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Response Letter 7.15.16.pdfJuly 15, 2016 Jen Machuga City of Edmonds 121 5th Avenue North Edmonds, WA 98020 RE: Resubmittal of Revised Edmonds Short Plat 18227 80th Avenue West City of Edmonds File No. PLN20150031 / Our Job No. 15370 Dear Jen: Wilson & Neal, PLLC Attorneys at Law J" 4 We have revised the plans and technical documents for the above -referenced project in accordance with comments we have received from City of Edmonds staff. Enclosed are the following documents for your review and approval: 1. Five full-size copies of the revised preliminary short plat map 2. One 11x17 -inch copy of the revised preliminary short plat map 3. Three full-size copies of the revised civil engineering plans 4. One 11x17 -inch copy of the revised civil engineering plans 5. Three copies of the preliminary stormwater site plan report dated July 8, 2016 prepared by Taylor Engineering Consultants 6. Three copies of the geotechnical engineering study dated June 29, 2016 prepared by Geotech Consultants, Inc. 7. Infiltration considerations dated March 11, 2015 (updated and legible sieve analysis exhibit attached dated June, 2016) prepared by Geotech Consultants, Inc. The following outline provides each of the comments in your letter dated January 21, 2016 in italics exactly as written, along with a narrative response describing how each comment was addressed: Your proposal for all three lots to utilize separate access driveways is not consistent with regulations requiring the proposal to minimize grading and causes concerns related to traffic safety (see attached Engineering Division memo). Additionally, the proposed lot layouts are not practical and could result in potential future private property issues since the property lines are not located in logical locations. Concerns were also raised related to the site design and access during the public comment period. One of the subdivision review criteria of ECDC 20.75.085 states the following: "The proposal shall be designed to minimize grading my using shared driveways and by relating street house site and lot placement to the existing topography." Based on the current proposal, staff cannot find that this criterion is being met. It appears that the subject site may be a good candidate for a modification request in order to propose more logical lot layouts and access. Modification requests could PO Box 158 Kent, WA 98035 + (206) 805-6238 Office # (206) 550-3189 Mobile Terry@WilsonNeal.com Jen Machuga City of Edmonds July 15, 2016 Page 2 take the form of a proposal for reduced minimum required setbacks, lot area, and/or lot width. The fee for a modification request is $795 per type of request, and such request also requires a written statement addressing the review criteria of ECDC 20.85.010. It shall be noted that a modification request requires public notice and may only be approved if all of the required findings set forth in ECDC 20.85. 010 can be made. Response: A separate modification request accompanies this resubmittal package addressing the layout issues and grading issues raised. 2. If your long-term plan is to replace the existing residence, you may find that demolishing the existing residence with the subdivision would allow you greater flexibility with the location of the lot line between Lots 1 and 2. It should be noted that if the proposal requires the removal of the existing residence, demolition would not need to occur until the time of final review of the short plat, not with preliminary review. Response: Our current proposal is to keep the existing residence. 3. Please revise your preliminary plans as necessary and provide a cover letter responding to the enclosed comments from the Engineering Division dated December 21, 2015 Response: All plans have been revised as requested and individual responses to all engineering comments have also been provided herein. 4. Thank you for providing a geotechnical report. This report, however, does not provide any references to the applicable critical areas code requirements of ECDC Chapters 23.40 and 23.80. As previously requested, your geotechnical engineer must include sufficient evidence as to how the design standards of ECDC 23.80.070.A.3 will be met through the proposal, or if an alternative design would be more compliant with these requirements. Design alternatives to consider include, but are not limited to, lot layout, vehicular access, future building location, etc. After revising the proposal in response to the above comments, please provide the revised proposal to your geotechnical engineer and request an addendum to the previous report that clearly reviews the revised proposal's compliance with the applicable critical areas code requirements of ECDC Chapters 23.40 and 23.80, including a specific analysis of the proposal's compliance with the design standards of ECDC 23.80.070.A.3. Response: The geotechnical report has been updated by Geotech Consultants dated June 29, 2016. The report has been updated to include more