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Hard File ScannedOFFICE OF THE HEARING EXAMINER CITY OF YELM REPORT AND DECISION CASE NO.: BSP-05-0197-YL and SPR-05-0160-YL APPEAL OF MITIGATED DETERMINATION OF NONSIGNIFICANCE BSP-05-0197-YL APPLICANT/ APPELLANT: 3B&C, LLC P.O. Box 875 Yelm, WA 98597 SUMMARY OF REQUEST: The applicant is requesting approval to create 6 commercial building sites through the binding site plan process, and to construct a 5,600 square foot commercial building on one of the building sites. The site encompasses 2 parcels. There are existing residences on the site that will be demolished. SUMMARY OF APPEAL: The appellant is appealing the mitigation measures attached to a Mitigated Determination of Nonsignificance for a proposed binding site plan to create commercial spaces for and site plan review to construct a 5,600 square foot commercial building. SUMMARY OF DECISION: Request granted. Appeal denied. PUBLIC HEARING: After reviewing Planning and Community Development Staff Report and examining available information on file with the application, the Examiner conducted a public hearing on the request as follows: The hearing was opened on November 7, 2005. Parties wishing to testify were sworn in by the Examiner. -1- The following exhibits were submitted and made a part of the record as follows: EXHIBIT "1" - Planning and Community Development Staff Report and Attachments EXHIBIT " 2" - Submittal from the City EXHIBIT " 3" - Map EXHIBIT "4" - Map EXHIBIT "5" - Map EXHIBIT "6" - Document from Washington State Department of Ecology EXHIBIT "7" - Responses to Mitigation Measures TAMI MERRIMAN appeared, presented the Planning and Community Development Department Staff Report addressing the binding site plan, and testified that the site is located at the intersection of West Road and 103rd. The applicant filed an environmental appeal because it wants to use alternate technology for stormwater due to the location of Yelm Creek and the high groundwater table. The site plan shows the buildings proposed on the west side of the internal plat road. The development will require the demolition of the existing residence, and wetlands are more than 200 feet away. The City will evaluate each building in accordance with the design guidelines as it is proposed. Conditions require landscaping and corner enhancement. GRANT BECK appeared and presented the findings and conclusions of the responsible official on the environmental appeal and testified that mitigating measures were imposed pursuant to SEPA review on stormwater drainage impacts because of high groundwater. The City did not accept alternate technology, but required the bottom of the pond to have an elevation of six feet above groundwater. The pond must also accommodate road frontage stormwater. The appellant cited three reasons for the appeal: 1. The City didn't identify the groundwater protection in the presubmittal hearing; 2. The requirements are beyond the minimum regulations of the City; 3. The proposed vortex system is used elsewhere and accepted. He determined that all of the issues fail and that the MDNS should be approved. Concerning presubmittal, it is true that the City did not identify the additional protection, but these are pre-meeting conferences and pre-review conferences. The Examiner has previously ruled on this issue. The City is requiring the same condition as it did in the Wal-Mart MDNS. The high groundwater is an emergent issue. We have the same groundwater issue and the same condition attached. The high groundwater did not emerge as an issue until after formal submittal. SEPA review fills in gaps left by legislation. At the time of review the Critical Areas Ordinance had not been updated, but now it is included within the code. The ordinance would require the additional protection if the applicant submitted the site plan today. At the time of submittal a gap existed in the City ordinances. Review is based on Thurston County regulations and the Salmon Creek Interim Regulations. Condition 3B refers to an elevation of 335 feet, but such is not a regulation. It is an attempt to help the applicant determine the groundwater. The flood elevation must be determined. The aerial photograph determined the high groundwater and the applicant must install the system six feet above the map elevation which results in -2- the 335 foot guideline. Measure 3C requires separate water infiltration. No capacity exists for additional stormwater from the road in the development across West Road. Concerning approved alternate systems, DOE allows alternate systems under stringent conditions and the City has allowed such systems where they are very large and where there is financial backing, reporting, and maintenance. The school has the same system the applicant desires, but meets the requirements of the City. These types of systems are not appropriate in a binding site plan where lots can be owned by various businesses or as an association. Concerning the policy background, he reviewed past projects and the condition has a scientific background as the entire City has been identified as an aquifer recharge area. A policy of the old Critical Areas Ordinance requires treatment of projects located on a critical aquifer. Emergent technology is not listed in the 1992 DOE Manual adopted by the City. ROBERT TAUSCHER, professional engineer, appeared and introduced Exhibit "5", a confirmation that wetlands do not exist on the property. Concerning emergent technology policy, the DOE web page shows approval under the general use level. Concerning vortex, he can't see an extra reporting requirement to DOE which produced Exhibit "6" which defines the criteria of the system. He designed the engineering for the school and DOE required no additional reporting. Maintenance of the system requires a vactor truck and a condition could require a contract with a provider. Also, vortex itself provides maintenance. The maintenance must occur about every four months. The maintenance is site specific and a program is set up for each site. The only cost is that of the vactor truck. The roof runoff can be taken and directed to the infiltration galleries. It can stay out of the treatment element. An alternative is a swale, but such would reduce the number of buildings. Another alternative is a wet pond which would also cause the loss of a lot. A ground cartridge unit is also an alternative, but it requires the same maintenance. ERLING BIRKLAND appeared and testified that he has no questions or concerns with the staff report except for the storm drainage issue. In many jurisdictions they can provide a bond to ensure maintenance of the system. They can accommodate these requirements. The City needs to address other technology then dumping water in a hole. MR. BECK reappeared and testified that other options do exist such as a wet pond above or below ground. Wet ponds below ground do not consume surface areas. The vortex raises the elevation of the storm drainage as the City desires. The applicant can provide over winter monitoring to provide assurance of the groundwater level. MR. TAUSCHER reappeared to introduce Exhibit "7" addressing the Salmon Creek requirements. Other options do exist, but they are trying to keep the cost of development down. They looked at the best cost effective method. Other jurisdictions accept their proposed method. The Examiner then left the record open to November 22, 2005, for the applicant and the City to further discuss the SEPA issues and for the City to respond to the applicant's submittals. No one spoke further in this matter and the hearing was concluded. -3- NOTE: A complete record of this hearing is available in the City of Yelm Community Development Department FINDINGS, CONCLUSIONS AND DECISION: FINDINGS: The Hearing Examiner has admitted documentary evidence into the record, heard testimony, and taken this matter under advisement. 2. Notice of the date and time of the public hearing was posted on the site, mailed to owners of property within 300 feet of the project site, and mailed to the recipients of the Notice of Application and SEPA Determination on October 24, 2005. Notice of the date and time of public hearing was published in the Nisqually Valley News in the legal notice section on October 21, 2005. 3. The City of Yelm Responsible Official issued a Mitigated Determination of Nonsignificance on August 12, 2005. An appeal was filed. 4. The applicant has a possessory ownership interest in a rectangular, five acre parcel of property located at the northeast corner of the intersection of West Road SE and NE 103`d Avenue within the City of Yelm. The parcel abuts West Road for430 linear feet and varies in depth between 577 and 474 feet. The southern tip of the parcel touches NE 103rd Avenue. The applicant requests binding site plan approval to allow creation of six commercial building pads and site plan approval for one, 5,600 square foot structure. 5. Improvements on the site include two single family residential dwellings and accessory outbuildings, all of which will be removed. The site plan shows access provided via a single road extending northeast from West Road and terminating in a cul-de-sac near the north property line. Three building pads and associated parking areas are located on each side of the internal road. The site plan shows Type 3 landscaping along the West Road frontage and Type 2 landscaping along the balance of the perimeter. A portion of the northeastern property line extends closer than 200 feet from the centerline of Yelm Creek, but no improvements are planned for said area. The area within the shoreline jurisdiction will consist of Type 2 landscaping. 6. The site is located within the Commercial (C1) zone classification of the Yelm Municipal Code (YMC). Section 17.26.010 YMC provides that the purpose of the C1 classification is to identify appropriate areas for the location of business centers to serve the needs of the community for convenience goods and services such as food, drugs, household supplies, automobile servicing and other related uses. -4- Section 17.26.030 YMC sets forth 69 uses allowed outright in the C1 classification. 7. Section 17.26.060 YMC requires for the C1 classification a minimum parcel size of 5,000 square feet and setbacks from side property lines of ten feet, rear property lines of 20 feet, and front property lines of 15 feet. Section 17.26.090 YMC limits the height of buildings to 40 feet and Section 17.26.110 YMC sets forth off-street parking requirements. The site plan will comply with all bulk regulations of the C1 classification. 8. All abutting parcels are located within the C1 classification; and parcels to the south across 103~d Avenue and to the east along 103~d Avenue are improved with commercial uses. The abutting parcel to the west is improved with a single family residential dwelling. Improvement of the site as proposed fits well with the existing commercial uses and future uses as contemplated by the comprehensive plan and development regulations. 9. Conditions of approval require the applicant to improve the street frontage of West Road SE to a commercial collector standard which requires an 11 foot wide travel lane, five foot wide paved shoulder, vertical curb, planter strip with street trees, a five foot wide sidewalk, and streetlighting. The applicant must also pay the transportation facility charge of $750.00 per new p.m. peak hour trip and meet the parking requirements set forth in Chapter 17.72 YMC. Compliance with said conditions will ensure that the plat makes appropriate provision for streets, roads, alleys, and other public ways. 10. The City of Yelm will provide both domestic water and fire flow as well as sanitary sewer service to the site. The applicant must pay the connection fee for both water and sewer. 