2006-07-06 Hearing Examiner MinutesahC.1Scly
CITY OF EDMONDS
121 5TH AVENUE NORTH • Edmonds, WA 98020 • (425) 771-0220 • FAX (425) 771-0221
HEARING EXAMINER
FINDINGS, CONCLUSIONS, AND
RECONSIDERATION DECISION
OF THE HEARING EXAMINER
APPELLANTS: Eric Thuesen: AP-06-48 &
Scott & Maria Mallory et al: AP-06-45
CASE NO.: AP-06-45 & AP-06-48
LOCATION: 509 9 b Ave. N
FINDINGS OF FACT AND CONCLUSIONS:
GARY HAAKENSON
MAYOR
1. On July 17, 2006, two parties of record (Rick Gifford on behalf of Eric Thuesen and
Charles LaNasa), submitted timely requests for reconsideration of the Examiner's
Decision on the subject appeals (See Reconsideration Exhibits A - B).
2. The requests for reconsideration were forwarded to the Hearing Examiner on July17,
2006 (Reconsideration Exhibit A) and on July 20, 2006 (Reconsideration Exhibit B).
3. The City of Edmonds Planning Staff requested clarification of the Examiner's decision
on July 20, 2006 (Reconsideration Exhibit Q.
4. ECDC 20.100.020.G gives the Hearing Examiner five working days in which to issue a
written response to a request for reconsideration. This report will address all three of the
requests and will be issued within five working days of receipt of the last two requests.
5. The reconsideration requests identified several areas where Mr. Thuesen and Mr. LaNasa
disagreed with findings, conclusions and conditions found in the July 6, 2006 Hearing
Examiner report on the subject case. Following are the issues identified:
Thuesen Issues: (See Reconsideration Exhibit A).
a. Adequacy of CAS and Wetland Survey:
1) Issue Not Properly Raised on Appeal:
2) Lack of Factual Foundation:
3) Additional Study is Unauthorized and Cannot Lawfully Be Ordered:
• Incorporated August 11, 1890
Sister City - Hekinan, Japan
Hearing Examiner Reconsideration Decision
Case Nos.: AP 06-45 & AP 06-48
Page 2
b. Plat Revision for Three Lots; Vested Status:
c. Finding Re Completeness of Subdivision Application:
Hearin¢ Examiner Response:
a. Adequacy of CAS and Wetland Survey:
As a matter of background for this discussion, the Examiner would like to briefly
review the wetland issue. Mr. Thuesen challenged the staffs decision to require
buffers around the wetland on the basis that the wetland survey determined the
wetland was not large enough to be classified as a regulated wetland under the old
Critical Areas Ordinance (CAO). He would like to be able to fill in the wetland to
allow for construction. The Examiner has concurred with Mr. Thuesen that if the
wetland is indeed an unregulated wetland then it should be treated as such and the
staff conditions relative to the wetland should not be required. However, if the
wetland is determined to be a regulated wetland, then all of the CAO requirements
must be complied with. This is an extremely important point, and one that must then
be based on a careful analysis of the actual size of the wetland.
The Examiner believes neighbors did properly raise the issue of the size of the
wetland when they questioned the wetland delineation accuracy in their letter of
appeal. They went on to submit photos and other information at the hearing that did
not establish the size of the wetland; but did raise significant questions relative to its
size. The burden of proof is on the Applicant (Mr. Thuesen) to show that he has met
the requirements of the Edmonds code. In this case, it is acknowledged staff
accepted the wetland study submitted by the Applicant. However, after review of the
entire file, the Examiner was not and is not convinced the existing wetland study
meets that burden of proof. The Examiner carefully reviewed all of the information
presented at the hearing before arriving at his decision to require another review of
the wetland in question. Also, while not listed in the Findings section of the
Examiner's report, it should be noted that on page 2 under the Public Hearing section
of the report, the Examiner visited the site prior to the public hearing.
Mr. Thuesen would like the Examiner to accept the wetland study on face value as an
exact scientific study that is error free. This Examiner has conducted several hearings
in multiple jurisdictions where wetland consultants have disagreed over the
delineation of boundaries of wetlands and has conducted hearings where land
surveyors have disagreed over survey information. Frankly, this Examiner has found
the delineation of wetlands to be as much art as science. Given the small amount of
difference between the currently determined area of the wetland (2,291 square feet)
versus the area of a regulated wetland under the old CAO (2,500 square feet), and
given the legitimate questions raised during the hearing process, the accuracy of the
final wetland delineation and survey boundaries (effectively how the property can be
developed) is of paramount importance. The Examiner stands by his reasoning for
the need for a new wetland study that was discussed in his original decision. The
Examiner has concluded that the best way Mr. Thuesen can meet his burden of proof
to show that the wetland is truly an unregulated wetland is to restudy the wetland as
described in that report and as conditioned below.
