20190604_response letter.pdf
PO Box 1478 ⬧ Everett, WA 98206 ⬧ Phone: (425) 303-9363
Fax: (425) 303-9362 ⬧ Email:info@insightengineering.net
May 23, 2019
Karen Lien
3000 Rockefeller Ave.
Everett, WA 98201
(425) 388-3311
Re: Langford – PLN20180064
IECO No. 19-0992
Dear Karen,
The project referenced above is revised in response to the review comments dated December 6,
2018. The review comments are numbered on the letter and have been addressed in italics as
follows:
1. Geotechnical Report: The critical area determination conducted on 1136 Vista Place
under file number CRA20180201 identified slopes on the site that exceed 40% which are
considered potential landslide hazard areas pursuant to Chapter 23.80 ECDC. A
geotechnical report consistent with requirements of ECDC 23.80.050 and addressing the
specific requirements ECDC 23.80.060 and .070 must be prepared to evaluate the
potential impacts of the proposed subdivision. Please also see the comments under
Subdivision Review Criteria below which will relate to the development and review of
the geotechnical report.
Please see the submitted Geotech report included with this submittal.
2. Wetland Determination: The critical area review under file number CRA20180201 also
identified an off-site wetland that may have buffers that extend onto the subject property.
In 2016 a wetland report was submitted for a project located at 1142 Vista Place. The
wetland was determined to be a Category III wetland. Wetland buffers for Category III
wetlands range from 60 feet to 225 feet depending on habitat score. The wetland rating
system has changed since the 2016 report was prepared so the extent of the buffers
cannot be determined; however, given the potential for a 225 buffer and the wetlands
location shown at 96 feet from the property boundary, the wetlands buffers may extend
onto the subject property. I have included the old wetland report regarding this wetland
for your reference. It must be determined whether the buffers from this wetland extend
onto the subject property. Understanding that the wetland is on adjacent property and
access to the wetland will rely on the adjacent property owner granting access for a
PO Box 1478 ⬧ Everett, WA 98206 ⬧ Phone: (425) 303-9363
Fax: (425) 303-9362 ⬧ Email:info@insightengineering.net
determination, there may be other options regarding the impacts of this wetland. First, I
would suggest contacting the adjacent property owner to see they will grant access. If not,
perhaps the old wetland report can be updated using the current wetland rating form to
determine the habitat score and thus the associated buffer width. Finally, depending on
whether the private drive needs widening (see fire comments below) the developable
portion of the site may be in an interrupted buffer. The interrupted buffer determination
consistent with the requirements of ECDC 23.40.220.C.4 would have to be approved.
Please submit an updated wetland report or, if appropriate, an interrupted buffer
determination.
A wetland evaluation report is included with this submittal.
3. Easements: The title report identifies a number of access and utility easements on the
subject property. Please provide these easements which are identified by the following
auditor file numbers (AFN) in the title report: 815306, 1126222, 1625989, and 1444635.
Additionally, the location of these easements and any other easements on the subject
property must be identified on the preliminary short plat.
The easements have been shown and labeled with their AFNs.
4. Preliminary Short Plat:
a. Surveyor signature – ECDC 20.75.040 requires the preliminary short plat to be
signed by the surveyor and preliminary short plat submitted with the application
was not signed by the surveyor. Please submit a preliminary short plat signed by
the surveyor.
Please see the signed preliminary short plat map.
b. Gross and Net Lot Area – Identify the gross and net lot area of each of the
proposed lots. Note that any access easement must be subtracted from the gross
lot area and the resulting net lot area must be at 12,000 square feet.
The gross and net areas have been outlined in the new short plat.
c. Please identify all structures within 25 feet of the subject property as required by
ECDC 20.75.060.M.
Any structures within 25 feet of the property line have been shown.
5. Site Bench Mark: The topography survey submitted with the application indicates the site
benchmark is a nail in the asphalt as shown with an elevation of 349.9. The site
benchmark identified in the survey notes an elevation of 280.1. Please verify the site
benchmark and associated elevation.
PO Box 1478 ⬧ Everett, WA 98206 ⬧ Phone: (425) 303-9363
Fax: (425) 303-9362 ⬧ Email:info@insightengineering.net
6. Subdivision Review Criteria: The criteria for reviewing subdivisions is contained in
ECDC 20.75.085. On initial review, more documentation is needed to demonstrate that
the criteria below can be met:
a. ECDC 20.75.080.A.4 Where conditions exist which could be hazardous to the
future residents of the land to be divided, or to nearby residents or property, such
as floodplains, steep slopes or unstable soil or geologic conditions, a subdivision
of the hazardous land shall be denied unless the condition can be permanently
corrected, consistent with subsections (A)(1) and (2) of this section.