11. The northeast corner of the site extends approximately 20 feet into the shoreline jurisdiction of Yelm Creek, but no development will occur therein. Wetlands associated with Yelm Creek measure more than 200 feet from the property line, and therefore the site meets all buffer requirements for the creek and associated wetlands. 12. The applicant must comply with all landscaping and screening requirements set forth in Chapter 17.80 YMC to include perimeter landscaping and landscaping necessary to provide visual relief and shade in parking areas. At the time of civil plan review the applicant must present a detailed final landscape and irrigation plan for approval. 13. The Yelm Design Guidelines place the site in a Mixed Use District. Design guidelines require a development to define the street edge with building, landscaping, or other features and to provide direct access to the building from the frontage. Larger developments must increase pedestrian and vehicular circulation, -5- reduce negative impacts to adjacent properties, and upgrade the overall visual quality of the City. Street corners require substantial landscaping, a decorative screen wall, pedestrian access, and architectural cover treatments. The site plan does not presently provide for enhancing the corner of West Road and 103ra Avenue, but must do so prior to final approval. The applicant proposes to landscape around the west, north, and east property lines. Sidewalks circulate through the site and from West Road SE into the site, and pedestrian access exists to all building pads. The pedestrian circulation and building design and details must meet all criteria set forth on pages 8-10 of the staff report. Compliance with code requirements will ensure that the site plan review for the first building satisfies all criteria set forth in Section 17.84.020(C) YMC. 14. Prior to obtaining binding site plan approval the applicant must establish that the request satisfies the criteria set forth in Section 16.32.065 YMC. Findings on each criteria are hereby made as follows: A. The site plan shows areas in the southern corner and along the northeast property line retained in open space and perimeter landscaping along all four property lines. Taxes will support parks and recreation, playgrounds, schools and school grounds. As found hereinafter, constructing the storm drainage system in accordance with the requirements of the SEPA mitigating measures will ensure that the binding site plan makes appropriate provision for drainage ways. Required improvements to streets, the payment of the transportation facility charge, and the connection to public water and sewer will ensure that the binding site plan makes appropriate provision for streets, roads, alleys, other public ways, potable water supplies, and sanitary waste. The sidewalks circulating through the site and from West Road will ensure safe walking conditions and a safe location for a transit stop if desired in the future. B. The binding site plan will serve the public use and interest by providing an attractive location for a commercial use consistent with the zoning and comprehensive plan designation as well as surrounding uses. C. Public facilities impacted by the businesses are adequate and available. D. As previously found, the City will provide sanitary sewer service for the project as well as water service. SEPA APPEAL 15. On August 12, 2005, the City Responsible Official (RO) issued a Mitigated Determination of Nonsignificance following review pursuant to the State Environmental Policy Act (SEPA). On September 2, 2005, Erling Birkland on behalf of 3B&C LLC (appellant) timely filed an environmental appeal challenging mitigating -6- measure no. 3 which reads as follows: 3. Civil plan submission shall include an updated preliminary stormwater plan that meets or exceeds the standards of the 1992 stormwater Manual as adopted by the City of Yelm. The stormwater plan shall include the following elements: a. Alternative technologies are not accepted. b. The elevation of the bottom of the infiltration gallery shall be a minimum of six feet above the elevation of the high groundwater area as identified by Thurston County (approximate elevation 335), and must be 50 feet horizontally, or 2 feet vertically away from the High Ground water area, which ever distance is less. c. Separate water quality treatment for roof runoff shall be provided. d. The stormwater system shall be designed to accommodate stormwater generated by required frontage improvements. 16. The appellant desires to use an alternative technology for the treatment of stormwater prior to infiltration. The appellant proposes a vortechnics unit manufactured by stormwater 360, Inc. which it asserts meets or exceeds many of the traditional means of removing pollutants. The appellant further asserts that the City has allowed the vortechnics unit in recently constructed schools. However, according to the RO, the City has rarely allowed the use of emerging stormwater treatment technology systems such as the vortechnics unit within the City. The City has allowed Yelm Community Schools to use such technologies because the district has the maintenance staff and financial resources to maintain the system and complete status reports. In the present case, the applicant proposes a relatively small, five acre project which will through the binding site plan process have six different owners of different sections of the parcel. A condominium type ownership is not appropriate to test emerging technologies, especially considering that the site is located atop a critical aquifer. 17. Concerning Mitigating Measure No. 3(b) the appellant asserts that the City did not disclose the required 335 foot groundwater elevation during the presubmission conference. Section 17.84.050 YMC entitled "Preliminary Site Plan" provides: Prior to applying for site plan review, a developer may file with the SPRC (Site Plan Review Committee) a summary site plan, which shall contain in a rough and approximate manner all of the information required in the site plan application. The purpose of a summary plan is to enable a developer filing the plan to obtain the -~- comments of the SPRC as to the applicability of the intent, standards and provisions of this chapter to the plan. Section 17.84.020(C) YMC requires the SPRC to review a site plan as follows: C. The SPRC shall review a site plan and approve, or approve with conditions, site plans which conform to the standards, provisions and policies, of the site as expressed in its various adopted plans including the applicable sections of the shoreline master program for the Thurston region.... The YMC does not contemplate that the presubmission review requires the City to identify all standards, provisions, and policies which will apply to a proposed plan. According to Section 17.84.050 YMC, the applicant need only provide a "summary site plan" which contains "in a rough and approximate manner all of the information required in a site plan application". The notes from the preapplication meeting specifically advise an applicant of that fact: These comments are preliminary in nature and not intended to represent final comments and/or requirements for the City of Yelm. Until a complete application is made, the Community Development Department can only attempt to inform the applicant of general requirements as they appear in the form presented by the applicant at the time of submission. Thus, lack of disclosure of the 335 foot elevation during the presubmission conference does not prohibit its imposition. 18. In its appeal the appellant questions how the City determined the 335 foot elevation and what datum it used to derive the elevation. The appeal notes that the 1992 DOE Stormwater Manual adopted by the City requires three feet of separation between the bottom of an infiltration facility and the seasonal high groundwater. The appellant also notes that the City has not formally adopted the Salmon Creek standards which require six feet of separation within the Yelm Creek area. However, the City has identified high groundwater in the area and has also determined that a minimum of six feet of separation is required between the bottom of an infiltration facility and said high groundwater table to provide adequate protection for the critical aquifer. The City Critical Areas Ordinance, amended subsequent to the filing of a completed application, now requires the six foot separation. The City also required the same six foot separation for the Wal-Mart Supercenter site. While Mitigating Measure 3(b) refers to an elevation of 335 feet such elevation is not a standard or regulation, but an attempt to assist the applicant in determining the height of the groundwater. The applicant must determine the flood elevation and install the system six feet above said system which results in the 335 foot estimate. -s- 19. According to RCW 43.21 C.060, a portion of the SEPA statute, SEPA supplements existing authority of all governmental agencies and allows decisionmakers to go beyond their traditional criteria (ordinances) and exercise SEPA given authority to make land use decisions based upon environmental considerations. The RO in evaluating the environmental impacts of the binding site plan application determined that existing ordinances did not provide adequate environmental protection for the groundwater due to an elevated winter water table, and therefore imposed a greater standard than required by ordinance pursuant to SEPA authority. 20. Our Courts have explained the purpose of SEPA review as follows: SEPA is a procedural statute designed to ensure that local governments consider the environmental and ecological effects of major actions to the fullest extent. SEPA's purpose is to provide decisionmakers with all relevant information about the potential environmental consequences of their actions and to provide a basis for a reasoned judgment that balances the benefits of a proposed project against its potential adverse effects. Des Moines v. Puget Sound Regional Council, 98 Wn. App 23 at 36; (1999). In fulfilling its responsibilities under SEPA, the RO reviews the environmental checklist and supporting documents and issues a threshold determination as to whether any probable significant adverse environmental impacts will result from the proposed development. Before requiring mitigating measures the RO must first consider whether the development regulations of local, state, or federal jurisdictions and enforcement thereof would mitigate an identified significant impact (WAC 197- 11-330; 197-11-660). The RO followed these procedures in issuing the MDNS in the present case, but found that existing City storm drainage standards would not provide sufficient aquifer protection. The RO therefore imposed mitigating measures pursuant to SEPA authority requiring the six foot vertical clearance standard. Thus, the RO has authority to impose the Salmon Creek standards even though not adopted by the Yelm City Council to mitigate a probable significant adverse environmental impact. 21. The appellant asserts that the drainage manual does not require the treatment of roof runoff prior to infiltration and questions the adoption of such standards by the City. The appellant also questions measure 3(d) which requires the stormwater system to accommodate stormwater generated by required frontage improvements on West Road based upon the existence of a stormwater collection system within West Road. The RO imposed these measures because no capacity exists for additional stormwater in the development on the southeast side of West Road. These issues can be resolved through providing additional capacity for existing systems or providing capacity on or off site. The appellant must accommodate stormwater generated by frontage improvements. -9- 22. RCW 43.21 C.075 entitled "Appeals" provides that where an agency authorizes an environmental appeal under SEPA as does the City, the agency: (d) Shall provide that procedural determinations made by the responsible official shall be entitled to substantial weight. Our Washington Supreme Court interpreted the "substantial weight" requirement in Wenatchee Sportsman v. Chelan County, 141 Wn. 2d 169 (2000), as follows: A decision to issue an MDNS may be reviewed under the clearly erroneous standard...A finding is clearly erroneous when, although there is evidence to support it, the reviewing court on the record is left with the definite and firm conviction that a mistake has been committed... For the MDNS to survive judicial scrutiny, the record must demonstrate that environmental factors were considered in a manner sufficient to amount to prima facia compliance with the procedural requirements of SEPA and that the decision to issue an MDNS was based on information sufficient to evaluate the proposal's environmental impact. 