Hearing Examiner Reconsideration Decision
Case Nos.: AP 06-45 & AP 06-48
Page 3
b. Plat Revision for Three Lots: Vested Status:
Mr. Thuesen's Attorney (Mr. Gifford) makes essentially the same arguments (albeit
with more emphasis) as he did at the hearing. He essentially makes the argument that
since the Edmonds code doesn't specifically address the issue of changes or
modifications of a vested application, then the property owner should be able to use
his property as he wishes. In this case he claims he is vested for a three lot short
subdivision and, again, as discussed in the Examiner's original report the Examiner
disagrees. This is a relatively small project, but the applicant is still asking for a 50%
increase over what was vested. Whether the project is a small projector a large
project a 50% increase is still a 50% increase, and this Examiner does not believe any
definition or code provision would consider that to be a minor modification.
Therefore, the Examiner continues to concur with City staff that the project is and
should be vested for two lots.
c. Completeness of Subdivision Application:
Information was submitted by the Applicant that complied with the provisions of
ECDC 20.75.060 F., H, and S on September 14, 2005, but as noted in the Examiner's
decision, said information was not submitted for a three lot short subdivision with the
original application on January 18, 2005. That information should have been
submitted with the original submittal on January 18, 2005 if the Applicant wanted to
be vested for three lots.
Again, the Examiner concurs with staff that vesting only applies to the original
application and not to the substantial modifications submitted by the applicant many
months later.
LaNasa Issues: (See reconsideration Exhibit B).
a. The Applicant lacks a current contractor license.
b. Clarification of minor changes.
c. Requirements to prevent flooding.
Hearing Examiner Response:
a. Contractor License:
As noted in the Examiner's report, the report only addressed the issues raised in the
letters of appeal. The issue regarding the Applicant's contractor status was raised
during the hearing, but was not an issue raised in the letter of appeal. Therefore, the
Examiner did not and will not address it as part of this review process. However, it
should be noted that if the project proceeds (whether the current Applicant or
someone else completes the project), actual construction of the project will need to
comply with all applicable rules and regulations relative to that issue.
b. Minor Changes:
Only minor changes to reflect topographic or other natural constraints were intended.
Complete relocation of driveways, etc. was not approved.
Hearing Examiner Reconsideration Decision
Case Nos.: AP 06-45 & AP 06-48
Page 4
c. Requirements to prevent flooding:
The issues relative to drainage are intertwined with the wetland and following the
new wetland study, engineering staff may gain better information upon which to base
final engineering requirements relative to drainage. However, at this stage in the
subdivision approval process, condition B.1.(4) is believed to be adequate.
6. Staff Request for Clarification: (See Reconsideration Exhibit Q.
a. Did the Examiner approve the short subdivision with conditions, and if so what
exactly are the conditions?
Hearing Examiner Res op nse;
a. Yes, the Examiner did approve the short subdivision for two lots, subject to the
following:
1) The case should be returned to City staff for the specific purpose of confirming
the size. of the wetland on the site. An additional wetland study should be
conducted at the applicant's expense to confirm whether or not the wetland is a
regulated or unregulated wetland as defined by the old CAO ordinance. When the
wetland is surveyed, the wetland biologist who delineated the wetland should be
present to verify that all of the wetland flags are accurately located in the survey.
2) If the wetland is less than 2,500 square feet in area then conditions B.l.a)(1), (2)
& (5), B. Lc) and B.l.d)(3) found in the administrative decision on this case, dated
April 12, 2006 should be deleted. However, if the wetland is greater than 2,500
square feet in area, then the conditions noted above should be revised as necessary
to comply with all of the requirements of the old CAO ordinance.
3) City staff should administratively process the new wetland review. The staff
decision on this issue will be final unless appealed to the Examiner.
b. b. All of the other conditions of approval required in the staff decision on this file,
dated April 12, 2006 should remain in effect.
7. The Applicant's Attorney also submitted a memo, in response to the City staff memo (see
Reconsideration Exhibit D). The Examiner believes the Attorney's response memo is
adequately addressed by the Hearing Examiner's response to the City staff memo.
