of KCC 15.08.040.
(12) Except for transitional housing, with a maximum of twenty (20) residents and four (4) staff, which are principally
permitted uses.
(14) Accessory living quarters are allowed per the provisions of KCC 15.08.359.
(23) Secure community transition facilities are permitted only in the GWC zoning district.
(25) A designated manufactured home is a permitted use with the following conditions:
a. A designated manufactured home must be a new manufactured home;

b. The designated manufactured home shall be set upon a permanent foundation, as specified by the manufacturer,
and the space from the bottom of the home to the ground shall be enclosed by concrete or an approved concrete
product that can be either load bearing or decorative.
c. The designated manufactured home shall comply with all city design standards applicable to all other single-family
homes;
d. The designated manufactured home shall be thermally equivalent to the State Energy Code; and
e. The designated manufactured home shall meet all other requirements for a designated manufactured home as
defined in RCW 35.63.160.
Op3_LURes 216


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
Amend Kent City Code 15.04.030 - Residential land use development conditions, as follows
(insert after 27.)
....
(28) Live-work units; provided, that the following development standards shall apply for live-work units, in
addition to those set forth in 15.04.190.
a. The unit shall contain a cooking space and sanitary facility in conformance with applicable building standards;
b. Adequate and clearly defined working space must constitute no less than fifty percent of the gross floor area of
the live/work unit. Said working space shall be reserved for and regularly used by one or more persons residing
there;
c. At least one resident in each live/work unit shall maintain at all times a valid city business license for a business
on the premises;
d. Persons who do not reside in the live/work unit may be employed in a live/work unit when the required parking
is provided;
e. Customer and client visits are allowed when the required parking is provided;
f. No portion of a live/work unit may be separately rented or sold as a commercial space for a person or persons
not living on the premises, or as a residential space for a person or persons not working on the premises;
g. The multiple-family design guidelines and development standards do not apply to live/work units;
h. Construct all nonresidential space, to the maximum allowed, to commercial building standards; and
i. Provide an internal connection between the residential and nonresidential space within each unit.
....
Op3_LUManu 217


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
KCC 15.04.040 Manufacturing Land Uses
Manufacturing, processing, blending and packaging of food
& beverage products P(23)
Manufacturing, processing, blending, and packaging of
drugs, pharmaceuticals, toiletries, and cosmetics P
Manufacturing, processing, blending, and packaging of
dairy products and byproducts P
Industrial laundry and dyeing (including linen supply and
diaper services) P
Printing, publishing, and allied industries P
Chemicals and related products mfg.
Contractor shops P(5)(3)
Custom arts and crafts products mfg.
Computer, office machines, and equipment mfg. P(3)
Manufacturing and assembly of electrical equipment,
appliances, lighting, radio, TV communications, equipment,
and components P(3)
Fabricated metal products mfg., custom sheet metal mfg.,
containers, hand tools, heating equipment, screw products,
extrusion, coating, and plating P
Manufacturing and assembly of electronic and electrical
devices, and automotive, aerospace, missile, aircraft, and
similar products P(3)
Hazardous substance land uses A(7) A(8) A(7)
Offices incidental and neccessary to the conduct of a
principally permitted use A A A P
Warehousing and distribution facilities P(16)
Rail-truck transfer uses
Outdoor storage (including truck, heavy equipment, and
contractor storage yards as allowed by development
standards, KCC 15.04.190 and 15.04.195) P
Miniwarehouses self-storage C C(19) P
Manufacturing of soaps, detergents, and other basic
cleaning and cleansing preparations
Op3_LUManu 218


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
Manufacturing of plastics and synthetic resins
Manufacturing of synthetic and natural fiber and cloth
Manufacturing of plywood, composition wallboard, and
similar structureal wood products
Manufacturing of nonmetallic mineral products such as
abrasives, asbestos, chalk, pumice, and putty
Manufacturing of heat-resisting or structural clay products
(brick, tile, or pipe) or porcelain products
Manufacturing of machinery and heavy machine tool
equipment for general industry and mining, agricultural,
construction, or service industries
Manfacturing, processing, assembling, and packaging of

articles, products, or merchandise made from previously
prepared natural or synthetic materials
Manufacuturing, processing, treating, assembling, and

packaging of articles, products, or merchandise from
previously prepared ferrous, nonferrous, or alloyed metals
Complexes which include a combination of uses, including a

mixture of office, storage, and light manufacturing uses
P
Accessory uses and buildings customarily appurtenant to a A(9) A(9) A(9)
permitted use (10) (10) (10) A(9) A(9)
Impound lots C
15.04.050 Manufacturing land use development conditions: (excerpts relevant to above table)
(3) Small scale light manufacturing operations as follows: stamping, brazing, testing, electronic assembly, and
kindred operations where the building, structure, or total operation does not encompass more than ten thousand
(10,000) square feet of area. The ten thousand (10,000) square foot total shall include all indoor and outdoor storage
areas associated with the manufacturing operation. Only one (1) ten thousand (10,000) square foot manufacturing
operation shall be permitted per lot.
Op3_LUManu 219


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
(5) Contractor shops where most of the work is done on call, and which do not rely on walk-in trade, but where
some incidental storage or semi-manufacturing work is done on the premises, such as carpentry, heating, electrical,
or glass shops, printing, publishing, or lithographic shops, furniture, upholstery, dry cleaning, and exterminators.
(7) For permitted uses, accessory hazardous substance land uses, including onsite hazardous waste treatment or
storage facilities, which are not subject to cleanup permit requirements of Ch. 11.02 KCC, subject to the provisions of
KCC 15.08.050, except offsite hazardous waste treatment or storage facilities, which are not permitted in this district.
Fuel farm facilities are not allowed in AG or A-10 zones.
(8) For permitted uses, hazardous substance land uses, including onsite hazardous waste treatment or storage
facilities, which are not subject to cleanup permit requirements of Ch. 11.02 KCC and which do not accumulate more
than five thousand (5,000) pounds of hazardous substances or wastes or any combination thereof at any one (1) time
on the site, subject to the provisions of KCC 15.08.050, except offsite hazardous waste treatment or storage facilities,
which are not permitted in this district.
(9) Includes incidental storage facilities and loading/unloading areas.
(10) Includes incidental storage facilities, which must be enclosed, and loading/unloading areas.
(16) Warehousing and distribution facilities and the storage of goods or products, except for those goods or products
specifically described as permitted to be stored only as conditional uses in the M3 district.
(19) Miniwarehouses; provided, that the following development standards shall apply for miniwarehouses, superseding
those set out in KCC 15.04.190 and 15.04.200:
a. Frontage use. The first one hundred fifty (150) feet of lot depth, measured from the property line or right-of-way
inward from the street frontage, shall be reserved for principally permitted uses for this district, defined by the
provisions of KCC 15.04.100(A)(1), or for the office or onsite managers unit, signage, parking, and access. A maximum
of twenty-five (25) percent of the frontage may be used for access to the storage unit area; provided, that in no case
shall the access area exceed seventy-five (75) feet in width. No storage units or structures shall be permitted within
this one hundred fifty (150) feet of commercial frontage depth.
b. Lot size . Minimum lot size is one (1) acre; maximum lot size is four (4) acres.
c. Site coverage . Site coverage shall be in accordance with the underlying zoning district requirements.
d. Setbacks . Setbacks shall be as follows:
(1) Front yard: Twenty (20) feet.
(2) Side yard: Ten (10) feet.
Op3_LUManu 220