141 Wn. 2d 169 at 176. The Examiner is not left "with the definite and firm conviction that a mistake has been committed", especially considering adoption of the required standards by the new critical areas ordinance. Applying the "substantial weight" criteria, the City's environmental analysis provides sufficient information to identify the proposal's probable significant environmental impacts, and the MDNS adequately mitigates said impacts to less than substantial. CONCLUSIONS: The Hearing Examiner has jurisdiction to consider and decide the issues presented by this request. 2. The applicant has established that the request for binding site plan approval and site plan review approval satisfies all criteria set forth in the Yelm Municipal Code. 3. The appellant has not shown that the responsible official was clearly erroneous in the issuance of the MDNS and in the imposition of Mitigating Measure No. 3. The environmental appeal should therefore be denied. 4. The request for binding site plan approval and site plan review approval should be granted subject to the following conditions: The conditions of the Mitigated Determination of Non-significance are hereby referenced and are considered conditions of this approval. -lo- 2. Parking shall be provided in accordance with the City of Yelm Development Guideline standards based on one space for every 300 square feet of gross floor area. 3. The applicant shall connect to the City water system. The cost to connect shall include a fee of $1,500.00 per Equivalent Residential Unit (900 cubic feet per month), subject to change. The number of ERU's will be calculated on water usage based on engineers calculations. 4. The civil plan submission shall include fire flow calculations and demonstrate that the fire flow requirements of the International Fire Code have been met at the site. The civil plan submission shall include a fire access plan showing all required fire lanes and a striping plan for fire lanes. All fire hydrants installed as part of the development shall include hydrant locks approved by the Development Review Engineer and the Public Works Director. 5 . The applicant shall connect to the City S.T.E.P. sewer system. The cost to connect shall include a fee of $5,417.00 per ERU with a $145.00 inspection fee per connection, subject to change. The number of ERUs required will be determined by approved water consumption calculations submitted as part of the civil plans. Sewer connection fees are paid at building permit issuance. Approved grease interceptors or oil interceptors shall be provided on all side sewers serving areas which include the potential for introduction of oils and greases into the sewer system. All S.T.E.P. tanks shall be designed to the specifications of the City of Yelm Development Guidelines, including a maximum depth to the tank invert of 6 feet below finish grade. 6. Upon completion of the onsite installation pursuant to the City's Development Guidelines, the S.T.E.P. sewer equipment, appurtenances and lines shall be conveyed to the City, and an easement provided for maintenance. 7. The applicant shall design and construct all stormwater facilities in accordance with the conditions of the Mitigated Determination of Non- significance. A final stormwater report shall be included in the civil plan submission. -11- 8. The civil plans shall include a complete detailed landscape plan in accordance with Chapter 17.80 YMC, including provisions for irrigation and for maintenance of landscaping. 9. Landscaping is required. o Type II landscaping is required along the perimeter property lines and adjacent to buildings. o Type III landscaping is required with all frontage improvements. o Type IV landscaping is required in all parking areas. o Type V landscaping is required in all above ground stormwater facilities. 10. Building elevations shall be consistent with the Yelm Design Guidelines for the mixed use district. 11. The corner of West Road and 103rd Avenue shall include corner enhancements consistent with the Design Guidelines for the mixed use district that include the following elements: o Landscaping enhancements o A structural element designed to enhance the intersection and create an attractive entry. o The landscaping plan shall include the plan for corner enhancement. 12. Refuse collection and trash compaction areas shall be designed to contain all refuse generated on site and deposited between collections. Deposited refuse shall not be visible from outside the refuse enclosure. Screening shall be of a material and design compatible with the overall architectural theme of the associated structure, shall be at least as high as the refuse container, and shall in no case be less than six-feet in height with a gate enclosure. The fence shall be a solid material such as wood or masonry, and shall be designed per the City of Yelm Development guidelines. Building plans shall include architectural details of the enclosure. DECISION: The request for site plan approval to allow creation of six commercial building pads and site plan approval fora 5,600 square foot commercial building at a site located at the northeast corner of West Road SE and 103rd Avenue SE within the City of Yelm is hereby granted subject to the conditions contained in the conclusions above. The environmental appeal challenging the imposition of Mitigating Measure No. 3 in the MDNS is hereby denied. ORDERED this 22"d day of December, 2005. -12- STEPHEN K. CAUSSEAUX, JR. Hearing Examiner TRANSMITTED this 22"d day of December, 2005, to the following: APPELLANT: 3B&C, LLC Erling Kirkland P.O. Box 875 Yelm, WA 98597 OTHERS: Robert Tauscher Jerome W. Morrissette 1700 Cooper Point Road SW Olympia, WA 98501 City of Yelm Tami Merriman 105 Yelm Avenue West P.O. Box 479 Yelm, Washington 98597 -13- CASE NO.: BSP-05-0197-YL and SPR-05-0160-YL WEST COMMERCIAL ROAD NOTICE 1. RECONSIDERATION: Any interested party or agency of record, oral or written, that disagrees with the decision of the hearing examiner may make a written request for reconsideration by the hearing examiner. Said request shall set forth specific errors relating to: A. Erroneous procedures; B. Errors of law objected to at the public hearing by the person requesting reconsideration; C. Incomplete record; D. An error in interpreting the comprehensive plan or other relevant material; or E. Newly discovered material evidence which was not available at the time of the hearing. The term "new evidence" shall mean only evidence discovered after the hearing held by the hearing examiner and shall not include evidence which was available or which could reasonably have been available and simply not presented at the hearing forwhatever reason. The request must be filed no later than 4:30 p.m. on January 4, 2006 (10 days from mailing) with the Community Development Department 105 Yelm Avenue West, Yelm, WA 98597. This request shall set forth the bases for reconsideration as limited by the above. The hearing examiner shall review said request in light of the record and take such further action as he deems proper. The hearing examiner may request further information which -14- shall be provided within 10 days of the request. 2. APPEAL OF EXAMINER'S DECISION: The final decision by the Examiner may be appealed to the city council, by any aggrieved person or agency of record, oral or written that disagrees with the decision of the hearing examiner, except threshold determinations (YMC 15.49.160) in accordance with Section 2.26.150 of the Yelm Municipal Code (YMC). NOTE: In an effort to avoid confusion at the time of filing a request for reconsideration, please attach this page to the request for reconsideration. -15- ~,~~ Tip City of Yelm ~~ Community Development Department 105 Yelm Avenue West P.O. Box 479 YELM Yelm, WA 98597 WASHINGTON NOTICE OF PUBLIC HEARING YELM HEARING EXAMINER DATE: Monday, November 7, 2005, 9:00 A.M. PLACE: City Council Chambers, City Hall 105 Yelm Ave West Yelm, Washington PURPOSE: Public Hearing to receive comments regarding the following applications: Case Number SUB-05-0239-YL & SHO-05-0240-YL (Yelm Creek Estates). A proposal by Rainier General Development to subdivide 5.6 acres into 23 residential lots on property located west of Crystal Springs Road, and adjacent to Yelm Creek on assessor parcel numbers 22718330102 & 22718330304. Case Number SUB-05-0257-YL (Golf Course View Estates). A proposal by Rainier General Development to subdivide 2.16 acres into 10 residential lots on property located on Longmire St. on assessor parcel number 21724420700. Case Number BSP-05-0197-YL & SPR-05-0160-YL (West Road Commercial). A proposal by 3B&C LLC to create building pads for future commercial development, and Site Plan Approval fora 5,600 sq.ft. commercial building on assessor parcel numbers 64303601701 and 64303601702. Case Number APP-05-0197-YL (Appeal of MDNS Conditions). Public Meeting to hear testimony from parties of record, regarding an appeal of certain conditions of the Mitigated Determination of Nonsignificance issued for West Road Commercial binding site plan case number BSP-05-0197-YL. The City of Yelm Hearing Examiner will hold a public hearing to receive comments on the proposals. The Hearing Examiner will make a decision on the matter within 10 days after the hearing. Testimony may be given at the hearings or through any written comments. Comments must be received by the close of the public hearing. Such written comments may be submitted to the City of Yelm at the address shown above or mailed to: City of Yelm, PO Box 479, Yelm WA 98597. Any related documents are available for public review during normal business hours at the City of Yelm, 105 Yelm Ave W., Yelm, WA. For additional information, please contact Tami Merriman at (360) 458-3835. The City of Yelm provides reasonable accommodations to persons with disabilities. If you need special accommodations to attend or participate in this hearing, call the City Clerk, Agnes Bennick, at (360) 458-8404, at least 4 days before the meeting. ATTEST: City of Yelm Agnes Bennick, City Clerk DO NOT PUBLISH BELOW THIS LINE Published in the Nisqually Valley News: Friday, October 21, 2005. Posted in Public Areas: Wednesday, October 19, 2005. o~ WAfNINOTOM Staff Report City of Yelm Community Development Department To: Stephen K. Causseaux, Jr., Hearing Examiner From: Grant Beck, Director of Community Development Date: October 17, 2005 Subject: Appeal of Mitigated Determination of Non-Significance BSP-05-0197-YL Appellant: 3B&C, LLC Location: 10336 West Road SE, Yelm, WA. Proposal: Appeal Mitigation Measure 3(a, b, c, & d) of the MDNS issued for the proposed West Road Professional Park. I. INTRODUCTION Erling Birkland, 3B&C LLC appeals mitigation measures attached to a Mitigated Determination of Non-significance for a proposed binding site plan to create commercial spaces for and site plan review to construct a 5,600 square foot commercial building. II. BACKGROUND 3B&C LLC has applied for a binding site plan and site plan review to create a professional business park on West Road in the City of Yelm. The City of Yelm reviewed the SEPA checklist and issued an MDNS on August 12, 2005. The MDNS included the following mitigating measures