specific information with regard to Chapter 23.40 of the Edmonds Code. Erosion Hazard Area and a Landslide Hazard Area has been discussed in the study per Chapter 23.40. In addition, the report has been updated with regard to Chapter 23.80 of the Edmonds Code. Several points are included in the updated report, in particular on Pages 3 and 4, with regards to information requested in Chapters 23.80.60 and 23.80.70. Your January 21 letter noted that information related to Chapter 23.80.70.A.3 was needed in the report; this portion of the code refers to an "alteration". However, per Chapter 23.80.70.A.1 and 2, any setbacks and/or buffer from Hazard Areas are determined by the geotechnical engineer, which are included in the June 29 report, and thus no alterations are needed. 23.80.A.3 does not apply to this project. The following outline provides each of the comments in JoAnne Zulaufs Memorandum dated December 21, 2015 in italics exactly as written, along with a narrative response describing how each comment was addressed: Jen Machuga City of Edmonds 1. Completed. Response: No response required. 2. Completed. Response: No response required. 3. Completed. Response: No response required,. 4. Completed. Response: No response required. July 15, 2016 Page 3 5. 12/21/15 It is still unclear how the driveway runoff for Lot 2 and Lot 3 will be collected. Please show the collection point and the conveyance to an infiltration system. Current CBs are not shown in or partially in the pavement area and therefore cannot collect runoff from those areas as drawn. Please specifically identify on the plan how the driveway(s) runoff will be collected. The storm systems shown appear to be shared though it is unclear. The access road and the impervious surface total from each lot shall be connected to a storm system. Lot 1 existing impervious surface will only need to be connected to a storm system if the existing house was constructed after 1977 or the existing house will be demolished. If the existing home is demolished, all impervious surface on that lot will need to be connected to a storm system as well. Response: On the plans previously submitted, the driveways would logically have been sloped toward the center swale. The current layout is different as a result of other comments, and includes a common driveway which has an inverted crown, sloped toward a shortened swale at the east end. Slope arrows now show the intent for all driveway runoff to flow to this ditch/swale. The CB is located outside the pavement because it's primary function is as a common collection point for all the site pipes and adjacent surface flow, with an oil -water separator prior to discharge to the drywell, which also includes a (bottomless) catch basin. 6. Completed. Response: No response required. 7. 12/21/15 At the connection to the public sewer system at manhole will be required. Please show on plan. To show feasibility of the sewer system, provide rim and invert elevations from proposed structures on each lot to a clean out at the property line and then on to a connection to the public sewer main. Please include length and size of all pipe to verify a minimum of 2% slope can be attained. Response: A Manhole has been added along with the required run data. 8. 12/21/15 Please see the stormwater engineer's comments below. Please provide an infiltration stormwater report including testing information using one of the approved testing Jen Machuga City of Edmonds July 15, 2016 Page 4 methods found in the City of Edmonds Stormwater Supplement Appendix C. The Supplement can be found on our website under Handouts Response: Please see enclosed stormwater report addressing the concerns that have been raised. 9. 12/11/15 Please see transportation engineers comments below.. The intention and arrangement of the access road(s) is unclear. a. 12/21/15 Please see transportation engineer's comments below. The proposed access along with the existing driveway and the driveway adjacent to the east will create a 50' expanse of asphalt with only a small area of vegetation between them. Please revise reducing the excessive access entry to the lots. An option would be to demo the driveway access from the east to the existing house and use only the west entrance. Then the access road to the other two lots could be reduced to a 15Access easement with 12' paved. Response: Please see enclosed revised Short Plat drawing and revised Engineering drawings. The layout has been revised to eliminate the "panhandle/flag lot" layout and a 26' proposed access and utility easement has been proposed, along with an accompanying modification request for the reduction of lot sizes for Lots 2 and 3. b. 12/21/15 Utility easements will be required to be shown during the civil review process. There is a label stating that a 30 x 20 area adjacent to the road is an Access/Utility easement. It appears that the road will be on both lot 2 and 3 property and that the utilities will also be on both properties through the road. If this is the case then the entire access road would be the Access/Utility easement. Please clarify. Response: Please see enclosed revised Short Plat drawing and revised Engineering drawings. The layout has been revised to eliminate the "panhandle/flag lot" layout and a 26' proposed access and utility easement has been proposed, along with an accompanying modification request for the reduction of lot sizes for Lots 2 and 3. c. Completed. Response: No response required. 