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
(3) Rear yard: Ten (10) feet.
e. Height limitation . The height limitation is one (1) story.
f. Outdoor storage . No outdoor storage is permitted.
g. Signs. The sign requirements of Ch. 15.06 KCC shall apply.
h. Off-street parking .
(1) The off-street parking requirements of Ch. 15.05 KCC shall apply.
(2) Off-street parking may be located in required yards, except in areas required to be landscaped.
i. Development plan review. Development plan approval is required as provided in KCC 15.09.010.
j. Landscaping . Landscaping requirements are as follows:
(1) Front yard: Twenty (20) feet, type III (earth berms).
(2) Side yard: Ten (10) feet, type II abutting commercial uses or districts; type I abutting residential uses or districts.
(3) Rear yard: Ten (10) feet, type II abutting commercial uses or districts; type I abutting residential uses or districts.
For maintenance purposes, underground irrigation systems shall be provided for all landscaped areas.
k. Onsite manager . A resident manager shall be required on the site and shall be responsible for maintaining the
operation of the facility in conformance with the conditions of the approval. The planning department shall establish
requirements for parking and loading areas sufficient to accommodate the needs of the resident manager and the
customers of the facility.
l. Drive aisles . Drive aisle width and parking requirements are as follows:
(1) Fifteen (15) foot drive aisle and ten (10) foot parking aisle.
(2)Parkingformanagersquartersandvisitorparking.
m. Building lengths . The horizontal dimension of any structure facing the perimeter of the site shall be offset at intervals
not to exceed one hundred (100) feet. The offset shall be no less than twenty (20) feet in the horizontal dimension, with
a minimum depth of five (5) feet.
n. Building materials . If abutting a residential use or zone, residential design elements such as brick veneer, wood
siding, pitched roofs with shingles, landscaping, and fencing shall be used. No uncomplimentary building colors should
be used when abutting a residential use or zone.
o. Prohibited uses . Use is restricted to dead storage only. The following are specifically prohibited:
(1) Auctions (other than tenant lien sales), commercial,
wholesale or retail sales, or garage sales.
Op3_LUManu 221


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
(2) The servicing, repair, or fabrication of motor vehicles, boats, trailers, lawn mowers, appliances, or other similar
equipment.
(3) The operation of power tools, spray painting equipment, table saws, lathes, compressors, welding equipment, kilns,
or other similar equipment.
(4) The establishment of a transfer and storage business.
(5) Any use that is noxious or offensive because of odor, dust, noise, fumes, or vibration.
(6) Storage of hazardous or toxic materials and chemicals or explosive substances.
p. Fencing . No razor wire is allowed on top of fences.
(23) Excluding slaughtering, rendering, curing, or canning of meat or seafood products.
Op3_LUTranspo 222


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
KCC 15.04.060 Transportation, Public, and Utilities
Land Uses
Commercial parking lots or structures C C C
Transportation and transit facilities C C C C C
Railway and bus depots, taxi stands C C C
Utility and transportation facilities: Electrical substations,
pumping or regulating devices for the transmission of
water, gas, steam, petroleum, etc. C C C C C
Public facilities: Firehouses, police stations, libraries, and
administrative offices of governmental agencies, primary
and secondary schools, vocational schools, and colleges C C C C C
Wireless telecommunications facility (WTF) by
administrative approval P(1)(3) P(1)(3) P(1)(3) P(2)(3) P(1)(3)
Wireless telecommunications facility (WTF) by conditional
use permit C(4)(3) C(4)(3) C(4)(3) C(8) C(5)(3) C(4)(3)
EV Charging Station A (9) A(9) A(9) A(9) A(9) A(9)
Rapid Charging Stations A A A A A A
15.04.065 Transportation, public, and utilities land use development conditions: (excerpts relevant to above table)
(1) For WTF towers ninety (90) feet or less for a single user and up to one hundred twenty (120) feet for two (2) or
more users.
(2) For WTF towers that are within the allowable building height for the district in which they are located.
(3) All WTFs are subject to applicable portions of KCC 15.08.035.
(4) A conditional use permit for a WTF is required if it is greater than ninety (90) feet for a single user or one hundred
twenty (120) feet for two (2) or more users.
(5) A conditional use permit is required if the WTF exceeds the allowable building height of the district.
(8) If on property owned, leased, or otherwise controlled by the city or other government entity subject to KCC
15.08.035(I).
(9) Level 1 and 2 charging only.
Op3_LUWhol 223


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
KCC 15.04.070 Wholesale and Retail Land Uses
Bakeries & confectioneries P P P P
Wholesale bakery P
Bulk retail P(26) P(26) P
Recycling centers
Retail sales of lumber, tools, and other building materials,
including preassembled products P P
Hardware, paint, tile and wallpaper (retail) P P P P P
Farm equipment P P
General merchandise: Dry goods, variety and department
stores (retail) P P P P P
Food and convenience stores (retail) P P P P P
Automobile, aircraft, motorcycle, boat, and recreational
vehicles sales (retail) P P
Automotive, aircraft, motorcycle, and marine accessories
(retail) P P P P
Gasoline service stations S(6) S(6) S(6) S(6)
Apparel and accessories (retail) P P P P P
Furniture, home furnishing (retail) P P P P P
Eating and drinking establishments (no drive-through) P P P P P
Eating and drinking establishments (with drive-through) S(6)(20)
Eating facilities for employees P P P
Planned development retail sales
Drive-through/drive-up businesses (commercial/retail - P(a)
other than eating/drinking establishments) (24) P(24) P(20) P(20)
Miscellaneous retail: Drugs, antiques, books, sporting
goods, jewelry, florist, photo supplies, video rental,
computer supplies, etc. P P P P P
Liquor store P P P P P
Farm supplies, hay, grain, feed, fencing, etc. (retail) P P
Nurseries, greenhouses, garden supplies, tools, etc. P P P
Pet shops (retail and grooming) P P P
Op3_LUWhol 224


