2020-10-07 PLN2020-0037 City request for reconsideration Order Correcting NoticeCITY OF EDMONDS
121 5th Avenue North, Edmonds WA 98020
Phone: 425.771.0220 • Fax: 425.771.0221 • Web: www.edmondswa.gov
DEVELOPMENT SERVICES DEPARTMENT • PLANNING DIVISION
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REQUEST FOR RECONSIDERATION – ORDER CORRECTING NOTICE
Project: Diamond Parking Services LLC
File Numbers: PLN2020-0037 – Conditional Use Commercial Parking
Date: October 7, 2020
From: __ __________________________
Mike Clugston, AICP, Senior Planner
I believe the contents of this request to be true.
I. CITY REQUEST FOR RECONSIDERATION OF HEARING EXAMINER’S
ORDER TO CORRECT NOTICE
On September 29, 2020, the Hearing Examiner issued an Order to Correct Notice for the
referenced public hearing. In the Order, the Examiner requested that:
“Notice required by ECDC 1.03.020 shall be posted in the areas currently1
required by ECDC 1.03.020 at least 14 days prior to the date of a re-opened
hearing. Staff is free to add any additional hearing notice it deems appropriate.
1 To be safe, it would be best if staff posted at the locations under the current
version of ECDC 1.03.020 and that which was in effect 14 or more days prior to
the August 27, 2020 hearing date. If the US Post Office and/or library is closed to
the public and staff doesn’t have access to the notice boards in those buildings,
staff need not post in those locations.”
According to Section 20.06.140 of the Edmonds Community Development Code
(ECDC), any party of record with standing may request reconsideration of a decision the
Hearing Examiner issues immediately after the open record public hearing on a land use
permit application. Reconsideration is limited to:
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1. Error(s) of procedure;
2. Error(s) of law or fact;
3. Error(s) of judgement; and/or
4. The discovery of new evidence that was not known and could not, in the exercise
of reasonable diligence, have been discovered.
The City requests that the following error of fact be revised.
The code references to “ECDC 1.03.020” should be to “Edmonds City Code (ECC)
1.03.020”.
The City requests that the following errors of procedure be revised.
At the time public notice of the subject hearing was posted on August 10, 2020, ECC
1.03.020 required the following three locations to be posted:
A. Public bulletin board in the Edmonds Civic Center, 250 Fifth Avenue North,
Edmonds, Washington, 98020;
B. Public bulletin board in the Edmonds Public Library, 650 Main Street,
Edmonds, Washington, 98020; and
C. Public bulletin board, Edmonds branch of the United States Post Office, 201
Main Street, Edmonds, Washington.
Due to building closures resulting from COVID-19, the public bulletin boards in the
Edmonds Civic Center (now the Public Safety Complex) and the Edmonds Public Library
were closed to the public. Staff did not have access to those locations and could therefore
not post them. Furthermore, because those buildings were closed to the public during the
relevant period, posting a notice inside those buildings would not have contributed to
public notice of the hearing.
More importantly, the September 29, 2020 hearing examiner order directs that notice be
provided in a manner that is no longer possible. Specifically, the Edmonds Post Office at
201 Main Street, and the public bulletin board inside it, no longer exists. That building
was demolished in 2017. The City does not believe that the examiner would have
required this notice procedure had he known about the building demolition. But the order
as written, because it requires the impossible, constitutes procedural error, unless the
order is interpreted to only require compliance with the version of ECC 1.03.020 that
took effect on August 23, 2020.
To correct the code regarding posting notices at the Post Office site, the Edmonds City
Council passed Ordinance 4193 on July 21, 2020. As of the August 23, 2020 effective
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date of the ordinance, public notice now must be posted at the following three locations:
A. Public bulletin board in the Edmonds Public Safety Complex, 250 Fifth Avenue
North, Edmonds, Washington, 98020;
B. Public bulletin board in the Edmonds Public Library, 650 Main Street,
Edmonds, Washington, 98020; and
C. Public bulletin board, Edmonds City Hall, 121 Firth Avenue North, Edmonds,
Washington.
This version of the code was not in effect on August 10, 2020. Staff posted the notice for
the referenced hearing as required by the code on August 10, 2020 to the extent that was
possible. As noted above, both the Public Safety Complex and Public Library were
closed due to COVID-19 so access to the public bulletin board in those buildings was not
possible. The old Post Office building at 201 Main Street no longer existed. And even if
the new version of ECC 1.03.020 had been in effect on August 10, 2020, Edmonds City
Hall is closed to the public except by appointment. So, posting on that bulletin board
would have been of little benefit to the public.
As a result, staff requests that the referenced hearing not be re-opened for additional
posted notice because the project was posted as able on August 10, 2020 given the
circumstances at that time. Alternatively, if the hearing examiner still believes that
additional compliance with ECC 1.03.020 is necessary, the City asks that the examiner
direct compliance with the version of the code that existed on September 29, 2020, but
only to the extent that such buildings are open to the public.