Almost all of the proposed Lot 1 consists of slopes in excess of 50%. Developing
this site may require a significant cut into the hillside which could impact slope
stability and existing residence on the top of the slope. The geotechnical report
must address how this site could be developed and how the hazard can be
permanently corrected. As noted in the Building Division comments (attached), it
is likely that peer review will be required for the geotechnical analysis and design.
Note the cost peer review is required to be covered by the applicant.
Please see the included geotechnical report.
b. ECDC 20.75.080.B.1 Lots shall be designed to contain a usable building area. If
the building area would be difficult to develop, the lot shall be redesigned or
eliminated, unless special conditions can be imposed on the approval which will
ensure that the lot is developed properly.
In addition to the slopes on the proposed Lot 1, the orientation of Lot 1 with the
private drive that transects the lot further limits the buildable area and makes this
a difficult site to develop. The proposed residence for Lot 1 shown on the
preliminary development does not comply with the setbacks for Lot 1. A lot
cannot be created through the subdivision process that would require a variance in
order for it to be developed.
The setbacks have been corrected on the revised plan.
Different layouts for subdividing this property were presented during the two pre-
application style meetings over the last year. Given the review criteria in ECDC
20.75.080A.4 and 20.75.080.B.1, a different layout of the proposed subdivision
should be given strong consideration. Otherwise, please demonstrate how the
proposed layout complies with these criteria.
The layout has been changed. Lot 2 is now much larger, and has a larger portion on
the southeast corner of the site. It should be noted that an 80-foot lot circle can fit
onto it. There are technically now two buildable pads on Lot 2, one in the east and
one in the west. While the west is still where the client wishes to build, there is also a
possibility of building elsewhere.
PO Box 1478 ⬧ Everett, WA 98206 ⬧ Phone: (425) 303-9363
Fax: (425) 303-9362 ⬧ Email:info@insightengineering.net
7. Fire Comments: The proposal was review by South Snohomish County Fire District;
whose comments are attached. The Fire District notes that the private drive would serve
three lots following this subdivision. If the private drive is to serve three lots, it would
need to be widened to 20 feet and a fire department turnaround provided. Alternatively,
in place of a 20-foot wide drive, a second gate could be installed which would prevent
Lot 1 from access via Vista Place from the Olympic Avenue side. Both gates (including
the existing one on the 12th Avenue side of the property) would need to be equipped with
a key switch and Opticom sensors.
The existing home will now not be served by the private drive, and will instead only
access from 12th Ave. The new lot will not have access to 12th Ave. Therefore, the existing
easement should be sufficient for the new lot and the existing lot to the south which would
share access with it.
8. Please respond to the comments from Jeanie McConnell, Engineering Program Manager,
provided in the attached memorandum. If you have any questions on Ms. McConnell’s
comments, you may contact her.
See below.
Memorandum from Jeanie McConnell, Engineering Program Manager
December 6, 2018
GENERAL
1. Provide a site plan that shows access point from Vista Place and 12th Ave N.
The access points have been labeled.
2. Label roads as private or public right-of-way (ROW) and provide dimensions for ROW
and/or easement areas.
These specifications have been provided on the plat map for both Vista Place and 12th
Ave N.
3. Label existing pavement width of Vista Place adjacent to the subject property, as well as
the existing pavement width of that section or ROW that provides a connection between
the subject property and 12th Ave N.
The pavement has been added and the widths have been labeled.
4. Show existing access easement areas and existing pavement areas on one plan sheet. Will
the existing and proposed pavement areas fall within existing easement areas?
The pavement areas have now been shown, as well as the easements.
PO Box 1478 ⬧ Everett, WA 98206 ⬧ Phone: (425) 303-9363
Fax: (425) 303-9362 ⬧ Email:info@insightengineering.net
5. From the plans provided it looks as though the existing driveway that loops from Vista
Place to 12th Ave N will remain. Please confirm and refer to South Snohomish County
Fire District comments.
The driveway is no longer to remain as-is—some of it will be removed to prevent access
to 12th Ave N.
6. Refer to South Snohomish County Fire District comments for access width requirements.
Comment noted.
UTILITIES
1. Show the location of stormwater systems, sanitary sewer systems, water mains, water
meters, and water service lines adjacent to or within the proposed subdivision. Utilities to
the existing and proposed homes shall be shown. Provide approximate invert elevations
for side sewer at house, property line and new connection to main to show feasibility.
Call out length and size of all pipe to verify slopes.
Please see the revised plan.
2. If a fire sprinkler system is required for the proposed single-family residence, the water
service to the property will need to be larger than what’s proposed. Typically, a 1” meter
and 1 ½” water service line provides sufficient flow. Revise plans accordingly.
Please see the revised plan.