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
Computers and electronics (retail) P P P P
Hotels and motels P P(25) P P
Complexes which include combinations of uses, including a
mixture of office, light manufacturing, storage, and
commercial uses P
standards, KCC 15.04.190 and 15.04.195) P(19)
Accessory uses and buildings customarily appurtenant to a A(16)
permitted use (17) A(17) A(17) A(16) A(16)
Agriculturally related retail
Battery Exchange Station A(23) A(23) A(23) S(23) S(23)
Note: a. Option #3 - If two-story development within strip-mall or shopping center.
15.04.080 Wholesale and retail land use development conditions: (excerpts relevant to above table)
(6) Special uses must conform to the development standards listed in KCC 15.08.020.
(17) Includes incidental storage facilities, which must be enclosed, and loading/unloading areas.
(19) Reference KCC 15.07.040(C), outdoor storage landscaping.
(20) Whenever feasible, drive-up/drive-through facilities shall be accessed from the rear of a site and run along an
interior lot line or building elevation. Landscaping, sufficient to soften the visual impact of vehicle stacking areas, may
be required.
(23) All battery exchange activities and associated storage shall take place within an enclosed building. The
development standards listed in KCC 15.08.020.B shall apply, except that number three (3) shall not apply.
Amend Kent City Code 15.04.080 - Wholesale and retail land use development conditions, as follows (insert after
....
(24) Drive-through/drive-up businesses are permitted only under the following conditions:
a. The development must be within a strip-mall or shopping center.
(25) The ground floor or street level must be retail or pedestrian-oriented following the Midway Design Guidelines.
The main ground floor entry shall open to a public street with accessory retail uses accessible by pedestrians.
(26) Bulk retail is permitted only when single tenant building is over one acre in size.
....
Op3_LUServ 225


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
KCC 15.04.090 Service Land Uses
Finance, insurance, real estate services P P P P P
Personal services: Laundry, dry cleaning, barber, salons,
shoe repair, launderettes P P P P P
Mortuaries P P
Home day-care P P P P P P
Day-care center P P P P P P
Business services, duplicating and blue printing, travel
agencies, and employment agencies P P P P
Building maintenance and pest control P P
standards, KCC 15.04.190 and 15.04.195) P
Rental and leasing services for cars, trucks, trailers,
furniture, and tools P P
Auto repair and washing servies (including body work) P C P
Repair services: Watch, TV, electrical, electronic, upholstery

P P P
Professional services: Medical, clinics, and other health care-
related services P P P P P
Heavy equipment and truck repair P
Contract construction service offices: Building construction,
plumbing, paving, and landscaping P(16) P
Educational services: Vocational, trade, art, music, dancing,
barber, and beauty P P P P
Churches S(4) S(4) S(4) S(4) S(4)
Administrative and professional offices - general P P P P P
Municipal uses and buildings P(13) P(13) P(13) P(13) P(13)
Research, development, and testing P C P P
Planned development retail sales
Accessory uses and buildings customarily appurtenant to a A(18)
permitted use (19) A(19) A(19) A(18) A(18)
Boarding kennels and breeding establishments C
Op3_LUServ 226


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
Veterinary clinics and veterinary hospitals P(8) P(8) P(8) P(8)
Administrative or executive offices which are part of a
predominant industrial operation
Offices incidental and necessary to the conduct of a
principally permitted use
15.04.100 Service land use development conditions: (excerpts relevant to above table)
(4) Special uses must conform to the development standards listed in KCC 15.08.020.
(8) Veterinary clinics and animal hospitals when located no closer than one hundred fifty (150) feet to any residential
use, providing the animals are housed indoors, with no outside runs, and the building is soundproofed.
Soundproofing must be designed by competent acoustical engineers.
(13) Except for such uses and buildings subject to KCC 15.04.150.
(16) Contract construction services office use does not include contractor storage yards, which is a separate use listed
in KCC 15.04.040.
(19)Includes incidental storage facilities, which must be enclosed, and loading/unloading areas.
Op3_LUCultur 227


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
KCC 15.04.110 Cultural, Entertainment, and
Recreational Land Uses
Performing and cultural arts uses, such as art
galleries/studios P P P P
Historic and monument sites P
Public assembly (indoor): Sports facilities, arenas,
auditoriums and exhibition halls, bowling alleys, dart-
playing facilities, skating rinks, community clubs, athletic
clubs, recreation centers, theaters (excluding school
facilities) C C P P
Public assembly (outdoor): Fairgrounds and amusement
parks, tennis courts, athletic fields, miniature golf, go-cart
tracks, drive-in theaters, etc. C C P
Open space use: Cemeteries, parks, playgrounds, golf
courses, and other recreation facilities, including buildings P(7)
or structures associated therewith C(9) C(9) C(9) C C
Employee recreation areas
P(5) P(5)
Private clubs, fraternal lodges, etc.
C C C C C
Recreational vehicle parks
Recreational buildings in MHP A
15.04.120 Cultural, entertainment, and recreational land use development conditions: (excerpts relevant to above
table)
(5) Business, civic, social, and fraternal associations and service offices are principally permitted uses.
(7) Principally permitted uses are limited to golf driving ranges.
Amend Kent City Code 15.04.120 Cultural, entertainment, and recreational land use development conditions, as
....
(9) Conditionally permitted uses are limited to parks and playgrounds.
....
Op3_LUResource 228


S = Special Uses
Commercial District
Combining District
CM-2 Commerical
A = Accessory Uses
CC Community
M-CR Midway
District
KCC 15.04.130 Resource Land Uses
Agricultural uses such as planting and harvesting of crops,
animal husbandry (including wholesale nurseries and
greenhouses)
Crop and tree farming
Storage, processing, and conversion of agricultural
products (not including slaughtering or meat packing)
permitted use A A A A A A
Roadside stands
229
6. RECOMMENDATION: Amend development standards within the District Regulations

chapter of Kent City Code 15.04.190 thru 15.04.195 District Regulations Option #3
Development Standards tables and Option #3 Development Standard Conditions, as
follows: (See Attachment E Option #1 and #2 Development Standards tables and Option
#1 Development Standard Conditions.)
.
November 22, 2010 Land Use & Planning Board Public Hearing
Midway Zoning and Development Regulations CPZ-2007-2
Op3_ComDevReWork (2) 230
Option #3 - Kent City Code 15.04 Development Standards
15.04.190 Commercial and industrial zone development standards
New Zoning Districts Existing Zoning Districts
MTC-1 Midway MTC-2 Midway MCR Midway CC CM-2

Transit Community-1 Transit Community- Commercial/ Community Commerical
District 2 District Residential District Commercial Manufacturing 2
Base Maximum Base Maximum Base Maximum
1.5 FAR 1.5 FAR
for all for all
1.5 FAR uses, or uses, or
for all 3.0 FAR 3.0 FAR
uses, or a with a with a
1.0 FAR maximum 1.0 FAR maximum 1.0 FAR maximum
for all height of for all height of for all height of
Floor area ratio uses 65' 55' uses 200' (2) uses 200' (2)
Maximum impervious
60%(a) 60%(a) 70%(a) 70%(a) 70%(a) 70%(a)
surface
Minimum lot area: square 7,500 7,500 7,500 7,500 7,500 7,500 10,000 10,000
feet or acres, as noted sq.ft. sq.ft. sq.ft. sq.ft. sq.ft. sq.ft. sq.ft. sq.ft.
Minimum lot width 75 ft 75 ft 75 ft 75 ft 75 ft 75 ft
Maximum site coverage:

80% 100% 80% 40% 50%
percent of site
Minimum yard
requirements: feet
20 ft see Design
(67) see Design
20 ft see Design
Minimum Front Yard see Design see Design see Design 15 ft. 15 ft.
Guidelines Guidelines Guidelines
(67)(10) see Design
(67)(10) see Design
(67)(10) see Design
Minimum Side Yard see Design see Design see Design (9) (10)
Minimum Side yard on
flanking street of a corner see Design Guidelines
lot
(67)(19)
Minimum Rear yard 20' (3) (67)(19) (67)(19) 20 ft. (19)
20' (3)
Yards, transitional conditions
Additional setbacks
5 Stry/
55 ft 16 Stry/ 16 Stry/
Height limitation: in 65' 55'(1) 3 Stry/
(68)(69) 200 ft (1) (2) 200 ft (1) (2) 2 Stry/35 ft (30)
stories/not to exceed in feet (4) 40 ft (30)
65' 55'(1) (69) [1] (69) [1]
(4)
The landscaping requirements of Ch. 15.07 KCC shall apply. See

Landscaping
Design Guidelines
Outdoor storage (39) (40,41)
11/15/2010 S:\Permit\Plan\COMP_PLAN_AMENDMENTS\2007\CPA-2007-4_MIDWAY\LUPB\Regulations\Midway_Regs090210.xls 1

The sign regulations of Ch. 15.06 KCC shall apply.
Signs
see Design Guidelines
Vehicle drive-through, drive-
(46) (46) (46) (46)
in, and service bays
Loading areas
Off-street parking The off-street parking requirements of Ch. 15.05 KCC shall apply.
Mutlifamily design
see Design Guidelines
review
(50)(56) (50)(56) (50)(56) (36,50,
Additional standards (50,56)
(70) (70) (70) 56)
Notes:
1. A minimum of 2-stories. (Option: Board may consider waiving minimum height for single tenant buildings over one acre in size; such
option would require change to proposed subarea plan Policy MLU-2.2.)
2. Additional height above 65' is allowed through an incentive program to a maximum of 200'. (Option: Board may consider lower
height maximum, e.g., 65', 100' or other option.)
3. Rear yard applies only when abutting residential zoning district.
4. 65 ft 55 ft west of Pac Hwy; 35 ft within 20 ft of a SF residential district; 45 ft within 40 ft of SF residential district
(a.) Impervious surface can be increased reduced if development participates in regional storm detention or density bonus system.
Option 3. LUPB may consider waiving minimum height for single tenant buildings over one acre in size. (Note: Such option would conflict
with proposed Subarea Plan Policy MLU-2.2).
Option 3. LUPB may consider lower maximum height (e.g., 65', 100' or other option).
15.04.195 Commercial and industrial land use development conditions. (excerpts relevant to above table)
9. No side yard is required, except when abutting a more restrictive district, and then the side yard shall be not less than
twenty (20) feet in width.
10. No side yard is required, except abutting a residential district, and then the side yard shall be twenty (20) feet minimum.
19. No rear yard is required, except abutting a residential district, and then the rear yard shall be twenty (20) feet minimum.
30. The planning manager shall be authorized to grant one (1) additional story in height, if during development plan review it
is found that this additional story would not detract from the continuity of the area. More than one (1) additional story may
be granted by the planning commission.
36. Design review for mixed use development is required as provided in KCC 15.09.045(E).
39. Outdoor storage areas are prohibited.
40. Outdoor storage areas shall be fenced for security and public safety by a sight-obscuring fence unless it is determined
through the development plan review that a sight-obscuring fence is not necessary.
41. Any unfenced outdoor storage areas shall be paved with asphaltic concrete, cement, or equivalent material to be
approved by the city engineer.

46. Wherever feasible, drive-up/drive-through facilities shall be accessed from the rear of a site and run along an interior lot
line or building elevation. Landscaping, sufficient to soften the visual impact of vehicle stacking areas, may be required.
50. Development plan approval is required as provided in KCC 15.09.010.
56. The performance standards as provided in KCC 15.08.050 shall apply.
Amend Kent City Code 15.04.195 Commercial and industrial land use development conditions, as follows
(insert after 66.)
....
(67) No yard, except as required by landscaping, or if surface parking is provided onsite. See the Midway Design
Guidelines and KCC 15.09.045.
(68) The height of new construction in MRT-1 zoning district abutting a residential district shall be thirty-five (35) feet in
height within twenty (20) feet from the residential district and forty-five (45) feet in height within forty (40) feet from the
residential district.
(69) New construction shall conform to applicable Federal Aviation Administration regulations, including Part 77, Federal
Aviation Regulations, Objects Affecting Navigable Airspace, as presently constituted or as may be subsequently amended.
(70) The transit oriented community design review requirements of KCC 15.09.045 shall apply.
....
233
7. RECOMMENDATION: Amend within the Off-Street Parking and Loading Requirements

