S-06-144 Comments on Civils and NGPA - 2nd Review.pdf
CE
ITY OF DMONDS
th
• 1215 AN•E,WA98020
VENUEORTHDMONDS
P: 425.771.0220 • F: 425.771.0221 • W:www.ci.edmonds.wa.us
HONEAXEB
DSD: P•E•B
EVELOPMENT ERVICES EPARTMENTLANNINGNGINEERING UILDING
July 28, 2010
Mr. Steve Miles
Email: smiles@glacierenviro.com
RE: ADDITIONAL COMMENTS ON CIVILS AND VEGETATION MANAGEMENT
PLAN FOR HINKLE/MILES SHORT PLAT
FILE NO. S-2006-144
Dear Mr. Miles:
I have reviewed your resubmittal received on 6/17/10 of your civils and proposed vegetation
management plan for the above short plat, and it was found that the following information,
corrections, or clarifications will need to be addressed, in addition to the comments provided by
Jeanie McConnell on 7/16/10, before review can continue:
1.1/12/10 Comment - It appears that a slight change was made to the property line location
between Lots 3 and 4. Please describe all proposed changes to the locations of the interior
property lines of the short plat made since the preliminary approval. Depending on the
degree of these changes, a minor change to the short plat may need to be processed
pursuant to ECDC 20.75.110.
Thank you for describing the need to slightly shift the property lines within the subdivision.
In order to be able to administratively approve this adjustment, I need to be able to confirm
compliance with the minimum lot size requirements of the RS-20 zone. The minimum net
area (gross area excluding area of any vehicular access easements) per lot is 20,000 square
feet. It appears that the lots will comply with this requirement, but I was unable to
determine the net areas of Lots 1 and 4 since the area of the access easements was not
provided. Thus, please provide gross and net areas of all four lots to confirm that they are
above 20,000 square feet. If any of the lots are less than 20,000 net square feet due to the
shift in property lines, the lines would need to be shifted back so that the lots comply with
this requirement.
2.1/12/10 Comment - 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. 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.
Thank you for submitting a letter from Soil & Environmental Engineers dated 6/10/10.
This letter states that S&EE reviewed Sheets 1 through 5 of your civil plans and Sheet U1;
however, it does not address the Vegetation Management Plan Report by Arboricultural
Consulting nor Sheets 1 and 2 of the vegetation management plan sheets. Additionally, the
letter does not address compliance of all reviewed materials with the critical areas code
requirements of ECDC 23.40 and 23.80. Please provide S&EE with the Vegetation
Management Plan Report by Arboricultural Consulting as well as Sheets 1 and 2 of the
vegetation management plan sheets, and request that S&EE write an addendum to their
letter addressing these materials and if these materials and the civil plans are consistent
with the requirements of ECDC 23.40 and 23.80 in order to ensure that the work to be
conducted will not compromise the stability of the slopes on or adjacent to the site. Also,
any civil sheets that have been revised since the initial sheets dated 6/2/10 that were
provided to S&EE for review should also be provided to S&EE and addressed in the
addendum by S&EE.
3.The vegetation management plan by Arboricultural Consulting will need to be revised as
follows:
a.1/12/10 Comment - Item 8 on Page 6 of the plan states that supplemental
irrigation should be provided. How do you plan to provide this irrigation?
Item #9 on Page 7 of the Vegetation Management Plan Report by Arboricultural
Consulting states that supplemental irrigation should be provided for each of the
plants through the first growing season (April to September), and that this
irrigation should be provided at consistent and regular intervals either with an
overhead sprinkler or drip emitters or soaker hoses. In order to minimize
disturbance to the slope, an above ground temporary sprinkler system is
recommended as opposed to a below ground system. Please add a note to the
vegetation management plan sheets stating that irrigation will be provided
through the first growing season as recommended on Page 7 of the report by
Arboricultural Consulting. Additionally, please contact the Public Works
Department to obtain the proper permits for the irrigation system (even if only a
temporary system) prior to installation of the system.
b.1/12/10 Comment - Item 5 on Page 7 (now Item 5 on Page 9 of the updated
report) of the plan states that the NGPA should be monitored for hazardous
trees. What are the recommendations for removal and replacement for any such
trees in the future?
Item 5 on Page 9 of the Vegetation Management Plan Report by Arboricultural
Consulting states that monitoring should be conducted yearly for any hazardous
situations, and that any trees that need to be removed should be reported to the
City. However, the report does not provide direction on replacement of any trees
removed from the NGPA. The report should be updated to state that replacement
of any trees removed from the NGPA shall be per City of Edmonds tree cutting
code and critical areas regulations, or as amended, and as approved by the City.
c.There appears to be a mathematical error in the last paragraph on Page 3 of the
Vegetation Management Plan Report, as the total number of trees, number of
trees to be removed, and number of trees to be retained do not add up. Please
have Arboricultural Consulting LLC correct this error.
4.1/12/10 Comment - The plans indicate removal of several existing trees located outside of
the NGPA area. It is understood that many trees will need to be removed for development
of the new lots; however, it appears that trees beyond the footprint of development are
planned for removal. Although these trees are not located within the NGPA, the critical
areas and tree cutting codes (ECDC 18.45, 23.40, and 23.80) call for the retention of trees
that are not hazardous or in the path of development when located on and/or adjacent to
Landslide Hazard Areas.