being appealed: 3. Civil plan submission shall include an updated preliminary stormwater plan that meets or exceeds the standards in the 1992 stormwater Manual as adopted by the City of Yelm. The stormwater plan shall include the following elements: a. Alternative technologies are not accepted. b. The elevation of the bottom of the infiltration gallery shall be a minimum of six feet above the elevation of the high groundwater area as identified by Thurston County (approximate elevation 335), and must be 50 feet horizontally, or 2 feet vertically away from the High Ground water area, which ever distance is less. c. Separate water quality treatment for roof runoff shall be provided. d. The stormwater system shall be designed to accommodate stormwater generated by required frontage improvements. III. ISSUES The applicant appealed the City's issuance of the Mitigated Determination, specifically conditions relating to the use of emerging stormwater treatment technologies and the requirement that the bottom of the infiltration gallery be no less than 6 feet above the high groundwater area. The basis for the appeal is that some of the conditions of the MDNS were not disclosed during the pre-submission meeting, that the Salmon Creek Standards have not been adopted by the City of Yelm, that that the proposed stormwater system design meets the 1992 stormwater Manual, and that the City has approved emerging stormwater treatment technologies in the past. IV. ANALYSIS The Yelm Municipal Code does not contemplate that the pre-submission review requires the City to identify all standards, provisions, and policies which will apply to the proposed plan. The Hearing Examiner previously found as part of the Rothwell appeal of the approval of a site plan review application (APL-03-8361-YL) that pre-submission notes are not binding. To reinforce this concept, it is the unbroken practice of the Community Development Department place at the top of all pre-submission comments the following language: These comments are preliminary in nature and are not intended to represent final comments and or requirements for the City of Yelm. Until a complete application is made, the Community Development Department can only attempt to inform the applicant of general requirements as they appear in the form presented by the applicant at the time of pre-submission. This note was included on both the Planning and Civil Engineering notes for the proposed business park. The State Environmental Policy Act does not limit the Responsible Official to adopted codes and regulations to mitigate potential environmental impacts. The appellant notes that the 1992 stormwater manual only requires three feet of vertical separation between the bottom of a infiltration gallery and groundwater and that the City has not adopted the Interim Site Development Standards for New Development in Salmon Creek Basin. Page 2 of 4 As noted in the findings of the MDNS, however, the City identified that the proposed development is located in a critical aquifer recharge area and adjacent to a potential high groundwater flooding area. If, during a high groundwater event, the groundwater elevation is higher than the required three feet of vertical separation as required by the 1992 stormwater Manual, the strong possibility exists of untreated stormwater entering the groundwater, which is also a critical aquifer recharge area. In order to mitigate this potential significant impact, the City looked to the standards in the Interim Site Development Standards for New Development in Salmon Creek Basin, adopted by Thurston County after high groundwater events in the mid 1990's. Adjacent to an area of known high groundwater, this document establishes a screening threshold for all development of 6 feet to known high groundwater. If the bottom of the infiltration gallery is less than 6 feet above groundwater, over winter monitoring and additional engineering analysis is required. If the bottom of the infiltration gallery is greater than 6 feet above groundwater, no other special standard need be met in order to protect the aquifer. In this instance, as with the updated Yelm Critical Areas Code, which was adopted by the City Council on September 28, 2005, the City chose to require the 6 feet of separation rather than having the project go through a years worth of ground water monitoring before designing the stormwater system. These conditions are reasonable and are designed to appropriately mitigate identified probable significant impacts to the environment. Allowing the use of emerging stormwater treatment technologies is discretionary on the part of the City and is not always appropriate. The appellant wishes to utilize a vortechs system by Stormwater360, Inc. as part of the stormwater quality treatment component at the site. As noted in the appeal, the City has rarely allowed an emerging stormwater treatment technology system to be used within the City. Also as noted in the appeal, one of the few entities that the City has allowed to utilize these technologies is Yelm Community Schools. The City approved the use of emerging technologies for the School District because the District has the maintenance staff and financial resources to maintain the system and complete status reports on the operation of the system pursuant to the General Use Designation issued by the Washington State Department of Ecology for the vortechs system. A small development such as the proposed business park, where the stormwater system is likely to be owned and maintained by a condominium owners association, is not the appropriate situation to test emerging stormwater technologies. Page 3 of 4 Certain clarifications to the Mitigated Determination of Non-significance to address questions raised by the appellant are appropriate. Condition 3b indicates that the groundwater elevation is approximately 335 feet. This elevation is approximate and was only cited in order to provide some indication of the groundwater elevation to the application. The key requirement is that the bottom of the infiltration gallery must be 6 feet above the high groundwater. The high groundwater area will be established by the appellants surveyor, most likely through the use of the high groundwater maps and aerial photographs of the high groundwater areas provided by Thurston County. Condition 3c requires separate water quality treatment for roof run-off. The intent of this condition is to separate the roof run-off, which is assumed to be clean pursuant to the 1992 stormwater Manual, be directed to a drywell and not through the stormwater system, in order to reduce the size of the stormwater system. Condition 3d requires the development to accommodate storm drainage from frontage improvements. There is no publicly owned stormwater system in the area of this proposed development. The system the appellant refers to as being available to direct stormwater from frontage improvements towards is a private system installed to accommodate stormwater treatment from that development. VI. CONCLUSION The Mitigated Determination of Non-significance should be upheld. LIST OF EXHIBITS Appeal Notice and Letter Mitigated Determination of Non-significance Hearing Examiner Decision - Rothwell Appeal Pre-submission notes -Civil Pre-submission notes -Planning Page 4 of 4 Mitigated Determination of Non-Significance File Number SPR-05-0160-YL and BSP-05-0197-YL Proponent: 3B&C LLC Description of Proposal: Binding Site Plan and Site Plan Review to provide commercial spaces for construction, and construction of 5,600 sq. ft. commercial building with associated parking. Location of the Proposal: 10336 West Road SE, Corner of West Road and 103`d Ave SE., Tax Parcel #'s 64303601701 & 46303601702. Section/Township/Range: Section 19, Township 17 North, Range 2 East, W.M. Threshold Determination: The City of Yelm as lead agency for this action has determined that this proposal does not have a probable significant adverse impact on the environment. Therefore, an Environmental Impact Statement (EIS) will not be required under Section 43.21 C.030 (2)(c) RCW. This decision was made after review of a completed environmental checklist and other information on file with the lead agency. This information is available to the public on request. Conditions/Mitigating Measures: See Attachment A Lead agency: City of Yelm Responsible Official: Grant Beck, Community Development Director Date of Issue: August 12, 2005 Co adline: August 26, 2005 App I Deb `, •/3eptember 2, 2005 Grant Beck, Community Development Director This, Mitigated Determination of Non-Significance (MDNS) is issued pursuant to Section 197-11-340 (2) WAC. Comments must be submitted to Grant Beck, Community Development Department, at City of Yelm, 105 Yelm Avenue West, P.O. Box 479, Yelm, WA 98597, by August 26, 2005, at 5:00 P.M. The City of Yelm will not act on this proposal prior to September 2, 2005, at 5:00 P.M. You may appeal this determination to the Yelm Hearing Examiner, at above address, by submitting a written appeal no later than September 2, 2005 at 5:00 P.M. You should be prepared to make specific factual objections. Contact Grant Beck, Community Development Director, to learn more about the procedures for SEPA appeals. This MDNS is not a permit and does not by itself constitute project approval. The applicant must comply with all applicable requirements of the City of Yelm prior to receiving construction permits which may include but are not limited to the City of Yelm Comprehensive Plan, Zoning Code (Title 17 YMC), Critical Areas Code (Chapter 14.08 YMC), Stormwater Drainage Design and Erosion Control Manual, International Building Code, Critical Areas Regulations (Title 14 YMC), Road Design Standards, Platting and Subdivision Code (Title 16 YMC), and the Shoreline Master Program. DO NOT PUBLISH BELOW THIS LINE Published: Nisqually Valley News, August 19, 2005 Posted in public areas: August 12, 2005 Copies to: All agencies/citizens on SEPA mailing list and adjacent property owners Dept. of Ecology w/checklist Attachment A Mitigated Determination of Non-Significance SPR-05-0160-YL 8 BSP-05-0197-YL Findings of Fact 1. This Mitigated Determination of Non Significance is based on the project as proposed and the impacts and potential mitigation measures reflected in the following environmental documents: / Environmental Checklist (June 7, 2005, Erling Birkland) / Wetland Reconnaissance (February 2005, Pacific Rim Soil & Water, Inc.) / Preliminary Drainage and Erosion Control Report (May 2005, Jerome W. Morrissette & Associates) / Transportation Impact Analysis (May 2005, Heathe & Associates) 2. The environmental documents indicate that the property is composed of soils and substrates that are suitable for building and for stormwater infiltration. There is no indication that there are any potential significant impacts to the earth (geology, topography, soils). 3. There is no indication in any of the environmental documents that there will be any potential long-term significant impacts to air quality from the proposed development. 4. The City of Yelm is identified as a Critical Aquifer Recharge Area, a designated environmentally sensitive area. Potential Impacts to groundwater quality and quantity will be mitigated through measures that meet or exceed the standards in the 1992 DOE stormwater manual as adopted by the City of Yelm. In addition, the northern portion of the property is identified by Thurston County as a potential high groundwater flooding buffer area. Thurston County, in other areas of the County that are potential high groundwater flooding areas, indicates in the Interim Site Development Standards for New Development in Salmon Creek Basin that if there is more than six feet of separation between the level of the high groundwater and the bottom of any infiltration gallery, the project should be designed to the effective drainage manual. The City has adopted the 1992 Department of Ecology Drainage Design Manual, which requires that stormwater generated from a parking facility be treated for oils, sediments, and heavy metals before infiltration. 