The United Methodist Church is requesting City permits to expand its food bank operations. The Church proposes to demolish an existing, stand-alone 1,345 square foot single family house located on the subject property. It would replace the demolished structure with an expanded food bank facility and residence in one building. The size of the new facility would be similar in size to the existing facility although built in a manner to increase efficiencies, and to expand the number of food bank clients.
6900 Steilacoom Boulevard SW
Assessors Parcel Number
R4 (Single Family Residential 4)
85,500 square feet (1.96 acres)
One church building, 16,000 square feet, and one single family residence. The church was established in the late 1950s and has been added upon over the years. The single family residence was moved on to the church site also in the last 1950s.
Property fronts on three streets, Steilacoom Boulevard SW, 69th Avenue SW, and Flora Street SW; there are no street frontage improvements (curb, gutter, and sidewalk)
- The Religious Land Use and Institutionalized Persons Act (RLUIPA)
- City of Lakewood Comprehensive Plan
- City of Lakewood Municipal Code, Title 18A (Land use & Development Regulations)
Findings (Food Bank)
- The Methodist Church was established in the Lakewood community in the late 1950s. The building has been added upon over the years. Pierce County Assessor’s records indicate that the church was built in 1975.
- The food bank (operated by FISH Food Banks of Pierce County) preceded the construction of the church and has been in existence in the Lakewood area since 1973. It is assumed that the food bank has been in operation at this location since the Methodist Church was constructed.
- In 2012, the food bank for all of Pierce County served 2,000 families per month, or 9,000 people per month. The total number of clients served in 2012 was 556,298. Specific to this location, this food bank serves about 100,000 clients per year. There four or five food banks in Lakewood; this is the largest.
- The City has not received any complaints from surrounding property owners as to the operation of the fish bank.
- The Church fronts on a busy arterial street that moves about 20,000 vehicles per day.
- In 1996, the City of Lakewood incorporated and at that time the Methodist Church was subject to the City’s development regulations. From 1996 until 2001, the City of Lakewood had in place interim zoning. In 2001, the City of Lakewood adopted a permanent set of land use regulations. The Methodist Church property was designated “Single Family Residential” in the City’s newly adopted Comprehensive Plan and classified as R4 under the City’s adopted zoning code .
- The Residential 4 (R4) zoning district is the City’s primary residential zone, which provide for single-family dwellings in established residential neighborhoods. The R4 designation provides for increased residential density through smaller lot sizes and allowance for residential development comprising two units per lot.
Churches are defined as religious assembly under the City’s zoning code. The definition of religious assembly is as follows:
Religious services involving public assembly such as those that customarily occur in synagogues, temples, and churches. For the purpose of compliance with the federal Religious Land Use and Institutionalized Persons Act of 2000, except where lands are restricted to public facilities, Religious Assembly use types shall be treated equally with Community and Cultural Services Civic use types. These use types do not include homeless shelters, food banks (emphasis added), or other social services, which shall instead be treated as a Social Services Civic use type; daycares or preschools, which shall instead be treated as a Daycare Facilities Civic use type; schools, which shall instead be treated as an Education Civic use type; or facilities for residence of religious orders, which shall instead be treated as a Co-Housing Residential use type. (18A.20.400 L.)
More specifically, current zoning would describe the food bank as a Social Service Level 3 use:
Social Services. Establishments primarily engaged in the provision of services that are strongly associated with meeting basic needs. Examples include clothing banks, food banks, temporary shelters, and counseling services.
Level 1: Establishments which are accessory to a primary Community and Cultural Services, Religious Assembly, or Education Civic use type and do not exceed one thousand (1,000) gross square feet or twenty (20) percent of the structure, whichever is less, and do not contain more than five (5) beds or serve more than fifteen (15) people per day or meal.
Level 2: Establishments which are accessory to a primary Community and Cultural Services, Religious Assembly, or Education Civic use type and do not exceed one thousand, five hundred (1,500) gross square feet or twenty (20) percent of the structures, whichever is less, and does not contain more than ten (10) beds or serve more than twenty-five (25) people per day or meal.
Level 3: Establishments which are a primary or accessory use and serve a city-wide or regional area with an intensity greater than Level 2. (18A.20.400 M.)
Determination (Food Bank):
Based on the current level of operations, the existing food bank is a Level 3 Social Service. Level 3 Social Services are not listed in the R4 zone, and therefore, are not allowed. (18A.2.215) However, the use preceded the establishment of the current zone and has been in existence for many years. Because the food bank provides an important public service, and has not caused or created conflicts with surrounding single family property owners, the food bank is hereby determined to be a primary permitted use PROVIDED that: 1) the size/scale of the food bank operation stays within the general footprint of the building that is to be demolished; and 2) that if the food bank expands its operations, that it does so in such a way that it does not negatively impact the surrounding residential neighborhood. To this end, this determination is predicated on the food bank submitting an expanded operational plan, subject to the review and approval of the community development director.
- The findings for the residential unit are the same as that of the food bank, however, additional remarks have been added below.
- There is only one residence on the property.
- According to comments from the local pastor, the residence was moved on to the church property in the late 1950s, and was once used as the church’s pastor’s residence.
- The residence is located on the southwest corner of the church property.
- The R4 zone allows the construction of a residential dwelling unit that provides living accommodations for a single individual or family. (18A.20.300 A.)
The demolition of an existing single family residence and its replacement with a new single family residence is allowed provided the structure complies with the R4 development standards. (18A.30.160)
These determinations are deemed administrative interpretations; it shall be considered to constitute an official interpretation of the City’s land use regulations and shall subsequently be applied and used for future administration in reviewing like proposals.
- The proposal is subject to the city’s noise regulations as contained in LMC 8.36.010.
- Delivery vehicles and clients of the food bank shall not access Flora Street SW.
- A demolition permit is required to be issued to remove the existing structure in addition to other permit requirements from other agencies having jurisdiction in Lakewood (Pierce County Public Works & Utilities, West Pierce Fire District, and Lakewood Water District)
- A building permit is required to build a new residence and enlarged food bank facility in addition to other permit requirements from other agencies having jurisdiction in Lakewood (Pierce County Public Works & Utilities, West Pierce Fire District, and Lakewood Water District)
- The new single family residence shall comply with the R4 development standards.
Within 45-days of this approval, submit an operational statement providing the following information:
The number of commercial vehicles that park or have access to the Church property and which are associated with the food bank;
Estimated number of vehicular trips to and from the site per day including deliveries and client–related trips.
The Community Development Director's determination shall be processed and subject to the applicable requirements of LMC 18A.02.540 and may be appealed as provided in LMC 18A.02.740.
October 30, 2013
 The existing church is classified in the R4 zone as Religious Assembly Level 2. Zoning regulations would require the church to obtain a conditional use permit. The church, however, does not possess a conditional use permit, and, technically, is a legal non-conforming use. In the event that the church desires to expand or enlarge, or cause a change in use, the City would require the church to file a conditional use permit. As part of the use permit process, and depending on the level of investment, the City could require the church to dedicate right-of-way and make street frontage improvements.