11-0775 Plan Review Comments #4.pdfCITY OF EDMONDS - 121 5"' AVENUE NORTH - EDMONDS, WA 98020
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April 6, 2012
Eric Thuesen
ericthuesen@frontier.com
RE: PLAN REVIEW COMMENTS #4 FOR PLAN CHECK # 2011-0775
ACCESSORY STRUCTURE (CABANA) AT 509 9TH AVENUE NORTH
Dear Eric,
I have again reviewed the above building permit application for the Planning Division. Before I can sign
off on the permit, however, the following information needs to be further clarified in a written response
and with updated plans showing all changes specifically called out:
Structural lot coverage: Please include a breakdown of the structural lot coverage for the
parcel. According to ECDC 21.15.110, "[c]overage means the total ground coverage of all
buildings or structures on a site measured from the outside of external walls or supporting
members or from a point rivo and one-half feet in from the outside edge of a cantilevered
roof, whichever covers the greatest area." Provide a calculation of the total lot coverage as a
percentage of the lot area.
2. Elevation drawings: Please provide updated elevation drawings reflecting the change in the
height calculations shown on the March 30 site plan.
Retaining wall: The retaining wall that was originally proposed on the September 16 and
November 22, 2011 plans is shown to be much larger on the resubbed site plan from March
303 2012. Significant additional fill is also shown within a portion of the landslide hazard
area north of the cabana. It is uncertain how this change satisfies the critical areas code
requirements, particularly for avoiding or minimizing the impact to the hazard described in
ECDC 23.40.120.B. Please describe. Also, have your new geotech specifically address the
larger retaining wall in his report while updating the whole report making detailed reference
to the previously identified code requirements in ECDC 23.40 and 23.80. Without this
specific reference, third party review per ECDC 23.40.090.13 may be required at your
expense.
Please submit three copies of your updated site plan (one being reduced size of 11 x 17 or smaller)
and two sets of any updated sheets of the building plans. Please make all submittals to a Permit
Coordinator, Monday through Friday, 8:00 am to 4:30 pm. If you have any questions, please contact
me at (425) 771-0220.
Sincerely,
Ilk
Mike Clugston, AICP
Associate Planner
Previous comments on building permit BLD-2011-0775
Review #1— September 23, 2011
Review #2 — December 2, 2011
Comment #3 —March 12, 2012
1. 9123111 comment - Critical Areas: The critical area checklist associated with the address
(CRA-2001-0067) identified the presence of steep slopes on the subject site. The 2004 critical
areas code update describes these geologically hazardous areas as possible erosion hazard areas
(slopes between 15% and 40%) and landslide hazards (slopes in excess of 40%). As proposed,
the accessory structure would project out over the upper portion of a steep slope identified as a
possible landslide hazard.
The critical areas code requires that applicants attempt to avoid and minimize impacts to
critical areas. ECDC 23.40.120.A (Mitigation sequencing) states:
Applicants shall demonstrate that all reasonable efforts have been examined with the
intent to avoid and minimize impacts to critical areas.
Further, ECDC 23.40.120.13 states:
When an alteration to a critical area is proposed, such alteration shall be avoided,
minimized, or compensated for in the following sequential order of preference:
1. Avoiding the impact altogether by not taking a certain action or parts of an
action;
2. Minimizing impacts by limiting the degree or magnitude of the action and its
implementation by using appropriate technology or by taking affirmative steps,
such as project redesign, relocation, or timing, to avoid or reduce impacts;
3. Rectifying the impact to wetlands, frequently flooded areas, and fish and wildlife
habitat conservation areas by repairing, rehabilitating, or restoring the affected
environment to the historical conditions or the conditions existing at the time of the
initiation of the project;
4. Minimizing or eliminating the hazard by restoring or stabilizing the hazard area
through engineering or other methods;
5. Reducing or eliminating the impact or hazard over time by preservation and
maintenance operations during the life of the action;
6. Compensating for the impact to wetlands, frequently flooded areas, and fish and
wildlife habitat conservation areas by replacing, enhancing, or providing substitute
resources or environments; and/or
7. Monitoring the hazard or other required mitigation and taking remedial action
when necessary.
From the location of the proposed accessory structure within an area of steep slopes (and within
a required setback), it does not appear as if the above process was considered. For example,
moving the structures closer toward the existing house (away from the slope) would reduce the
impact to the hazard and then also satisfy the required zoning setbacks (see #4 below).
Regardless of where the accessory structure is located, however, a geotechnical report must be
submitted. This report must review the criteria listed above and the criteria for development in
or near geological hazards identified in ECDC 23.80.060 and .070, and must contain the
elements listed ECDC 23.80.050 and 23.40.090. The report must be prepared by a qualified
professional (ECDC 23.80.050.A) and is subject to independent review according to ECDC
23.40.0903, as appropriate.
City review of the proposal includes the criteria in ECDC 23.40.160.
12/2/11 comment — Thank you for providing a response to the above correction request.
However, the cabana is being proposed under the critical area requirements of ECDC 23.40, not
old ECDC 20.15B. Mr. Bruce could update the existing report to include reference to the new
code and this specific project (accessory structure/grading/retaining wall in a critical area
regulated in ECDC 23.80) or start anew. Either way, a report from a qualified professional is
required for this project as noted previously.
3112112 comment — Based on a discussion at the counter on Friday, March 9, you requested
clarification regarding whether an existing geotechnical report could be incorporated into the
current geotech review if the original report was more than five years old. My understanding
was as long as any subsequent changes to the site were examined by the geotechnical engineer,
the original report could be updated with more current information. However, according to
ECDC 23.80.050.D, previous studies can only be incorporated when prepared within the last
five years for a specific site. As a result, please have Mr. Bruce develop a new geotechnical
report specific to this proposal that meets the requirements of ECDC Chapter 23.80 and 23.40.
1 apologize for the confusion.
2. 9123111 comment - Site Plan: The site plan submitted is not accurately scaled. Use a survey or
the approved development plan from the associated short plat (S-07-76) as a base map and
show the proposed improvements on that.
12/2/11 comment — Please submit a site plan that is accurately scaled (see Engineering's
comments to the same effect). The scale is close to 1:20 but not accurate.
3. 9123111 comment - Datum Point: Label the datum point and its elevation on the updated site
plan.
12/2/11 comment — The narrative received 11/22/11 describes the datum point as being at 149'
but it is not labeled on the site plan.
4. 9123111 comment - Setbacks: The Proposed spiral staircase is shown encroaching into the south
side setback (10'). No structures may be located within a required property line setback with
the exception of those identified in ECDC 16.20.040 and ECDC 21.90.150.
12/2/11 comment — The steps on the proposed cabana still encroach into the south side setback.
Per ECDC 16.20.040.C: "Uncovered and unenclosed porches, steps, patios, and decks may
project into a required setback not more than one-third of the required setback, or four feet,
whichever is less; provided, that they are no more than 30 inches above ground level at any
point." In this case, the steps could encroach 3.33 feet (1/3 of 10 feet). Please note the distance
of the proposed encroachment on the revised site plan.
5. ok
All referenced code sections are available at the following website:
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