5. The environmental documents do not indicate that there are any priority species or habitats or any endangered or threatened species on or near the property that would be impacted by the proposed development. 6. The environmental documents do not identify a potential significant impact related to the use of energy or natural resources. 7. The environmental checklist indicates noise generated from vehicles will be minimal. 8. The environmental checklist indicates that the site will be lit to provide a safe level of Attachment A MDNS (SPR-05-0160-YL &BSP-OS-0197-YL) lighting in the parking lot and around the building and that impacts will be mitigated through design of the lighting plan and placing down shields along the property line. 9. The City of Yelm has adopted a concurrency management system as required by the Growth Management Act. Chapter 15.40 YMC (concurrency Management) is designed to ensure that the improvements required to support development are available at the time of development. A concurrency determination may be issued for a proposal as it relates to transportation issues when: the development provides on-site frontage improvements; the project makes off-site improvements as necessary to provide for the safe movement of traffic; and the project makes a contribution to projects identified the six-year transportation improvement program in the form of a Transportation Facilities Charge. 10. The Growth Management Act at Section 36.70.070 (6)(b) RCW states that a finding of concurrency can be issued when required improvements are in place at the time of development or that a financial commitment is in place to complete the improvements or strategies within six years. 11. The City of Yelm and the Washington State Department of Transportation ("WSDOT") have established a minimum intersection level of service ("LOS") standard of "D" for all intersections in the City's commercial zones, with the exception of the intersection of Yelm Avenue and First Street NW where the standard is LOS "F". 12. All intersections in the City are currently operating in compliance with the adopted LOS standard and will continue to operate within the adopted standard after the completion of the proposal. 13. The traffic impact analysis (TIA) submitted as part of the application indicates that the project will generate an average of 563 vehicle trips per day, with a PM peak of 74 vehicles per hour. The TIA indicates that, with average growth: The proposal will impact traffic movements at various signalized intersections, including lowering the level of service and increasing wait times at the light at Yelm Avenue and First Street (SR 507 and SR 510) and increase wait times at the intersections of 103`d Ave and Yelm Avenue East, and West Road and 103`d Ave.SE. Although the proposal has an impact on the level of service of these intersections, the LOS will not drop below the City's adopted standards. 14. Section 14.04.055 YMC indicates that the principal guide in measuring environmental impact is consistency with the land use designations of the comprehensive plan and the development regulations designed to implement the plan. 15.The checklist indicates that the proposal will not require addition fire or police protection services. 16. Temporary construction impacts such as noise, light, water quality, and air quality, are mitigated by requirements of the Zoning Code and Development Guidelines relating to construction activities. Attachment A MDNS (SPR-05-0160-YL & BSP-05-0197-YL) Mitigation Measures 1. The developer shall mitigate transportation impacts based on the peak PM trips generated by the project. The Transportation Facility Charge (TFC) shall be based on the proposed use at the time of tenant improvement at a rate of $750 per peak PM trip. 2. The applicant shall be responsible for frontage improvements along West Road to meet City Standards for a commercial collector to include a sidewalk, planter strip, curb and gutter, a 5' paved shoulder and an 11' travel lane. 3. Civil plan submission shall include an updated preliminary stormwater plan that meets or exceeds the standards in the 1992 stormwater Manual as adopted by the City of Yelm. The stormwater plan shall include the following elements: a. Alternative technologies are not accepted. b. The elevation of the bottom of the infiltration gallery shall be a minimum of six feet above the elevation of the high groundwater area as identified by Thurston County (approximate elevation 335), and must be 50 feet horizontally, or 2 feet vertically away from the High Ground water area, which ever distance is less. c. Separate water quality treatment for roof runoff shall be provided. d. The stormwater system shall be designed to accommodate stormwater generated by required frontage improvements. 3. The civil plan submission shall include a lighting plan that maintains a light level of 0.1 candle-foot 5 feet off the edge of the property. Attachment A MDNS (SPR-05-0160-YL & BSP-05-0197-YL) OFFICE OF THE HEARING EXAMINER CITY OF YELM REPORT AND DECISION CASE NO.: APPEAL OF SITE PLAN REVIEW APPROVAL: SPR-03-8354-YL APL-03-8361-YL APPELLANTS: Mr. and Mrs. Steve Rothwell 1011 West Yelm Avenue Yelm, WA 98597 SUMMARY OF REQUEST: The appellants are appealing the conditions of their site plan review approval allowing the after the fact conversion of a residential accessory structure to a dance studio. SUMMARY OF DECISION: Appeal denied. PUBLIC HEARING: After reviewing Planning and Community Development Staff Report and examining available information on file with the application, the Examiner conducted a public hearing on the request as follows: The hearing was opened on January 16, 2004, at 1:00 p.m. Parties wishing to testify were sworn in by the Examiner. The following exhibits were submitted and made a part of the record as follows: EXHIBIT "1" - Planning and Community Development Staff Report and Attachments GRANT BECK appeared, presented the Community Development Department Staff Report, and testified that site plan review (SPR) is necessary to convert a previously constructed shop building to a dance studio. The city approved the SPR, but required that the existing residential structures connect to City sewer and water. The appellant does not appeal the requirement to connect the dance studio to public utilities. In addressing the appeal issues, statements and requirements made in the pre-submission conference are -2- not binding. In this instance, the results of the conference included a note that the requirements are preliminary in nature and the appellants were advised. The purpose of the pre-submission conference is to advise applicants of the process and the general requirements. However, the City does not consider any engineered drawings, but provides an idea of the requirements. The city engineer noted in comments that the department did not know about the water/sewer connection requirements. One of the reasons for the connection requirement is the adopted plans of both Thurston County and the City. A Group B water system currently serves the site and is regulated by City and Health codes. He listed all of the appropriate sections of the Thurston County plan which names the City as the primary water provider. The dance studio is a new development which constitutes a commercial public use. The SPR is a discretionary permit which allows the placement of conditions of approval. The regulatory authority is found in the staff report. The requirements are based in health, safety, and welfare as the new sewer line will cross the existing water line serving the two houses and will also be located within 100 feet of the present drinking waterwell. The storm system is also located nearthe septic drainfield, and the septic for the mobile home was installed in 1970. They have no septic permit for the house as it was constructed in 1944. Section 17.84.050 of the code requires apre- submission conference. BILL TURNER, professional engineer, appeared on behalf of the appellants and testified that they are not developers, but school teachers, and that Mr. Rothwell was selected as citizen of the month. They constructed the new building, a 50 foot by 60 foot pole barn with bays. They used one bay for a basketball court, one bay for storage, and the third bay for a dance studio. They originally erected the building for personal use, but people came to them and wanted them to expand the dance facility. The appellants felt that all they needed was a B&O License. If they had known of the violation they would never have made the change. They shut the business down immediately and came to the City to the resolve the issues. The site plan pre-conference lets people know the City's requirements and what they need to do to complete them. The whole reason is to familiarize people with the criteria and let them know what they need to do. The City should have notified the appellants at the pre-hearing conference and by not doing so failed to comply with the ordinance. The appellants will have to expend substantial funds to connect to utilities. The appellants spent substantial funds to comply with the presubmittal conference requirements. He referred to Section 13.08.020 regarding sewers and noted that connection is totally at the discretion of City staff. The ordinance doesn't specify when property owners have to connect, but only specifies connection must occur 30 days from the date of a failing system. If they did not have an approved functioning septic system, the City would have placed them on sewers long ago. The State does not consider the water system public, and the Health Department refers to it as a Group II only for administrative purposes. A relative lives in the second residence and the well is exempt. Three buildings exist on the site; two residences and a pole barn and they should be looked at separately. SR-510 is a severely congested road and approval of the site plan will require dedication of right-of-way and the construction of street improvements. The City will have to purchase the right-of-way if the project does not go forward. The use provides activities for 40 to 50 children and involves them in dance as opposed to video games and t.v. -3- Reappearing was MR. BECK who testified that the appellants were told of the requirements for a dance studio. Their use constitutes a commercial activity and was treated as such from day one. The administration of Group II water systems is part of the plan. Site plan review requires a notice of application and comment period and is therefore a discretionary permit. MR. TURNER reappeared and testified that properties are connected to utilities when developed. The appellants have lived on the site for a long time and will need to sell the parcel in accordance with its commercial zone. A future owner will connect the site. They would have to refinance the site to get the studio alone connected. The dance studio is a desperately needed use. No one spoke further in this matter and so the Examiner took the request under advisement and the hearing was concluded at 1:35 p.m. NOTE: A complete record of this hearing is available in the City of Yelm Community Development Department FINDINGS. CONCLUSIONS AND DECISION: FINDINGS: The Hearing Examiner has admitted documentary evidence into the record, heard testimony, and taken this matter under advisement. 2. Appropriate notice was given. 