10. Completed, Response: No response required. Traffic _R_goort Review. Sertr. nd Hauss Trns ortation Engineer: I have concerns regarding access from / to LOT #1 onto 80th Ave. W (especially for drivers backing out of driveway to access 80th Ave. W). In order to provide a safer access, the driveway from LOT #1 should join the other (2) driveways further to the east, so drivers only have to turn their heads @ 90degree angle to see vehicles coming from the south (instead of much more / very uncomfortable unsafe position under current layout). Can that movement be completed safely / show AUTOTURN layouts? In order to further improve access from LOT 1 and 2 (for drivers backing out), a turnaround within the property should be provided so they are facing 80th Jen Machuga City of Edmonds July 15, 2016 Page 5 Ave. W. when coming out of the driveway. Please see City Standard Detail E2.6 for on-site turnaround requirements. Response: The access driveway to Lot 1 has also been relocated further East. Engineering plans have also been revised to remove sections of the existing driveway and propose access driveways that should satisfy the city's turn around standards. Stormwater Review.- Jeay Shuster Stormwater En ineer The stormwater report information submitted is incomplete and therefore a full review was not possible. Infiltration is feasible on this site based on the soil descriptions in the geotech letter dated 3/11/2015. The figure in that report with the sieve analysis (plate 4) was difficult to read making it impossible to confirm any of the body of the report. Project is >10,000 sf of impervious is proposed and it is near a steep slope, I would require a pilot infiltration test (Appendix C of the Stormwater Supplement) for this site and not solely rely on sieve analyses. Response: The TIR has been revised to document that the project is < 10,000 sf. It never was >10,000 sf — we attempted to convey our desire to size the infiltration facility for the existing impervious roof area, even though it was not technically required per Section 2.3 of the Edmonds Stormwater Code Supplement (ESCS). The new area take -offs document how the project meets the requirements for use of the presized calculations, and the required drywell size is reduced to 609 sf. It should be noted that we conservatively used the largest possible Sizing Factor, and now propose to leave the previously -sized 807 sf drywell even though it is larger than required. If a pilot infiltration test is still required, we can certainly have one done, but it will most likely further reduce the required drywell size. The drainage report appears to be using the pre -sizing tables to design the dry well. The project impervious is >10,000 therefore exceeds the maximum for using pre -sized calculations. The infiltration BMPS must be modeled. The modeling results included have no record of the input parameters so it is impossible to verify findings. The spreadsheet with impervious calculations is cut off. Response: See response above for justification for using the presizing tables. The modeling results included in the TIR were missing the input parameters. These have been revised and are now included, but this modeling is only used to generate flows for sizing erosion control facilities. We don't know how the spreadsheet was cut off — the original pdf in our file is whole and intact. Regardless, these areas have been changed as described above and in the revised TIR. The site will have >5000 sf pollution generating impervious surface. The proposal is an "oil water separator elbow" for this. They must include a treatment system per the Ecology 2005 manual. Please revise report and resubmit. Response: Similar to the impervious area discussion above, if the existing pavement is taken into account per Section 2.3 of the ESCS, the site will not have > 5,000 of PGIS. The new + replaced PGIS totals 4,985 sf, and in addition, the project will remove 2.978 sf of PGIS, which does not generate any credit for the project, but is nevertheless worth noting. Jen Machuga City of Edmonds July 15, 2016 Page 6 We believe that the above responses, together with the enclosed revised plans and technical documents, address all of the comments we have received. Please review and approve the enclosed at your earliest convenience. If you have questions or need additional information, please do not hesitate to contact me at this office. Thank you. Respectfully, Terrance Randall Wilson Attorney at Law 153700005-S-PRLM-SH PL enc: As Noted cc: Phong Le, Clear Vision Homes, Inc. Trevor Lanktree, Lanktree Land Surveying, Inc.