REVIEWED LETTER FROM ATTORNEY-TIA-RCVD VIA MAIL-DATED 02.15.2021CROWLEY LAW OFFICES, P.S.
One Union Square
600 University Street, Suite 1901
Seattle, Washington 98101
Telephone (206) 224-7069
Fax (206) 624-8785
crowleylawoffices.com
February 15, 2021
City of Edmonds Engineering Program Manager
Jeanie McConnell
Jeanie. mcconnell@edmondswa.gov
City Transportation Engineer
Bertrand Hauss
Bertrand.Hauss@edmondswa.gov
Re: Dental Office located at 22815 Edmonds Way
City of Edmonds,
Julie Seaborn
julie@crowleylawoffices.coin
Our office represents Dr. Zach Streit regarding the charge for a Traffic Impact Fee. The City of Edmonds
is requiring Dr. Streit to pay $36,000 Impact Fee. This should not be required for several reasons.
Per ECC 3.36.040(A)1, the alteration of an existing nonresidential structure that does not involve a change
in use and does not expand the usable space or add any residential units should be exempted from the
payment of all impact fees.
The permit applied for and received by your office on 1/29/2021, is simply to add a non load -bearing wall,
plumbing and cabinetry. None of these work orders include the expansion of existing structures or uses
or change existing uses that create additional demand for public facilities. Therefore, the Impact Fee
should not be required.
This business location went from a medical practice (per the 201.2 Building Permit) to a medical practice.
There is no change in Use. If there is no Change in Use then there is no Impact Fee.
Additionally, there is no increase in traffic so there is no need for a traffic study. From 2012 until 2019,
the prior owner had seven practitioners in the building. There were seven practitioners: four Doctors, a
Nurse, a Therapist and an Aesthetician. There was a total of 11 employees. Those seven practitioners
saw 7 patients per hour, on average. Which is 49 visits per day, which is over 300 visits per week.
Dr. Streit, who purchased the office from the prior owner, has 10-15 patients 3 days a week. Which is
approximately 30 — 40 visits per week, one patient per hour, on average. The impact on traffic has
decreased, rather than increased. Therefore, there is no increase in traffic and an analysis is not required.
Julie Seaborn
julie@crowleylawoffices.com
There have been several phone calls and emails with the Broker and the Traffic Engineer where the City
agrees that there should not be an Impact Fee.
In sum, the City of Edmonds should not require an Impact Fee, there is no Change in Use of this property.
There does not need to be a study. If the City decides to pursue this then send the Appeal form to me
and Dr. Streit will continue to appeal this decision.
Thank ou.
Ju ' Seabo