chapter of Kent City Code 15.05.040 Parking standards for specific activities Option #2
Parking Space Requirement table and parking conditions, as follows: (See Attachment E
Option #1 Parking Standards table)
.
Op3_Parking 234
Option #2 - Amendments to Kent City Code 15.05 Parking Standards
Chapter 15.05 Off-Street Parking and Loading Requirements
SPECIFIC LAND USE Parking Space Requirement
Living Activities
Single-family Two (2) parking spaces per single-family dwelling.
Duplex Two (2) parking spaces per dwelling unit.
Multifamily 1, 3 One (1) parking space per unit for efficiency apartments in all sized developments; two (2)
parking spaces for each dwelling unit for developments with forty-nine (49) or less dwelling
units; one and eight-tenths (1.8) parking spaces per dwelling unit for developments of fifty
(50) or more dwelling units. For developments of fifty (50) or more dwelling units, one (1)
parking space for each fifteen (15) dwelling units for recreation vehicles.
Multiple dwellings for low-income One (1) parking space for each two (2) dwelling units
elderly 2, 4
Accessory dwelling unit One off-street parking space per accessory unit is required in addition to the required parking
for the single-family home. The planning director may waive this requirement where there are
special circumstances related to the property and its location. The surface of a required ADU
off-street parking space shall comply with KCC 15.05.090(C).
Boardinghouses and lodging houses One (1) parking space for the proprietor, plus one (1) space per sleeping room for boarders or
lodging use, plus one (1) additional space for each four (4) persons employed on the premises.
Mobile and manufactured home parks Two (2) parking spaces for each mobile home site, plus one (1) screened space for each ten
(10) lots for recreation vehicles.
Recreational vehicle park One (1) parking space for each site.
Hotels 5 One (1) parking space for each guest room, plus two (2) parking spaces for each three (3)
employees.
Commercial Activities
Banks 6 One (1) parking space for each two hundred (200) square feet of gross floor area, except
when part of a shopping center.
Professional and business offices 6 One (1) parking space for each two hundred fifty (250) square feet of gross floor area, except
Shopping centers 7 Four and one-half (4.5) spaces per one thousand (1,000) square feet of gross leaseable area
(GLA) for centers having GLA of less than four hundred thousand (400,000) square feet, and
five (5.0) spaces per one thousand (1,000) square feet of GLA for centers having a GLA of over
four hundred thousand (400,000) square feet.
Restaurants, nightclubs, taverns and One (1) parking space for each one hundred (100) square feet of gross floor area, except
lounges 8 when part of a shopping center.
Retail stores, supermarkets, One (1) parking space for each two hundred (200) square feet of gross floor area, except
department stores and personal when located in a shopping center.
service shops 9
Other retail establishments; furniture, One (1) parking space for each five hundred (500) square feet of gross floor area, except when
appliance, hardware stores, located in a shopping center.
household equipment service shops,
clothing or shoe repair shops 10
Drive-in business 11 One (1) parking space for each one hundred (100) square feet of gross floor area, except
when located in a shopping center.
Op3_Parking 235
Uncovered commercial area, new and One (1) parking space for each five thousand (5,000) square feet of retail sales area in addition
Living Activities
used car lots, plant nursery to any parking requirements for buildings, except when located in a shopping center.
Motor vehicle repair and services One (1) parking space for each four hundred (400) square feet of gross floor area, except
Industrial showroom and display One (1) parking space for each five hundred (500) square feet of display area.
Bulk retail stores One (1) parking space for each three hundred fifty (350) square feet of gross floor area.
Industrial Activities
Manufacturing, research and testing One (1) parking space for each one thousand (1,000) square feet of gross floor area. For
laboratories, creameries, bottling parking requirements for associated office areas, see Professional and business offices.
establishments, bakeries, canneries,
printing and engraving shops
Warehouses and storage buildings One (1) parking space for each two thousand (2,000) square feet of gross floor area. Maximum
office area of two (2) percent of gross floor area may be included without additional parking
requirements.
Speculative warehouse and industrial One (1) parking space for each one thousand (1,000) square feet of gross floor area if building
buildings with multiple use or tenant size is less than one hundred thousand (100,000) square feet, or one (1) parking space for
potential each two thousand (2,000) square feet of gross floor area for buildings which exceed one
hundred thousand (100,000) square feet gross of floor area. This is a minimum requirement
and valid for construction permit purposes only. Final parking requirements will be based upon
actual occupancy.
Recreation-Amusement Activities
Auditoriums, theaters, places of One (1) parking space for each four (4) fixed seats, or one (1) parking space for each one
public assembly, stadiums and hundred (100) square feet of floor area of main auditorium or of principal place of assembly
outdoor sports areas 12 not containing fixed seats, whichever is greater.
Theaters (option for previous
item)
Bowling alleys 13 Five (5) spaces for each alley, except when located in a shopping center.
Dance halls and skating rinks 14 One (1) parking space for each two hundred (200) square feet of gross floor area, except
Golf driving ranges One (1) parking space for each driving station.
Miniature golf courses One (1) parking space for each hole.
Recreational buildings, whether One (1) parking space for each two hundred (200) square feet of gross floor area. Such spaces
independent or associated with a shall be located adjacent to the building and shall be designated for visitors by signing or other
multifamily complex special markings.
Educational Activities
Senior high schools, public, parochial One (1) space for each employee plus one (1) space for each ten (10) students enrolled. In
and private addition, if buses for the transportation of children are kept at the school, one (1) off-street
parking space shall be provided for each bus, of a size sufficient to park each bus. One (1)
additional parking space for each one hundred (100) students shall be provided for visitors in
the vicinity of or adjacent to the administration portion of the building or complex. Such
parking spaces shall be so designated by signing or other special marking as approved by the
traffic engineer.
Op3_Parking 236
Colleges and universities and
Living Activities Two and one-half (2 1/2) parking spaces for each employee, plus one (1) space for each three
business and vocational schools 15 (3) students residing on campus, plus one (1) space for each five (5) day student not residing
on campus. In addition, if buses for transportation of students are kept at the school, one (1)
off-street parking space shall be provided for each bus, of a size sufficient to park each bus.
One (1) additional parking space for each one hundred (100) students shall be provided for
visitors in the vicinity of or adjacent to the administration portion of the building or complex.
Such parking spaces shall be so designated by signing or other special marking as approved by
the traffic engineer.
Elementary and junior high Two and one-half (2 1/2) parking spaces for each employee. In addition, if buses for
transportation of students are kept at the school, one (1) off-street parking space shall be
provided for each bus, of a size sufficient to park each bus. One (1) additional parking space
for each one hundred (100) students shall be provided for visitors in the vicinity of or adjacent
to the administration portion of the building or complex. Such parking spaces shall be so
designated by signing or other special marking as approved by the traffic engineer.
Libraries and museums One (1) parking space for each two hundred fifty (250) square feet in office and public use.
Day-care centers One (1) parking space for each employee, plus loading and unloading areas.
Medical activities
Medical and dental offices 16 One (1) parking space for each two hundred (200) square feet of gross floor area, except
Convalescent, nursing and health One (1) parking space for each two (2) employees, plus one (1) parking space for each three
institutions (3) beds.
Hospitals One (1) parking space for each three (3) beds, plus one (1) parking space for each staff
doctor, plus one (1) parking space for each three (3) employees.
Religious activities
Churches 17 One (1) space for each five (5) seats in the main auditorium; provided, that the spaces for any
church shall not be less than ten (10). For all existing churches enlarging the seating capacity
of their auditoriums, one (1) additional parking space shall be provided for each five (5)
additional seats provided by the new construction. For all existing churches making structural
alterations or additions which do not increase the seating capacity of the auditorium, no
additional parking need be provided.
Mortuaries or funeral homes One (1) parking space for each one hundred (100) square feet of floor area of assembly
rooms.
Other uses
For uses not specifically identified in this section, the amount of parking required shall be
determined by the planning department, based on staff experience, parking required for similar
uses, and, if appropriate, documentation provided by the applicant.
Amend Kent City Code 15.05.040 - Parking standards for specific activities, as follows [insert text after condition (5)d. Compact stalls
will not be permitted except for one-third (1/3) of the required employee parking .]
....
3. In MTC-1, MTC-2, and MCR zoning districts, a minimum of 0.75 parking space per dwelling unit, or conduct a
parking feasibility study to determine need. No spaces provided for recreation vehicles.
4. In MTC-1, MTC-2, and MCR zoning districts, one (1) parking space for each four (4) dwelling units, or conduct a
parking feasibility study to determine need.
Op3_Parking 237
Living
5. Activities
In MTC-1, MTC-2, and MCR zoning districts, one (1) parking space for each guest room, plus two (2) parking
spaces for each five (5) employees, or conduct a parking feasibility study to determine need.
6. In MTC-1 and MCR zoning districts, one (1) parking space for each four hundred (400) square feet of gross floor
area , except when part of a shopping center and in MTC-2 zoning district, one (1) parking space for each five
hundred (500) square feet of gross floor area or conduct a parking feasibility study to determine need.
area or conduct a parking feasibility study to determine need.
8. In MTC-1 or MCR zoning districts, one (1) parking space for each two hundred (200) square feet of gross floor
area and in MTC-2 zoning district a minimum of one (1) parking space for each three hundred (300) square feet of
gross floor area or conduct a parking feasibility study to determine need. No parking is required if use is 3,000
square feet or less and with a parking supply of at least twenty (20) spaces within five hundred (500) feet or 1,000
feet of a public garage.
area and in MTC-2 zoning district, one (1) parking space for each five hundred (500) square feet of gross floor area
or conduct a parking feasibility study to determine need. No parking is required if use is eight hundred (800) square
feet or less and with a parking supply of at least twenty (20) spaces within five hundred (500) feet or 1,000 feet of a
public garage.
10. In MTC-1and MCR zoning districts, one (1) parking space for each 1,000 square feet of gross floor area and in
MTC-2 zoning district, one (1) parking space for each 1,000 square feet of gross floor area or a conduct parking
feasibility study to determine need. No parking is required if use is eight hundred (800) square feet or less and with
a parking supply of at least twenty (20) spaces within five hundred (500) feet or 1,000 feet of a public garage.
area, except when located in a shopping center.
12. In MTC-1 and MCR zoning districts, conduct a parking feasibility study to determine need.
13. In MTC-1 and MCR zoning districts, three (3) parking spaces for each alley, except when located in a shopping
center.
14. In MTC-1 and MCR zoning districts, one (1) parking space for each five hundred (500) square feet of gross floor
area or conduct a parking feasibility study to determine need.
15. In MTC-1, MTC-2, and MCR zoning districts, conduct a parking feasibility study to determine need.
16. In MTC-1, MTC-2 and MCR zoning districts, a minimum of one (1) parking space for each four hundred (400)
square feet of gross floor area or conduct a parking feasibility study to determine need.
17. In MTC-1, MTC-2 and MCR zoning districts, one (1) parking space for each ten (10) seats in the main auditorium;
provided, that the spaces for any church shall not be less than ten (10). For all existing churches enlarging the
seating capacity, one (1) additional parking space shall be provided for each ten (10) seats provided by the new
construction.
....
238
8. RECOMMENDATION: Amend within the Sign Regulations chapter of Kent City Code
15.06.050 Regulations for specific districts, as follows:
(insert between C. Signs permitted in downtown commercial and downtown commercial