3. This request is exempt from review under SEPA. 4. On May 5, 2003, the City of Yelm issued building permit no. 6967 to Steven and Darlene Rothwell, appellants, authorizing construction of a "50 x 64 enclosed play area". Mr. Rothwell signed the permit application affirming in part: I certify that I have read and examined the information contained within the application and know the same to be true and correct. I also certify that the proposed structure is in conformity with all applicable City of Yelm regulations including those governing zoning.... The City classified the structure as a residential accessory use and a Group U occupancy under the 1997 Uniform Building Code (UBC) which includes private garages, carports, and sheds. The City of Yelm Municipal Code (YMC) considers an enclosed play area as an accessory use to an existing single family dwelling. -4- 5. Shortly following approval, the City became aware that the appellants were advertising dance lessons at the site to include a "summer special July and August only $20.00 classes per month". A staff investigation revealed that in addition to operating a dance studio from the "enclosed play area", the appellants had also installed restroom facilities without obtaining building or plumbing permits, connected the restroom tothe on-site well, and connected the building to the on-site sewage disposal system without approval of the Thurston County Health Department. The City issued an enforcement letter dated July 2, 2003, requiring the applicant to obtain site plan review for the commercial use. Thus, less than two months after obtaining the permit for an accessory, enclosed, play area the appellants commenced advertising and operating a dance studio, installed restroom facilities, connected said facilities to the existing on-site sewage disposal system, and provided water to the site, all without permits. 6. In response to the City's letter the appellants submitted to site plan review, and their application to convert a portion of the structure to a dance studio was approved on December 3, 2003. The City issued the permit subject to the appellants complying with a number of conditions which included: A. Connect all existing structures to the City water system. B. Abandon the existing well. C. Connect all existing structures to the City sewer system. D. Abandon the on-site septic disposal systems. The appellants appeal the City's imposition of the above conditions. 7. The appellants' parcel is irregularly shaped, measures approximately four acres, and abuts Yelm Avenue for 150 feet. Improvements on the site include a site built single family residential dwelling, mobile home, and the recreation building. An on-site drinking water well provides water to all three structures. The appellants agree to connect the "enclosed play area" structure to City water and sewer, but object to connecting the existing residential dwellings. The appellants therefore appeal the four conditions set forth hereinabove. 8. The City of Yelm granted site plan approval for the Rothwell Dance Studio Case No. SPR-03-8354-YL on December 3, 2003, and imposed the said four conditions along with numerous other conditions of approval. On December 9, 2003, the appellants timely filed a Notice of Appeal asserting four errors. Findings on all four alleged errors are made hereinafter. Appellants assert that the City violated the YMC by not specifically notifying them at the pre-application meeting that they would have to connect the two existing residential structures to City water and sewers. Appellants further assert that since they were not so advised, the YMC precludes the City from imposing such requirement. -5- 9. Section 17.84.050 YMC entitled "Preliminary Site Plan" provides: Prior to applying for site plan review, a developer may file with the SPRC [Site Plan Review Committee] a summary site plan, which shall contain in a rough and approximate matter all of the information required in the site plan application. The purpose of the summary site plan is to enable a developer filing the plan to obtain the comments of the SPRC as to the applicability of the intent, standards and provisions of this chapter to the plan. Section 17.84.020(C) YMC requires the SPRC to review a site plan as follows: C. The SPRC shall review a site plan and approve, or approve with conditions, site plans which conform to the standards. provisions and policies of the City as expressed in its various adopted plans and ordinances including the applicable sections of the shoreline master program for the Thurston region.... The YMC does not contemplate that the pre-submission review requires the City to identify all standards, provisions, and policies which will apply to the proposed plan. According to Section 17.84.050 YMC, an applicant need only provide "a summary site plan" which contains "in a rough and approximate manner all of the information required in a site plan application". The notes from the pre-application meeting specifically advise an applicant of that fact: These comments are preliminary in nature and are not intended to represent final comments and/or requirements for the City of Yelm. Until a complete application is made, the Community Development Department can only attempt to inform the applicant of general requirements as they appear in the form presented by the applicant at the time of submission. Even so, written comments from the pre-application meeting notified the appellant as follows regarding water and sewer: The proposed site is not currently connected to a public water system. Your site will be required to connect to the City of Yelm public water system... The proposed site is not currently connected to the City of Yelm's STEP sewer system. Your site will be required to connect to the City's sewer system... -6- Note: It is unknown at this time if the existing residence will be allowed to continue on the current water and sewer system. These options will be reviewed at the time of civil engineering review. If the residence is required to connected [sic] to the public water and sewer system, the well and septic system will have to be decommissioned. The SPRC did not fail to comply with the intent of the YMC as it specifically stated in the pre-application comments that the City would make the decision regarding sewer and water hook-ups for the homes "at the time of civil engineering review". 10. Appellants assert that the Washington State and Thurston County Health Department requirements have classified the existing well as a shared well or two party well and that it does not need approval as a Group B system. Furthermore, testing shows the well clean and free of any contaminants. The appellants therefore assert that while they must connect the commercial building to City water, the existing well is adequate and legal for the existing dwellings. Section 246-290- 020(1) of the Washington Administrative Code (WAC) provides in part: Public water system shall mean any system providing water for human consumption...excluding asystem serving only one single family residence.... WAC 246-290-020(5)(c) provides: A Group B water system is a public water system that does not meet the definition of a Group A water system.... The existing water system which serves the two residences on the site meets the definition of a Group B system. Section 2.1.2 of the South Thurston County Urban Growth Area's Abbreviated Coordinated Water System Plan (water system plan) provides in part: Over time, existing small public water systems should generally be incorporated into the designated utility to ensure adequate fire flow to protect structures and public safety and provide professional water system operation and management.... Section 4.5 of the water system plan reads: Minimizing the number of separate water systems is a long-term objective of the Public Water System Coordination Act. Incorporating existing small systems into municipal systems is consistent with this objective. Thus, the policies of the water system plan clearly provide that small water systems -~- such as the existing Group B system will be incorporated into the municipal system. The requirement of the SPRC that the applicant abandon the Group B system and connect to the Yelm water system is consistent with said policies. Furthermore, as previously found, Section 17.84.020(C) YMC requires the SPR to ensure that site plans comply with "policies of the City" as expressed in its "adopted plans". 11. Appellants assert that no "major building construction" will occur on the property, and therefore the appellant's 3,200 square foot building does not meet the definition of "new development". Section 17.84.010 YMC requires site plan review as follows: A. Site plan review and approval shall be required prior to the use of land for the location of any commercial, industrial or public buildin or activity.... B. Exceptions from site plan review and approval shall be granted by the site plan review committee, if: there is no addition of sauare feet or no additional tenant.... The appellants' proposal falls squarely within the requirements of Section 17.84.010 YMC, and thus site plan review is required. 12. Appellants assert that no City ordinances or Public Works standards require them to connect the existing residences to City water and sewer. As previously found, Section 17.84.020(C) YMC requires the SPRC to ensure that a proposed site plan conforms "to the standards, provisions, and policies of the City as expressed in its various adopted plans and ordinances". The Community Development Department Staff Report on pages 3-6 provides an exhaustive list of policies which support connection of the entire site to City sewer and water. CONCLUSIONS: The Hearing Examiner has jurisdiction to consider and decide the issues presented by this request. 2. Section 2.26.090(A)(1) YMC authorizes the Examiner to issue decisions on appeals from "orders, recommendations, permits, decisions, or determinations made by a City official in the administration or enforcement of the provision of the zoning code or any ordinance adopted pursuant to it". The City has shown that the SPRC did not exceed its authority, did not misinterpret the YMC, properly notified the appellants of the possibility of connection of both houses to city sewer and water, and properly imposed Conditions 2A, 2B, 3A, and 3B following its review of the appellants' site plan in Case No. SPR-03-8354-YL. Therefore, the appellants' appeal should be denied. -8- DECISION: The appellants' appeal should be denied. ORDERED this 3~d day of February, 2004. STEPHEN K. CAUSSEAUX, JR. Hearing Examiner TRANSMITTED this 3~d day of February, 2004, to the following: APPELLANTS: Mr. and Mrs. Steve Rothwell 1011 West Yelm Avenue Yelm, WA 98597 OTHERS: Bill Turner 4405 7th Avenue SE, Ste. 300 Lacey, WA 98503 City of Yelm Tami Merriman 105 Yelm Avenue West P.O. Box 479 Yelm, Washington 98597 CASE NO.: APPEAL OF SITE PLAN REVIEW APPROVAL: SPR-03- 8354- YL APL-03-8361-YL NOTICE 1. RECONSIDERATION: Any interested party or agency of record, oral or written, that disagrees with the decision of the hearing examiner may make a written request for reconsideration by the hearing examiner. Said request shall set forth specific errors relating to: -9- A. Erroneous procedures; B. Errors of law objected to at the public hearing by the person requesting reconsideration; C. Incomplete record; D. An error in interpreting the comprehensive plan or other relevant material; or E. Newly discovered material evidence which was not available at the time of the hearing. The term "new evidence" shall mean only evidence discovered after the hearing held by the hearing examiner and shall not include evidence which was available or which could reasonably have been available and simply not presented at the hearing for whatever reason. The request must be filed no later than 4:30 p.m. on February 18, 2004 (10 days from mailing) with the Community Development Department 105 Yelm Avenue West, Yelm, WA 98597. This request shall set forth the bases for reconsideration as limited by the above. The hearing examiner shall review said request in light of the record and take such further action as he deems proper. The hearing examiner may request further information which shall be provided within 10 days of the request. 