3. Show the location of existing and proposed dry utilities within the subject site. All new
services shall be installed underground.
Please see the revised plan.
Comments from Zack Richardson, PE, Stormwater Engineer
November 30, 2018
Review comments:
1. Drainage Report: In 5.4, expand text to more clearly explain that “mitigate (801)”
represents the combined flows (ie. vault overflow plus bypass).
The report and method of stormwater disposal has changed. Please see the new report.
2. Drainage Report: No action required at this time, but omission of the downstream
analysis (as stated in 6.1.3) is only permitted if the report continues to show that the
combined discharge will be less than existing condition; future revisions shall maintain
this condition or the analysis will be required.
Please see the new report. We are proposing infiltration for all new impervious areas.
PO Box 1478 ⬧ Everett, WA 98206 ⬧ Phone: (425) 303-9363
Fax: (425) 303-9362 ⬧ Email:info@insightengineering.net
3. Drainage Report: In the first paragraph of 6.5, please remove the term “earth subsidence”.
a. The earth subsidence and landslide hazard area (ESHLA) is a specific area of
Edmonds in which this project is not located; the site contains only a (more
typical) landslide and erosion hazard areas.
Please see the new drainage report.
b. Keep in mind that the construction of retaining walls may eliminate small
localized landslide hazards and may not still be applicable as an infeasibility
criteria for LID BMPs after the project completion; include geotechnical
evaluation or report text to address the size and scope of the landslide hazard
and/or changes to the landslide condition as a result of the proposed project.
Please see the revised geotechnical report.
4. Drainage Report: Section 6.5 references a section of the ECDC 18.30 which cannot be
identified, update reference as needed. It is believed that the reference is intended to be
18.30.06.D.5.b.v.b.i, however that section is only applicable to projects which do not
discharge to the City’s MS4 and does not appear applicable to this project
(18.30.06.D.b.v).
Not applicable, as the report has changed.
5. Drainage Report: Update the MR#5 section to list specific infeasibility criteria for each
BMP, working in order down the BMP list.
a. A geotechnical report is likely still required in order to determine all BMPs
infeasible; include geotechnical report with next submittal.
Please see the infeasibility table shown in Appendix A of the drainage report.
6. Drainage Report: It is unclear why the orifice elevation is -0.0416’ in the WWHM model;
adjust to zero or clarify as needed.
The detention system has been removed so this comment is no longer valid.
7. C5: Per SWMMWW III-3.2.3.Access.8, the minimum height of detention vault shall be
7’, which exceeds the current depth proposed; revise detention design or product-type (ie.
detention tank; see Edmonds Addendum 6.3 for additional guidance) as needed.
The detention system has been removed so this comment is no longer valid.
8. C5: It appears the current proposal may not meet SWWMM recommended setback
requirements for the vault (property line, structure, and steep slope); update plan or
include additional text in drainage report as needed to address setbacks from the vault.
PO Box 1478 ⬧ Everett, WA 98206 ⬧ Phone: (425) 303-9363
Fax: (425) 303-9362 ⬧ Email:info@insightengineering.net
The detention system has been removed so this comment is no longer valid.
Memorandum from Leif Bjorback, Building Official
December 3, 2018
1. Building permits will be required for the following, as applicable: New home
construction; retaining walls; modifications to or demolition of existing structures.
Comment noted.
2. Dwellings exceeding 3000 square feet of fire area require fire sprinklers.
Comment noted.
3. Park Impact fees will be assessed for each new dwelling at a rate of $2734.05 each. The
fee may be waived for new homes that replace old homes provided the new construction
occurs within one year of the demolition of the old structure.
Comment noted.
4. The topography of proposed Lot 1 contains slopes in excess of 50% and, given the
dimensions and orientation of the lot, appears to be a difficult site to develop.
Excavations, foundation design and related site work will be required to be based on a
geotechnical analysis. It is highly likely that temporary shoring will be required, and
slopes excavation cuts will be limited to generally accepted engineering practices. It is
also likely that peer review will be required for the geotechnical analysis and design.
Okay, the owner understands additional geotechnical work will be needed to develop the
lot.
Comments from Karl Fitterer, Assistant Fire Marshal
November 29, 2018
Private drive services 3 or more residents would need a fire department turnaround and driveway
would need to be 20 feet wide. In place of 20 foot wide drive a second gate would need to be
installed and both gates would need to be equipped with a key switch and Opticom sensors. This
would enable the drive to be at Edmond’s City standards (12 feet paved). Also, will need signs
placed at 50 foot intervals stating “NO PARKING FIRE LANE” along private drive.
As the private drive would only serve 2 lots, the widening should no longer be necessary.
Please feel free to contact me with any questions or comments you may have.
Sincerely,
Brian Kalab, P.E.