enterprise districts and D. Signs permitted in office and neighborhood convenience
commercial districts.)
.
D. Signs permitted in midway transit community-1 district.
The aggregate sign area for any lot shall not exceed one (1) square foot for each linear
foot of street frontage. Aggregate sign area for corner lots shall not exceed three-fourths
(3/4) square foot for each linear foot of street frontage. The permitted signs enumerate in
this subsection shall be subject to the total aggregate sign area and may be permitted
subject to Midway Design Guidelines.
1. Identification signs for occupancies. Each single business property may have one (1)
freestanding monument sign per street frontage or one (1) projecting sign per street
frontage if located along or at the intersections of SR-99, SR-516, S 240th Street, S
246th Street, and S 272nd Street, if not located in a multitenant building, and one (1)
wall sign and one (1) suspended sign per street frontage.
a. Freestanding monument signs. Freestanding monument signs shall not

exceed a height of fifteen (15) feet. The maximum sign area permitted is eighty
(80) square feet for the total of all faces. No one (1) face shall exceed forty (40)
square feet. The sign may be internally illuminated which shall be constructed
using individual letters/characters, or sign cabinets with an opaque field or
background so that only the individual letters/characters are illuminated.
Freestanding monument signs shall not rotate, blink, flash, or be animated.
Freestanding monument signs shall include landscaping and curbing around the
base of the sign to prevent vehicles hitting the structure and improve the visual
appearance of the sign structure. Landscaping shall be in proportion to the
structure, with a minimum of one-half square foot of landscaping for each
square foot of sign area and shall be maintained throughout the life of the sign.
b. Projecting or suspended signs. Projecting or suspended signs shall not

protrude less than eight (8) feet above the surface of the sidewalk. The
following are recognized projecting signs:
i. Blade sign. Blade sign shall be double-faced, may be non-illuminated,

internal or internal indirect illuminated, or neon tube illuminated. Internal
illumination shall be constructed using individual letters/characters, or sign
cabinets with an opaque field or background so that only the individual
letters/characters are illuminated. The maximum sign area permitted is
239
eighty (80) square feet. No one (1) face shall exceed forty (40) square
feet. The maximum sign height permitted is twenty (20) feet. Blade signs
shall not rotate, blink, flash, or be animated.
ii. Hanging sign. Hanging sign shall be double-faced and shall be non-
illuminated.
b. Wall signs. Wall signs shall not exceed an area of ten (10) percent of the
building first floor facade to which it is attached or a minimum of twenty-four
(24) square feet, shall be attached flat against the building, and placement shall
not exceed thirty-five (35) feet above median sidewalk grade measured from
the top of the sign. Wall signs may be non-illuminated, internally or indirectly
illuminated. Internal illumination shall be constructed using individual
letters/characters, or sign cabinets with an opaque field or background so that
only the individual letters/characters are illuminated.
2. Identification signs for multitenant buildings. Each multitenant property may have
one (1) freestanding monument sign per street frontage or one (1) projecting sign per
street frontage if located along or at the intersections of SR-99, SR-516, S 240th
Street, S 246th Street, and S 272nd Street and each occupancy may have one (1) wall
sign and one (1) suspended sign per occupancy, except the anchor tenants with a
business frontage of at least one hundred (100) linear feet shall be allowed two (2)
wall signs. The aggregate wall sign area shall not exceed ten (10) percent of the first
floor building facade to which the signs are attached.
a. Freestanding monument signs. Each multitenant building may have one (1)
freestanding monument sign on each street frontage. The sign may not exceed
a height of fifteen (15) feet. The maximum sign area permitted is eighty (80)
square feet for the total of all faces. No one (1) face shall exceed forty (40)
b. Wall sign. Each multitenant building may have one (1) identification wall sign
for the buildings identification for each street frontage. The sign shall not
exceed a total of five (5) percent of the first floor facade to which it is attached.
The sign shall not name or advertise the individual tenants of the building. The
sign may be internally illuminated which shall be constructed using individual
240
only the individual letters/characters are illuminated. Aggregate sign area shall
apply. A multitenant building will have the option of the sign described in this
subsection (D)(2)(b) or the identification sign described in subsection (D)(2)(c)
of this section.
c. Identification signs for occupancies. Each occupant of a multitenant building

with street frontage shall be permitted two (2) wall signs and one (1) projecting
or suspended sign. Each occupancy shall be allowed at least 24 square feet of
sign area. The aggregate wall sign area shall not exceed ten (10) percent of the
first floor facade to which the signs are attached. The wall sign may be internally
illuminated and the projecting or suspended sign shall be non-illuminated.
Internal illumination shall be constructed using individual letters/characters, or
sign cabinets with an opaque field or background so that only the individual
letters/characters are illuminated. The projecting or suspended sign shall be
non-illuminated.
E. Signs permitted in midway transit community-2 district.