Thank you for revising the plans to cut much fewer trees than originally proposed. It was
noted, however, that approximately six trees located to the west of the existing residence on
Lot 4 are now proposed to be removed when they were originally proposed to be retained.
Please describe why these trees are now proposed for removal. Note that tree removal in
this area must be consistent with the critical areas and tree cutting codes (ECDC 18.45,
23.40, and 23.80).
5.1/12/10 Comment - Your plans indicate that you wish to remove the trees located within the
future building areas; however, these existing trees are providing stability to the steep
slope. Do you have plans for temporary erosion control of these areas until the homes are
constructed? Or, are you planning to wait until building permit approval to remove these
trees? Do you have plans for long-term erosion control of these areas if the trees are
removed and the lots are not immediately developed? Please have your geotechnical
engineer provide recommendations for temporary and long-term erosion control of these
areas.
It was noted that the report by S&EE dated 9/28/07 provides direction for temporary
erosion control during construction and also specifies that “all permanent slopes should be
seeded with the appropriate species of vegetation to reduce erosion and maintain the slope
stability;” however, the S&EE report does not specify what is appropriate. Additionally,
the Vegetation Management Plan Report provides direction for tree removal throughout the
site as well as the replanting that is to be done within the NGPA; however, no direction is
provided within this report for what should be done if trees are removed at this time from
the proposed building footprints, but if the new homes are not constructed within the near
future. It is reasonable to remove the trees within the path of the civil improvements, the
three specified trees within the NGPA, and any hazardous trees at this time, but it does not
seem necessary to remove the trees within the proposed building footprints until the time of
development of the houses on Lots 1 and 3. By removing the trees from the future building
footprints at this time, there is the potential for increased slope instability because the
existing trees provide much better erosion control than any temporary erosion control
measures, such as covering the areas with visqueen. Please provide valid reasoning for
needing to remove the trees within the future building sites at this time and
recommendations from S&EE on what to do for permanent erosion control in these areas if
homes are not developed within a reasonable timeline, or revise the plans to indicate that
these trees will be removed at the time of development of the future houses on Lots 1 and 3.
6.1/12/10 Comment - Your NGPA enhancement plan states that 33 trees will be planted;
however, the report by Arboricultural Consulting states that 22 trees will be planted.
Please correct this discrepancy.
The plant schedule on Sheet 2 of the Vegetation Management Plan indicates that 33 new
trees will be planted; however, Page 6 of the Vegetation Management Plan Report only
specifies that the three red alders that are to be removed from the NGPA must be replaced
at a 3:1 ratio, which would be 9 new trees. In order to make these documents consistent,
the Vegetation Management Plan Report must be updated to state that an additional 24
trees for a total of 33 new trees will be planted within the NGPA as specified on Sheet 2 of
the Vegetation Management Plan.
7.As stated in Jeanie McConnell’s comments sent on 12/22/09 and 7/16/10, SEPA review is
required since the grading quantities for the subdivision improvements exceed 500 cubic
yards. Please submit an environmental checklist, notarized adjacent property owners
(APO) list, and $485 payment to the Planning Division at your earliest convenience so that
SEPA review can be conducted. Please contact me if you have any questions on the
submittal requirements for SEPA review.
8.As stated in Jeanie McConnell’s comments sent on 12/22/09 (Comment #1 for Sheet N1),
utility lines and easements should be minimally located within the NGPA. I have reviewed
your response that the sewer, storm, and utilities have been designed to minimize impacts
to the NGPA area and existing trees. However, since there will be utility lines/easements
within the NGPA, language should be added to the Vegetation Management Plan Report
and plan sheets stating that if any plants must be disturbed for utility work, a replanting
plan will need to be approved by the City and offering any recommendations for what the
replanting should include.
9.It appears that the labels of Zones 1 and 2 are switched on Sheet 2 of the Vegetation
Management Plan. Please make sure the labels of these zones on Sheet 2 are consistent
with the descriptions in the report by Arboricultural Consulting. If this is the only change
to Sheet 2, this item can be redlined on the plans.
10.The preliminary plans for the subdivision indicated that the portion of the existing shed that
projects onto the northeast corner of Lot 1 was to be removed. As such, and because an
accessory structure cannot be located on a lot without a primary structure, a condition of
preliminary approval was placed on the subdivision (Condition 1.c) stating that the portion
of the shed that encroaches onto Lot 1 shall be removed. However, it was noted that your
revised plans show a five-foot building easement on Lot 1 to benefit the lot to the north. A
building easement cannot be utilized to solve an encroachment issue, and no buildings can
be located within an NGPA. Thus, this note will need to be removed from the civil plans,
and the portion of the shed that encroaches onto Lot 1 will need to be removed prior to final
approval and recording of the subdivision.
11.Pursuant to ECDC 23.40.290, a performance bond and/or a three-year maintenance bond
will be necessary to ensure maintenance of the new plantings within the NGPA. In order to
determine the amount of the bond(s), a cost estimate and/or bill from the landscaping
company (covering all new plants, labor, and taxes) will be required. This item is not
required for civil approval, but will be required before the Planning Division can issue final
approval of the civil work.
Please submit your responses to the above items with the resubmittal of your civil plans to the
Engineering Division, Monday through Friday, 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
Jen Machuga
Planner
Cc: Jesse Jarrell
Email: jessej@westernengineers.com
Jeanie McConnell, Engineering Program Manager