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10092009-appeal fee.pdfIn C. I890 October 9, 2009 CITY OF EDMONDS GARY HAAKENSON MAYOR 121 STH AVENUE NORTH • EDMONDS, WA 98020 • 425-771-0220 • FAX 425-771-0221 Website: www.d.edmonds.wa.us PUBLIC WORKS DEPARTMENT Lngineering Division Kelly Jorgenson 15523 3rd Drive SE Mil] Creek, WA 98012 Re: APL20090003 —Request for Return of Appeal Fee Dear Mr. and Mrs. Jorgenson: Please accept this letter as the City of Edmonds' formal response to your request for a refund of the administrative fee previously remitted with respect to the stonnlwater infiltration exception granted by the City's Hearing Examiner on October 7, 2009. After carefully considering this matter, the City respectfully denies your request. The stornwater exception mechanism set forth at ECDC 1830.065 is not an "appeal" to which a successful applicant would be entitled to a refund. Although this code section cross-references the process codified at Chapter 20.105 ECDC, this procedural fi-amework does not transform an applicant's request for a stormwater exception into an appeal. Unlike a true appeal proceeding, the process established by ECDC 18.30.065 does not involve a challenge to a lower decision -maker's ruling. Instead, it simply prescribes a more formal hearing process for a development applicant seeking to deviate from the general drainage standards contained in Chapter 18.30 ECDC, and ensures that all interested parties are afforded an opportunity to comment on the proposal. The contrast between this process and an appeal proceeding is particularly apparent in the context of your own development proposal, where City staff actively supported your request for an exception. Moreover, it is clear from both the language and surrounding context of ECDC 20.105.045 that the fee refund authorized by that section is limited to the prevailing party in appeals before the Edmonds City Council. The entitlement is inapplicable to Hearing Examiner proceedings. To my knowledge, the interpretation above reflects the City's consistent administration of the ECDC provisions at issue. I am unaware of any situation in which an applicant received a fee refired .after obtaining approval for a stormwater exception pursuant to ECDC 18.30.065. I trust the above adequately clarifies the City's position regarding this matter. Sincerely, Noel F. Miller, P.E. , Public Works Director City of Edmonds {7ZL744973.DOC;1100006.9000001 } • Incorporated August 11, 1890 • Sister City - Hekinan, Japan