2. APPEAL OF EXAMINER'S DECISION: The final decision by the Examiner may be appealed to the city council, by any aggrieved person or agency of record, oral or written that disagrees with the decision of the hearing examiner, except threshold determinations (YMC 15.49.160) in accordance with Section 2.26.150 of the Yelm Municipal Code (YMC). NOTE: In an effort to avoid confusion at the time of filing a request for -lo- reconsideration, please attach this page to the request for reconsideration. -~~- MEMORAND UM City of Yelm Community Development Department Engineering Division Pre-Application Meeting Date December 1, 2004 Civil Comments These comments are preliminary in nature and are not intended to represent final comments and or requirements for the City of Yelm. Until a complete application is made, the Community Development Department can only attempt to inform the applicant of general requirements as they appear in the form presented by the applicant at the time of pre-submission. Proponent: Erling Birkland, 3B & C LLC Project: Construct a Commerical Business Park Project Location: SE West Rd Yelm, WA 98597 Water The proposed site is currently not connected to the City of Yelm's water system. An existing 8" diameter water main is located at the intersection of 103~d Ave and West Rd. This project will be required to connect to and extend the water main along West Road. Following the water main extension the project will be required to extend the water system into the proposed development for its use. Commercial water connections are based on a consumption rate of 240 gallons per day and are charged at a rate of $1,500 per a residential connection (fee subject to change) inside city limits. Irrigation Meter: An irrigation meter shall be installed for the purpose of irrigation. An approved backflow prevention device will be required for all landscape irrigation connections. Cross Connection Control: Washington State Department of Health, in WAC 246-290-490 states that all group A water systems with 1000 or more connections are required by the department of health to develop and implement a cross control connection program. This program requires all commercial buildings and irrigation systems to have a back flow prevention device installed on the water services. A list of approved devices can be located at the above referenced Washington Administrative Code. Sewer The proposed site is currently not connected to the City of Yelm's STEP sewer system. This site is served by a 2" STEP sewer main located in West Road. This project will be required to install City of Yelm STEP sewer tank assembly(s) and an oil/water separator(s) before the STEP tank as required. The City will review the locations of proposed step tanks during land use approval. Commercial sewer connections are based on a consumption rate of 240 gallons per day and are charged at a rate of $5,417 per a connection (fee subject to change) inside city limits. An inspection fee of $145.00 per a connection will also be required. Fire All projects need to have fire protection for the buildings. When reviewing proposals or projects for compliance with the International Fire Code, the following need to be addressed: Does the proposal have fire hydrant coverage? To meet this requirement the building must have coverage by fire hydrants. All parts of the buildings must be within 150'of a fire hydrant. Another means of meeting fire code may be by installing a fire sprinkler system or utilizing fire lanes for fire truck access. Stormwater Developments with over 5,000 square feet of impervious surface are required to provide stormwater facilities pursuant to the 1992 DOE Stormwater Manual. If stormwater mitigation is required the types of stormwater mitigation may be wet ponds, bioswales and filter strips. The stormwater disposal is 100% infiltration. There is 2 ways to accomplish this: open ponds and underground galleries. The open ponds are depressions that store stormwater and allow it to infiltrate back into the underground aquifer. Street Improvements Frontage improvements will be required for this project. West Road is classified as an "Commerical Collector" roadway. This classification of roadway will require the half street pavement section of the roadway to be 16' in width, concrete curb and gutter, planter strip and 5' sidewalk. The required right of way will be 28' in width. Driveway location and distance from the intersection will be reviewed during the site plan review process. ADA Requirements The American Disabilities Act required that facilities are ADA accessible. Facility improvements will have to meet current code. Review of these improvements will be determined upon further review of the civil and architectural plans. February 3, 2004 Mr. and Mrs. Steve Rothwell 1011 West Yelm Avenue Yelm, WA 98597 RE: APPEAL OF SITE PLAN REVIEW APPROVAL: SPR-03-8354-YL APL-03-8361- YL Dear Appellants: Transmitted herewith is the Report and Decision of the City of Yelm Hearing Examiner relating to the above-entitled matter. Very truly yours, STEPHEN K. CAUSSEAUX, JR. Hearing Examiner SKC/ca cc: Parties of Record CITY OF YELM -1- City of Yelm ~~/ ,~`' Community Development Department 105 Yelm Avenue West P.O. Box 479 Yelm, WA 98597 wwswaroTOw Pre-Application Meeting December 1, 2004 These comments are preliminary in nature and are not intended to represent final comments and or requirements for the City of Yelm. Until a complete application is made, the Community Development Department can only attempt to inform the applicant of general requirements as they appear in the form presented by the applicant at the time of pre-submission. Proponent: Erling Birkland Project Proposal: Construct Office Complex Project Location: 10336 SE West Road Zoning and Setbacks The property is zoned Commercial (C-1 ), Chapter 17.26 YMC. This district allows business and professional offices as a permitted use subject to site plan review. Applications to develop, remodel or improve properties and structures within this zone shall require review and approval of a site plan in accordance with Chapter 17.84 YMC. Setbacks: Front property line 15 feet Side property line 10 feet Rear property line 20 feet Parking The requirements for off-street parking and their design shall be regarded as the minimum; however, the owner, developer, or operator of the premises for which the parking facilities are intended shall be responsible for providing adequate amounts and arrangement of space for the particular premises even though such space is in excess of the minimum set forth. Chapter 17.72 Business and professional offices require one (1) space per 300 square feet of gross floor area. Based on 57,200 square feet, 191 parking spaces would be required. For parking facilities containing 25 or more spaces, a maximum of 25% may be compact. 48 of these stalls may be compact. Yelm Development Guidelines 4G.110 states; "in all commercial and industrial developments, parking areas shall be so arranged as to make it unnecessary for a vehicle to back out into any street or public right-of-way. A parking plan shall be submitted to the Community Development Department for review and approval a the time of application for site plan review. All required parking areas must be paved, striped and landscaped. Ingress/Egress Ingress and egress at the site shall be consistent with the Yelm Development Guidelines, section 46.140. Existing vehicular access to the site is on West Road. No additional accesses may be created. Landscaping: Chapter 17.80, Type I, II, III, IV & V • Type I landscaping is intended to provide a very dense sight barrier and physical buffer to separate conflicting uses, and land use districts. Type I landscaping is required between this site and the residential use to the west. Type I landscaping is characterized by a 15 foot landscape strip in which any combination of trees, shrubs, fences, walls, earthen berms, and design features provides an effect which is sight-obscuring from adjoining properties. Type II landscaping is intended to provide visual separation of uses from streets, and visual separation of compatible uses so as to soften the appearance of streets, parking areas, and building elevation. This landscaping is used around the perimeter of a site, and adjacent to buildings. Type II landscaping would be required along the perimeter of the site on the north, east, and south property line. Type II landscaping is characterized by an 8 foot landscape strip between uses and a 5 foot strip around buildings of any combination of evergreen and deciduous trees (with no more than 50 percent being deciduous), shrubs, earthen berms and related plant materials or design features may be selected; provided, that the resultant effect is to provide partial screening and buffering between uses and of softening the appearance of streets, parking and structures. • Type III landscaping is intended to provide visual relief where clear sight is desired. This landscaping is utilized along pedestrian corridors and walks for separation of pedestrians from streets and parking areas. Type III landscaping would be required along West Road. Type III landscaping is typified by a six foot landscaping strip with street trees for a large overstory canopy along streets and pedestrian corridors and grass or other approved vegetation for groundcover. Earthen berms with grass or other vegetative groundcover and other design features may be worked into landscaping provided the resultant effect of providing apedestrian-friendly environment and visual relief where clear site is required can be achieved. • Type IV landscaping is intended to provide visual relief and shade in parking areas. At least 24 square feet of landscape development for each parking stall proposed. Each area of landscaping must contain at least 100 square feet of area and must be at least six feet in any direction. Each planting area must contain at least one tree. Live groundcover shall be provided throughout each landscaping area. No parking stall shall be located more than 50 feet from a tree. • Type V landscaping is required in storm water retention areas, if required. The floor and slopes of any stormwater retention/detention area shall be planted in vegetation that is suitable and will thrive in hydric soils. The landscaping of the stormwater facility shall be incorporated with all on-site landscaping. A conceptual landscaping plan is required with the application for site plan review. Final landscaping and irrigation plan is required as element of civil construction drawings, with installation prior to occupancy. The refuse area must be large enough to accommodate a dumpster and recycle bin. Refuse areas must be screened with an enclosure of a material and design compatible with the overall architectural theme. A six foot wall or fence shall enclose any outdoor refuse collection point. The fence shall be a solid material such as wood or masonry. Traffic The City has adopted a Transportation Facility Charge (TFC) of $750.00 per PM peak trip. The Code provides a default table that the applicant can use to determine new PM trips generated. For an administrative office, the trip generation rate is 3.68 per 1,000 square feet. A residence creates 1.01 new pm peak hour trips. This buildings previous use was a single-family residence. A credit should be issued for the existing traffic generation. To determine the projects impact and fee, use the following formula for the use proposed: ((Peak PM Trip Rate * Gross Floor Area)/1,000) * $750.00 =TFC Example: 3.68 x 57, 200 =210, 496 _ 1, 000 = 210.49 x $750.00 = $157, 872.00 Credit one residence. New residence: 1.01 x $750.00 = $757.50 Total: $157,114.50 If the applicant feels the proposed use would not generate the default number of trips as designated in the TFC Ordinance, and analysis prepared by a Washington State Licensed Engineer can be submitted to the City for review and consideration. SEPA An environmental checklist with a Traffic Impact Analysis is required. A portion of this property is within 200 feet of Yelm Creek, which is a shoreline of the state. Also, a portion of the property lies within the 100 year flood plain, and associated wetlands. If development occurs within the 200 foot shoreline jurisdiction area, a Shoreline Substantial Development permit is required. A wetland delineation is required to determine the wetland setback requirements. No development may occur in the flood zone. Application and Process Site Plan Review, Chapter 17.84, is an administrative process. Minimum application requirements are located in Section 17.84.060 and are listed on the application form. The Shoreline Substantial Development permit requires a public hearing before the Hearing Examiner. A project of this size can expect completed review in approximately 18 to 20 weeks. Land use approval typically contains conditions of approval that the applicant must complete prior to receiving a building permit. Upon satisfactory completion of all conditions of land use approval, the applicant can submit building plans for approval. Other Design Guidelines -the attached checklist must be submitted at time of application, with written responses on how each guideline requirement is proposed to be met. DESIGN GUIDELINES -West Road, Yelm WA 98597 Pro'ect Review Checklist Guidelines A licable Guidelines Met I.A. 1 Relate develo ment to edestrian oriented street fronta e. I.A. 2 Relate develo ment to street fronts other than edestrian-oriented streets . X I.B. 1 Minimize visibilit and im acts of service areas. I.C.