S-06-44 Planning Civil Review - 3rd Review.pdfCITE' OF EDMONDS ® 1215"' AVENUE NORTH - EDMONDS, WA 98020
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December 22, 2011
Mr. Erich Tietze
Via email: eota@clearwire.net
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Dear Mr. Tietze:
I have reviewed your resubmittal submitted on November 17, 2011 for civil review for the
above project for the Planning Division, and it was found that the following information,
corrections, or clarifications will need to be addressed before review can continue:
Tree Removal: Your plans indicate removal of several trees from Lot A that are well
outside of the footprint of the proposed civil improvements. Since the house is not
being constructed on Lot A at this time, please revise the proposed tree removal to only
remove those trees necessary to construct the civil improvements. Removal of other
trees will be reviewed at the time of future building permit application submittal.
When revising the plans to indicate removal of only those trees necessary to construct
the civil improvements, please also relocate the construction fencing to be as far from
the trees to be retained as possible in order to ensure adequate tree protection during
construction.
2. Geotechnical Report: Your response letter states that the applicant will have a
geotechnical report prepared and that it will be submitted separately. This report has
not yet been received, so I am unable to complete this portion of my review. Please
note that the geotechnical engineer will need to review the most current set of civil
plans in addition to addressing my previous comments from my February 17, 2011
letter, which were as follows:
Since much of the site contains a Landslide Hazard Area, this phase of the proposal will
need to be reviewed by a qualified geotechnical engineer pursuant to ECDC 23.40 and
23.80. The geotechnical engineer will need to review all plans for the civil
improvements as well as the vegetation management plan and proposals for tree
removal. Since changes are required to both the civil plans and the vegetation
management plan at this time, the updated versions of these plans must be reviewed by
the geotechnical engineer. Please provide a report by a qualified geotechnical engineer
that addresses how the proposed work associated with the civil improvements, tree
removal, and vegetation management plan is consistent with the critical areas
regulations of ECDC 23.40 and 23.80 and providing any additional recommendations
for what would need to be done in order to comply with the critical areas regulations
and avoid any potential negative impacts to the stability of the slope.
3. Vegetation Management Plan: Your response letter states that Wetland Resources,
Inc. is in the process of revising their report and that the report will be submitted
separately. This report has not yet been received, so I am unable to complete this
portion of my review. Due to the change in location of the NGPA with your
resubmittal, you will need to provide Wetland Resources with a copy of your revised
plans so that they may update their report as necessary to reflect the new location of
the NGPA and any changes to their recommendations based on the revised location of
the NGPA, in addition to addressing my previous comments from my February 17,
2011 letter, which are as follows:
Please request that Wetland Resources, Inc. revise the Vegetation Management Plan
dated July 24, 2009 to address the following comments:
a. It is stated in one location on page two of the plan that 7 conifers and 1 deciduous
tree within the NGPA areas could be impacted during construction activities, but
then it is stated elsewhere on page 2 that 7 conifers and 2 deciduous trees could be
impacted. Correct this discrepancy.
b. A section regarding building setbacks is provided on page 2 of the plan. The code
section referenced (ECDC 23.40.280) refers to building setbacks from the edge of
critical areas buffers, but does not necessarily apply to NGPAs. The civil plans
indicate possible future buildings footprints on Lots A and B that are located well
within 15 feet of the NGPAs. This section of the plan should be clarified or
possibly removed.
c. The Vegetation Management Plan should include the tree protection measures of
ECDC 18.45.050.1-1 for protection of existing trees that are to be retained during
construction activities.
d. The existing water and side sewer lines serving the existing residence go through a
portion of the NGPA on Lot C. The Vegetation Management Plan should include
provisions regarding what must be done to restore this portion of the NGPA if it is
disturbed by utility work on these existing lines, and the plan should also include
provisions on what must be done to restore any other portions of the NGPA areas if
disturbed by other construction activities.
e. State within the plan that all applicable City codes shall be followed for removal of
any trees or vegetation from within the NGPA areas in the future.
£ ECDC 23.40.220.C.7 provides regulations for vegetation removal from within
critical areas. This section requires a replacement ratio for hazardous trees within
critical areas of 2:1 and also a minimum replacement size of one inch in diameter at
breast height for deciduous trees and a minimum of six feet in height for evergreen
trees. Although this section discusses hazardous tree removal specifically, its
guidance for replacement ratios and sizes can also be applied to removal of trees
within the NGPA that are damaged by construction. Although the proposed
replacement ratio of 3:1 is higher than what is required by code, the proposed
replacement size of 1 gallon trees is substantially smaller, and following the
numbers set forth in the code will be more effective for mitigating any impacts
from tree removal. As such, the Vegetation Management Plan should be revised to
require a tree replacement ratio and tree sizes consistent with this code section.
g. Page 3 of the plan states that all disturbed ground within on-site critical areas shall
be seeded with grasses as recommended. Although this may be appropriate for
disturbed areas outside of the NGPAs, disturbed areas within the NGPAs should be
restored with native trees, shrubs, and groundcover. Thus, this section should be
clarified as to which areas of the site should be seeded with grasses and how
disturbed areas within the NGPAs should be restored. In particular, page 3 of the
plan states that no mitigation plantings are being provided for the removal of
invasive species within the NGPA areas; however, due to the slopes on the site, a
combination of ground cover and mulch at a minimum should be planted to reduce
erosion potential and help prevent invasive species from entering back into the site.
h. The plan states that no wetlands are present on the site, but the plan refers to
monitoring by a wetland biologist and makes reference to wetland requirements in
a few locations of the plan, particularly on pages 3 and 6. If there no wetlands are
present on or adjacent to the site, these references to wetland requirements should
be removed from the plan. If there are wetlands present, then the proposal needs to
meet the requirements of ECDC 23.50.
i. Page 4 of the plan refers to a potential performance bond. A performance bond will
not be required if all work is done at the applicable times; however, a maintenance
bond may be required. This section should be corrected to state that any bond
requirements will be established by the City and that a maintenance bond may be
required.
j. For the project monitoring program, as discussed on page 4 of the plan, the
requirement for annual site inspections is established. Please provide additional
information on who will do the monitoring and initial compliance report. A report
by a qualified professional must be provided to the City at the end of the mitigation
period in order to document compliance with the requirements of the plan. Also,
within the requirements for the monitoring program, the plan states that upon
completion of the disturbance activities on the subject property, an inspection by a
qualified professional will be made to determine plan compliance. The plan should
clarify what is meant by disturbance activities and whether this is referring to the
civil improvements and/or construction of the new homes on Lots A and B.
Please make all submittals to the Engineering Division, Monday through Friday, excluding
Wednesdays between 8:00 am and 4:30 pm. If you have any questions, feel free to contact
me at (425) 771-0220, ext. 1224.
Sincerely,
Development Services Department - Planning Division
msµ'
Jen Machuga
Associate Planner
Cc: Carl Clap (via email to carclp@comcast.net)