(3/4) square foot for each linear foot of street frontage. The permitted signs enumerated
in this subsection shall be subject to the total aggregate sign area and may be permitted
frontage, if not located in a multitenant building, and two (2) wall signs and one (1)
suspended sign per street frontage.

exceed a height of five (5) feet. The maximum sign area permitted is thirty (30)
square feet for the total of all faces. No one (1) face shall exceed fifteen (15)
square feet. The sign may be illuminated indirectly. Freestanding monument
signs shall include landscaping and curbing around the base of the sign to
prevent vehicles hitting the structure and improve the visual appearance of the
sign structure. Landscaping shall be in proportion to the structure, with a
minimum of one-half square foot of landscaping for each square foot of sign
area and shall be maintained throughout the life of the sign.


indirect illuminated, or neon tube illuminated. The maximum sign area
permitted is thirty (30) square feet. No one (1) face shall exceed fifteen
241
(15) square feet. The maximum sign height permitted is fifteen (15) feet.
Blade signs shall not rotate, blink, flash, or be animated.
illuminated.
b. Wall signs. Wall signs shall not exceed an area of five (5) percent of the
(24) square feet. Wall signs shall be attached flat against the building, and
placement shall not exceed fifteen (15) feet above median sidewalk grade
measured from the top of the sign. If a single business property is greater than
sixty-five (65) in height, one (1) building identification wall sign for each street
frontage may be placed on the parapet. Wall signs may be non-illuminated,
internally or indirectly illuminated, or neon tube illuminated. Internal illumination
shall be constructed using individual letters/characters, or sign cabinets with an
opaque field or background so that only the individual letters/characters are
illuminated. Wall signs shall not blink, flash, or be animated.
one (1) freestanding monument sign or one (1) projecting sign and each occupancy
with street frontage may have two (2) wall signs and one (1) suspended sign. The
aggregate wall sign area shall not exceed five (5) percent of the first floor building
facade to which the signs are attached.
a. Freestanding monument signs. Each multitenant building may have one (1)
freestanding monument sign on each street frontage. The sign may not exceed
a height of five (5) feet. The maximum sign area permitted is thirty (30) square
feet for the total of all faces. No one (1) face shall exceed fifteen (15) square
feet. The sign may be illuminated indirectly. Freestanding monument signs shall
include landscaping and curbing around the base of the sign to prevent vehicles
hitting the structure and improve the visual appearance of the sign structure.
Landscaping shall be in proportion to the structure, with a minimum of one-half
square foot of landscaping for each square foot of sign area and shall be
maintained throughout the life of the sign.


internal indirect illuminated, or neon tube illuminated. The maximum sign
area permitted is thirty (30) square feet. No one (1) face shall exceed
fifteen (15) square feet. The maximum sign height permitted is fifteen (15)
feet. Blade signs shall not rotate, blink, flash, or be animated.
242
illuminated.
b. Wall sign. Each multitenant building may have one (1) identification wall sign
for the buildings identification for each street frontage. The sign shall not
exceed a total of five (5) percent of the first floor facade to which it is attached
or a minimum of twenty-four (24) square feet. Wall signs shall be attached flat
against the building, and placement shall not exceed fifteen (15) feet above
median sidewalk grade measured from the top of the sign. If the multitenant
building is greater than sixty-five (65) in height, one (1) building identification
wall sign for each street frontage may be placed on the parapet. The sign shall
not name or advertise the individual tenants of the building. Wall signs may be
non-illuminated, internally or indirectly illuminated, or neon tube illuminated.
Internal illumination shall be constructed using individual letters/characters, or
sign cabinets with an opaque field or background so that only the individual
letters/characters are illuminated. Wall signs shall not blink, flash, or be
animated. Aggregate sign area shall apply. A multitenant building will have the
option of the sign described in this subsection (E)(2)(b) or the identification sign
described in subsection (E)(2)(c) of this section.
c. Identification signs for occupancies. Each occupant of a multitenant building

with street frontage shall be permitted two (2) wall signs and one (1) projecting
or suspended sign. Each occupancy with street frontage shall be allowed at least
24 square feet of sign area. The aggregate wall sign area shall not exceed five
(5) percent of the first floor facade to which the signs are attached. The wall
sign may be internally illuminated and the projecting or suspended sign shall be
non-illuminated. Internal illumination shall be constructed using individual
only the individual letters/characters are illuminated. The projecting or
suspended sign shall be non-illuminated. Wall signs shall not blink, flash, or be
animated.
F. Signs permitted in midway commercial/residential district.

(3/4) square foot for each linear foot of street frontage. The permitted signs enumerated
in this subsection shall be subject to the total aggregate sign area and may be permitted
frontage, if not located in a multitenant building, and two (2) wall signs and one (1)
suspended sign per street frontage.
243



internal or internal indirect illuminated, or neon tube illuminated. Internal
illumination shall be constructed using individual letters/characters, or sign
cabinets with an opaque field or background so that only the individual
letters/characters are illuminated. The maximum sign area permitted is
eighty (80) square feet. No one (1) face shall exceed forty (40) square
feet. The maximum sign height permitted is twenty (20) feet. Blade signs
shall not rotate, blink, flash, or be animated
illuminated.
c. Wall signs. Wall signs shall not exceed an area of ten (10) percent of the
(24) square feet, shall be attached flat against the building, and placement shall
not exceed thirty-five (35) feet above median sidewalk grade measured from
the top of the sign. Wall signs may be non-illuminated, internally or indirectly
only the individual letters/characters are illuminated.
one (1) freestanding monument sign or one (1) projecting sign and each occupancy
with street frontage may have two (2) wall signs and one (1) suspended sign per,
except the anchor tenants with a business frontage of at least one hundred (100)
linear feet shall be allowed three (3) wall signs. The aggregate wall sign area shall not
exceed ten (10) percent of the first floor building facade to which the signs are
attached.
244
a. Freestanding monument signs. Each multitenant building may have one

(1) freestanding monument sign on each street frontage. The sign may not
b. Wall sign. Each multitenant building may have one (1) identification wall
sign for the buildings identification for each street frontage. The sign shall not
exceed a total of five (5) percent of the first floor facade to which it is attached.
The sign shall not name or advertise the individual tenants of the building. The
sign may be internally illuminated which shall be constructed using individual
only the individual letters/characters are illuminated. Aggregate sign area shall
apply. A multitenant building will have the option of the sign described in this
subsection (D)(2)(b) or the identification sign described in subsection (D)(2)(c)
of this section.
c. Identification signs for occupancies. Each occupant of a multitenant

building with street frontage shall be permitted one (1) wall sign and one (1)
projecting or suspended sign. Each occupancy shall be allowed at least 24
square feet of sign area. The aggregate wall sign area shall not exceed ten (10)
percent of the first floor facade to which the signs are attached. The wall sign
may be internally illuminated and the projecting or suspended sign shall be non-
only the individual letters/characters are illuminated. The projecting or
suspended sign shall be non-illuminated.
.
9. RECOMMENDATION: Amend within the Landscaping Regulations chapter of Kent City