8. After reviewing the request for reconsideration, the Hearing Examiner decision on the
subject case, and after re -reviewing the original file on this application, the Examiner
reconfirms his July 6, 2006 decision on the subject application, with modifications noted
below. The discussions in the paragraphs above, however, hopefully will provide
additional clarity to the Examiner's intent on this case.
Hearing Examiner Reconsideration Decision
Case Nos.: AP 06-45 & AP 06-48
Page 5
RECONSIDERATION DECISION:
Based upon the foregoing findings and conclusions, the July 6, 2006 Hearing Examiner decision
on the subject case is modified as follows:
The two lot short subdivision is approved subject to the following conditions:
The case shall be returned to City staff for the specific purpose of confirming the size of
the wetland on the site. An additional wetland study shall be conducted at the applicant's
expense to confirm whether or not the wetland is a regulated or unregulated wetland as
defined by the old CAO ordinance. When the wetland is,surveyed, the wetland biologist
who delineated the wetland shall be present to verify that all of the wetland flags are
accurately located in the survey.
a. If the wetland is less than 2,500 square feet in area then conditions B.l.a)(1), (2) &
(5), B.l.c) and B.l.d)(3) found in the administrative decision on this case, dated April
12, 2006 shall be deleted. However, if the wetland is greater than 2,500 square feet in
area, then the conditions noted above shall be revised as necessary to comply with all
of the requirements of the old CAO ordinance.
b. City staff shall administratively process the new wetland review. The staff decision
on this issue will be final unless appealed to the Examiner.
2. All of the other conditions of approval required in the staff decision on this file, dated
April 12, 2006 remain in effect.
Entered this 26th day of July 2006, pursuant to the authority granted the Hearings Examiner
under Chapter 20.100 of the Community Development Code of the City of Edmonds.
Ron McConnell, FA CP
Hearing Examiner
APPEALS:
The following is a summary of the deadlines and procedures for filing appeals. Any person
wishing to file an appeal should contact the Planning Department for further procedural
information.
Section 20.105.020.A & B describe how appeals of a Hearing Examiner decision or
recommendation shall be made. The appeal shall be made in writing, and shall include the
decision being appealed along with the name of the project and the date of the decision, the name
of the individual or group appealing the decision, their interest in the matter, and reasons why the
Hearing Examiner Reconsideration Decision
Case Nos.: AP 06-45 & AP 06-48
Page 6
appellant believes the decision to be wrong. The appeal must be filed with the Community
Development Director within ten (10) working days after the date of the decision being appealed.
LAPSE OF APPROVAL:
Section 20.05.020.0 states 'Unless the owner obtains a building permit, or if no building is
required, substantially commences the use allowed within one year from the date of approval, the
variance shall expire and be null and void, unless the owner files an application for an extension
of the time before the expiration date.'
NOTICE TO COUNTY ASSESSOR:
The property owner may as a result of the decision rendered by the Hearing Examiner request a
change in the valuation of the property by the Snohomish County Assessors Office.
RECONSIDERATION EXHIBITS:
The following reconsideration exhibits were offered and entered into the record.
A. Reconsideration Request from Richard E. Gifford on behalf of Eric Thuesen, dated
7/14/06 (received 7/17/06)
B. Reconsideration Request from Charles A. LaNasa, dated7/12/06 (received 7/17/06)
C. Request for Clarification from Steve Bullock, Senior Planner, dated 7/20/06
D. Memorandum from Rick Gifford, dated 8/24/06
PARTIES OF RECORD:
Eric Thuesen
18333 85a Pl. W.
Edmonds, WA 98026
Gary & Joan Bloom
PO Box 219
Edmonds, WA 98020
Vivian Olsen
509 9a` Ave. N.
Edmonds, WA 98020
Richard E. Gifford
600 Main Street, Suite E
Edmonds, WA 98020
Scott & Maria Mallory
520 8 h Ave. N.
Edmonds, WA 98020
Ken & Vera Reidy
771 Daley St
Edmonds, WA 98020
Bill & Kathy Baird
850 Daley St
Edmonds, WA 98020
Planning Division
City Attorney
Engineering Division
Charles & Carolyn LaNasa
524 8a` Ave. N.
Edmonds, WA 98020
Jim and Barbra McQueen
528 8"' Ave. N.
Edmonds, WA 98020
Laurie Niven
847 Daley St.
Edmonds, WA "98020