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2017-07-21 CA vesting memo.pdfDate: July 21, 2017 To: Mike Clugston From: JeffTaraday Re: Caspers short plat vesting This memo briefly summarizes our analysis of whether the Caspers short plat owned by Echelbarger Investments is vested to the CAO that was in effect when the short plat application was submitted for the purposes of the pending building permit applications. We discussed this matter in March 2017 and how the Alliance Investment Group case would seem to suggest that Echelbarger Investments was not necessarily vested to the earlier CAO for the purposes of obtaining building permits. At the time, I advised you that we should apply the current CAO, at least to the extent of requiring the applicant to obtain a variance, but that the city wouldn't likely be able to enforce the current CAO to an extent that would render any of the lots unusable for single family residential purposes. Echelbarger Investments resisted our vesting analysis and caused me to take a closer look at the matter. Upon further review, I realized that the buffer width reduction that was approved as part of the short plat was not necessary to obtain the fourth lot. I found this fact to be significant because it demonstrated an intent by the developer to obtain the buffer width reduction for the purposes of later home construction. Had the buffer width reduction been necessary to obtain a fourth lot and had the fourth lot been approved accordingly, it would have been easier to make the argument that the applicant wouldn't necessarily be vested for the purposes of determining building footprints. But because that wasn't the case, it stands to reason that the primary purpose of obtaining the buffer width reduction at the plat stage was to create some certainty with regard to future allowable building footprints. R1100 Dexter Ave N Suite 100 Seattle WA98109 P 20&273.7440 F 206.273.7401 1 www.lighthouselawgroup.com The Noble Manner and Alliance Investment Group cases both emphasized this language: If a landowner requests only a division of land without any specified use revealed, then the county, city or town may consider the application to see if any legal use can be made of the land so divided, and no particular development rights would vest at that time. However, when an application is made for division of land for a specified use, then the applicant has the right to have that application for that use considered under the land use laws in effect on the date of the application. Here, the buffer width reduction that was sought by Echelbarger Investments and ultimately approved by the City as part of the short plat process would likely be considered the kind of "specified use" that would allow this short plat to vest to the previous CAO for the purposes of determining building footprints at the building permit stage. For that reason, I now believe that the city should treat this short plat as vested to the earlier CAO. Please feel free to contact me if you have any follow up questions.