Code 15.07.060 Regulations for specific districts, as follows:
(insert between H. Downtown commercial enterprise, DCE and I. Industrial agricultural, MA

[industrial uses] and Agricultural general district, AG and Industrial park district, M1.
.
I. Midway transit community-1district, MTC-1.
1. Additional landscaping requirements. Landscaping requirements shall be determined
245
through the midway design review process outlined in KCC 12.01.040 and shall include
the following to soften the appearance of parking areas, building elevations and
separate:
a. The perimeter of properties abutting a single-family residential or mobile

home park land use shall be landscaped with minimally ten (10) feet of Type I
landscaping.
b. The perimeter of properties abutting a multifamily residential land use

shall be landscaped with minimally five (5) feet of Type II landscaping.
c. The perimeter of properties abutting public right-of-way shall be

landscaped with minimally ten (10) feet of Type III landscaping. The following
exceptions apply:
i. When a vehicular parking area abuts such setback, a Type III landscape
strip with an average of twenty (20) feet in depth shall be provided.
ii. When such setback is utilized as a public open space plaza and not
accompanying parking, no perimeter landscaping strip shall be required,
and
iii. When such setback is utilized as a public open space plaza and exceeds
thirty (30) linear feet, street trees shall be provided as set forth in 2009
Design & Construction Standards, or as subsequently amended.
d. The perimeter of side property lines shall be landscaped with minimally

five (5) feet of Type III landscaping, unless the building is constructed at the
build-to line or property line.
J. Midway transit community-2 district, MTC-2.

separate:
a. The perimeter of properties abutting public parks, plazas, open space, or

multi-purpose trails shall be landscaped with minimally ten (10) feet of Type III
landscaping.
b. When vehicular parking area abuts public right-of-way, a Type III

landscaping strip minimally five (5) feet in depth shall be provided.
c. When vehicular parking area abuts the side property lines, a Type III
landscaping strip minimally ten (10) feet in depth shall be provided.
K. Midway commercial/residential, MCR.
246

separate:
a. When buildings abut the required front yard, a Type III landscaping strip
minimally ten (10) feet in depth shall be provided.
b. When vehicular parking area abuts public right-of-way, a Type III

landscaping strip minimally fifteen (15) feet in depth shall be provided.
c. When vehicular parking area abuts the side property lines, a Type III
landscaping strip minimally ten (10) feet in depth shall be provided.
10.RECOMMENDATION: Amend within the Administration chapter of Kent City Code

15.09.045 Administrative design review, as follows:
(insert between F. Mixed use design review and G. Appeals)

.
F. Transit oriented community design review. The planning services division shall use the
following criteria in the evaluation or conditioning of applications under the transit oriented
community design review process:
1. The midway design guidelines as an adopted element of the citys regulation of land
use, which is statutorily authorized, shall apply to all development with a land use plan
map designation of transit oriented community.
2. Residential use design review. In addition to the Midway design guidelines, the
following design requirements apply to residential uses and development.
a. Openings from the built-to line. When a residential unit has direct access
to the public domain, a ten (10) foot front yard shall be provided. When
residential units have access through a main location, such as an atrium,
courtyard or other main entryway, said access shall be at the built-to line.
b. Open space. Residential development shall provide not less than twenty
(20) percent of the gross land area for common open space, which shall be:
i. Designed to provide either passive or active recreation.
ii. If under one (1) ownership, owner shall maintain.
iii. If held in common ownership by all owners of the development by means

of a home-owners association, said association shall be responsible. If such
open space is not maintained in a reasonable manner, the city shall have
247
the right to provide for the maintenance thereof and bill the homeowners
association accordingly. If unpaid, such bills shall be a lien against the
homeowners association; or
iv. Dedicated for public use if accepted by the city legislative authority or
other appropriate public agency.
c. Storage of recreational vehicles. The storage or parking of recreational

vehicles shall be prohibited.
.
S:\Permit\Plan\COMP_PLAN_AMENDMENTS\2007\CPA-2007-4_MIDWAY\Regulations\Amendments2.doc
Appendix F
Traffic Volumes for SR 99 Intersections within the Midway Subarea

Midway Subarea Planned Action

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Midway Subarea Planned Action

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Final Environmental Impact Statement

City of Kent Comprehensive Plan Review and

City of Kent, Washington

710 Second Avenue, Suite 550

Proposed Action and Alternatives

proximity to planned high capacity transit improvements along or in the vicinity of

FEIS Review Alternative

Phasing of growth is assumed because of the economic downturn and Sound

planning period, identifies a city-wide transportation analysis and funding

EIS Authors and Principal Contributors

Weinman Consulting, LLC

Date of DEIS Issuance

Previous Environmental Documents

2008 Annual Amendment to Comprehensive Plan Capital Facilities Element and

Location of Background Information

FEIS Purchase Price

The document is also posted on the Citys website at <http://www.ci.kent.wa.us/> or

Chapter 2. Description of Alternatives ............................... 2-1

2.3.3. Planned Action Ordinance ....................................... 2-8

Chapter 3. Environmental Analysis .................................... 3-1

Chapter 4. Clarifications and Corrections ......................... 4-1

4.4.3. Revisions to DEIS Page 3.4-31 ................................ 4-7

4.6.20. Revisions to DEIS Page 3.6-94 ........................... 4-30

Chapter 5. Responses to Comments .................................... 5-1

Chapter 6. Distribution List ................................................. 6-1

MCR Midway Commercial/Residential

1.1. Proposed Action and Location

1.1.1. The Proposal

Meeker/Washington. Specific City of Kent Comprehensive Plan (Comprehensive

1.1.2. Proposal Objectives

The Citys objectives for this Proposal are as follows:

1.1.4. Description of Alternatives

The Proposal also evaluates the impacts of alternative growth strategies at a

FEIS Review Alternative

1.2. SEPA Procedures and Public Involvement

1.2.1. Purpose of the EIS

1.2.2. Level of Analysis

SEPA (Revised Code of Washington [RCW] 43.21C) requires government officials to

Kent Planning Area

This DEIS provides a qualitative and quantitative analysis of environmental impacts as

The City plans to complete a planned action ordinance to encourage redevelopment in a

1.2.3. EIS Scoping and Public Comment

1.3. Summary of Impacts

1.3.1. Impacts Common to AllBoth Alternatives

1.3.1.1. Natural Environment

Kent Planning Area

Earth-disturbing construction could accelerate erosion, particularly in steep areas.

Plants and Animals

1.3.1.2. Air Quality

Kent Planning Area

Emissions from Commercial and Industrial Operations

Emissions from Vehicle Travel

Greenhouse Gas Emissions

1.3.1.3. Land Use Patterns/Plans and Policies

Kent Planning Area

Land Use Patterns

Plans and Policies

would be an area of focused future development guided by the strategies and

Kent Planning Area

Kent Planning Area

Kent-Des Moines Road/I-5 Southbound Ramps,

Traffic flows at these locations would be substantially influenced by WSDOTs final SR

1.3.1.6. Public Services/Utilities

Kent Planning Area