(1) Take advantage of special opportunities and mitigate impacts of large develo ments. X I.D. 1 Reduce im act of service areas and mechanical a ui ment. X I.E. 1 Inte rate biofiltration swales and onds into the overall site desi n. X I.F. 1 Enhance the visual ualit of develo ment on corners. I.F.(2) Provide a paved pedestrian walkway from the street corner to the building entrance. II.A.(1) All pedestrian paths must correspond with federal, state and local codes for handica ed access, and the Americans with Disabilities Act. X II.A.(2) Provide adequate lighting at the building entries and all walkways and paths throw h arkin lots. X II.A. 3 Develo an on-site edestrian circulation conce t. X II.B.(1) Provide a pedestrian path at least 60" wide (preferably 96" wide) from the street sidewalk to the main ent X II.B.(2) Provide pedestrian paths or walkways connecting all businesses and the entries of multi le buildin son the same develo ment site. X II.B. 3 Provide athwa s throw h arkin lots X II.C.(1) Where street ROW is insufficient to provide adequate sidewalks buildings and other site features must be set back from the public ROW to achieve at least minimum sidewalk widths. X II.C.(2) Where new streets are developed, provide sidewalks according to minimum standards. II.D.(1) Provide, where feasible, pedestrian circulation routes to adjacent uses and transit. II.D. 2 Inte rate nearb transit sto s into the tannin of ad~acent site im rovements. II.D.(3) Encourage pedestrian paths from all transit stops through commercial areas to residential areas within 1,200 feet II.E. 1 Enhance buildin ent access. X II.F. 1 Provide edestrian-oriented o ens ace at ke locations. III.A. 1 Provide access roads throw h tar a lots with more than one street fronta e. III.B. 1 Minimize drivewa im acts. X III.C. 1 Meet re uirements for location of arkin lots on edestrian-oriented streets. Continued DESIGN GUIDELINES -West Road, Yelm WA 98597 Protect Review Checklist Guidelines Applicable Guidelines Met III.C. 2 Meet re uirements for arkin lot desi n detail standards. X III.D. 1 Minimize arkin areas throu h 'oint use and mana ement. III.D. 2 Encoura a structured arkin . III.D. 3 Reduce im acts of arkin ara es. IV.A. 1 Incor orate human-scale buildin elements. X IV.B. 1 Reduce scale of lar a buildin s. IV.C. 1 Architectural) accentuate buildin corners at street intersections. IV. D. 1 Enhance buildin s with a ro riate details. X IV. E. 1 Retain on final facades. IV.E.(2) Use compatible building materials. (See Building Material Summary Matrix, 59 X IV. F. 1 Treat blank walls that are visible from the street arkin or ad'acent lot. X IV.G.(1) Locate and/or screen roof-mounted mechanical equipment so as not to be visible from the street or from the round-level of ad~acent ro erties. X IV.G.(2) Where practical, locate and/or screen utility meters, electrical conduit and other service and utilities a aratus so as not to be visible from the street. X V.F.(1) Use plant materials that are approved for use in downtown Yelm. Pro onents ma use other )ant materials a roved b the Ci V.G. 1 Develo a site landsca a desi n conce t. X V.H. 1 Provide substantial site landsca in . V.H. 2 Protect and enhance natural features. X V.I. 1 Screen all arkin lots as re wired b Cha ter 17.80, Landsca in X V.I.(2) An alternative to the required perimeter parking area landscaping plan may be submitted. V.I. 3 Provide internal arkin lot landsca in X V.J.(1) Consider alternative building and parking siting strategies to preserve existin trees. V.J.(2) Consider the integration of pedestrian and bicycle paths with stands of mature trees where feasible to connect ad'acent uses. City of Yelm Community Development Department P.O. Box 479 Yelm, WA 98597 (360) 458-3835 (360) 458-3144 FAX Memorandum To: SPRC From: Roberta Allen, Administrative Assistant Date: September 6, 2005 Re: APP-OS-0275-YL -Project Review for West Road Professional Park Appeal Attached is the application packet for the above referenced project. After your initial review of the information submitted, if you need additional information from the applicant, please let me know as soon as possible. I:\APP Appeal\OS-0275 West Road Prof Park\Proj Rev Date Memo.doc ~oF 71~ CITY OF ~ YELM P.O. Box 479 Yelm, WA 98597 3saa5e-eaos RECEIVED ~***FIFTY DOLLARS & 00 CENTS RECEIVED FROM DATE REC. NO. 3B&C LLC 09/02/05 38174 PO BO% 875 YELILI WA 98597 BUDGETARY 894 2296 JANINE RECEIPT No. 3 817 4 AMOUNT REF. NO. 50.00 CASH SEPA APPEAL BSP 05 0197 YL ~7< ~ P~ Date Received ~~, T ~ City o f Yelm Fee G U By .I File No. -U 1 ~--- ~ 'l~'erf Communit Development y ~~i,~ ~ ~ o d~S Department NOTICE OF APPEAL YELM WASNINOTON ~~ ~ n Fee: Staff Decision - $50.00 Hearing Examiner Decision - $100.00 (In addition, any professional service charges per Resolution #358) A Closed record appeal may follow either an open record hearing or an open record administrative decision on a project permit application when the appeal is on the record, and no or limited new evidence or information is allowed to be submitted. Appeals on Category I & II project decisions are heard by the City Council. Appeals on Category III & IV project decisions as well as Category I & II decisions which have been appealed to the City Council go to Superior Court and follow the judicial review process set forth in RCW 366.70C. A Notice of Appeal must be filed within 14 days of Notice of Final Decision. PROJECT CASE NUMBER BEING APPEALED E3~ ~ D,~ D% /~' "~ ~ L_ DATE OF NOTICE OF FINAL DECISION /~~~-~~st- ~~ ZDD S APPELLANT(S) e~~ C' ~ ~ Mailing Address %~ c~ • r3c~;x ~'~ City, State and Zip 1/~ci~, Gch, jj,S~~ i' ~~ Telephone ~ ~ ,~ ~ Z 2 ~' EMAI L G ct29T~ .~ z.+~ -z , ~~ SPECIFIC ITEMS OF DECISION BEING APPEALED (attach additional sheet if necessary): ISCT i ~lTirIC~NE2~ I affirm that all answers, statements and information contained in and submitted with this application are complete and accurate to the best of my knowledge. I also affirm that I am the owner of the subject site or am duly authorized by the owner to act with respect to this application. Further, I grant permission from the owner to any and all employees and representatives of the City of Yelm and other governmental agencies to enter upon and inspect said property as reasonably necessary to process this application. I agree to ay all fees of the City that apply to this application. Signed - ~ -.__.-Date. ~'~1' D ~_ ~ ._ \ / ~~~ ~;~ 2 ?(~I15 CITY OF YELM ~~i~y 105 Yelm Auenue West (360) 458-3835 PO Box 479 (360) 458-3144 FAX Yelm, WA 98597 www.ci.yelm.wa.us tf ~ d~' .. ,.. Mr. Grant Beck, Community Development Director Date: 31 August 2005 5~~;= City of Yelm ' 105 Yelm Avenue W. P.O. Box 479 Yelm, Washington 98597 Re: Appeal of the Mitigated Determination of Non-Significance File Number SPR-OS-0160-YL and BSP-OS-0197-YL This letter is to formally appeal specific items identified in the published document of "Mitigated Determination ofNon-significance" File Number SPR-OS-0160-LY and BSP-OS-0197-YL, signed by Grant Beck, City of Yelm Community Development Director. The following comments are an appeal of items 3 a, b, c and d as stated in the "Mitigating Measures" of the published document: Item number 3 states that the Civil plan submission shall include an updated preliminary stormwater plan that meets or exceeds the standards in the 1992 stormwater Manual as adopted by the City of Yelm. The stormwater plan shall include the following elements: a. Alternative technologies are not accepted. The City of Yelm has allowed alternative technologies for treating stormwater in past projects, most recently the Yelm High School, Yelm Middle School and Ridgeline Middle School. Alternatively, Thurston County, City of Olympia, City of Tumwater and City of Lacey have all allowed "Alternative Technologies" to be used for the treatment of stormwater prior to infiltration. The proposed Vortechnics unit meets or exceeds many of the traditional means of removing pollutants and would be suitable in this application. We are requesting the City consider the use of effective alternative technologies that are currently being employed and approved with other projects in the City of Yelm and its neighbors. b. The elevation of the bottom of the infiltration gallery shall be a minimum of six feet above the elevation of the high ground water area as identified by Thurston County (approximate elevation 335), and must be 50 feet horizontally, or 2 feet vertically away from the High Ground water area, which ever distance is less. 1. The 335 elevation was not disclosed during the pre-submission conference with the City of Yelm. 2. How was this elevation determined, and what datum was this elevation derived from? 3. The 1992 DOE stormwater manual indicates that three (3) feet of separation is required between the bottom of the infiltration facility and the seasonal high ground water as determined from soil logs. J.W. Morrissette and Associates conducted 3 separate soil logs on site (see Preliminary Drainage & Erosion Control Report) and did not observe any evidence that would suggest that the ground water was any higher in elevation than 100" below existing grade. This was recorded in the test hole lowest in elevation. 4. Has the City formally adopted Salmon Creek Standards within the Yelm Creek area? This additional criteria was not disclosed at the pre-submission conference. c. Separate water quality treatment for roof runoff shall be provided. The Drainage Manual does not require that roof runoff be treated prior to infiltration. Is this criteria adopted by the City of Yelm? Previous projects within the City of Yelm have not required separate treatment of roof runoff. d. The stormwater system shall be designed to accommodate stormwater generated by required frontage improvements. Currently there is a stormwater collection system along West Road. We understand that the City's system was designed to handle the stormwater requirements for area located within the street right-of--way and includes a treatment and disposal component. Would the City consider the additional runoff for the improvements located in the street to be conveyed into the established collection system situated along West Road? Please feel free to contact me if you have any questions. Messages can be left at either 360-894-2296 or 360-458-3277. Sincerely, ~- - ~--Er ' g it 3 & C LLC PO Box 875 Yelm WA 98597