2009 10 12 Exhibits from ApplicantMcClure, PLLC
October l2, 2009
To:
Mr. Ben Cushman&
Ms. Doreen Milward
Cushman Law Offices, PS
924 Capitol Way South
Olympia, Washington 9801
RE: Smith Residence
City of Yelm Requirements for
Certificate of Occupancy
Dear Ms. Nlilward and Mr. Cushman:
ao sox a~ I a
Lacey, W.4 99509-8718
Phone~360-791-447a
Email' mtdurepllc@comcast.net
This letter is in response to your request for comments on the City of Yelm's requirements
for a certificate of occupancy for the Smith residence located on Lot 15, Palisades West
Avenue, Yelm, Washington.
You have asked me to address twa issues. First, the .fire flow requirement for the site.
Second, the plat requirement fora `sewer roll seal'. The following are my comments.
fire flow•
1t is my understanding the Yelm fire department in the persons of the Fire Marshall and the
Fire Chief have worked out a plan that they feel will allow any fire at the house to be
successfully fought. This plan includes using a two hydrants that are near the house. The
combined fire flow from these hydrants, using a second line and a booster pump is 1,065
gallons per minute. The nearest hydrant would deliver 500 g.p.m. The second hydrant,
located at the main road would deliver 565 g.p.m. using a booster pump and an extension
line. In addition, the fire department is confident that they could run tanker trucks back and
forth from the fire station which is located roughly 3 minutes away from the house.
The following is from the current edition of the International Fire Code:
C:llisers\VincetDocuments\a -- Consulting\a -- projeetsla -Legal Projects\Cushman -- Smith House in
Yelm\Cushman -- Smith Residence, City of Yelm CO Issues, 2009-10-12.wpd
Smith douse
City of Yclm
Certificate of Occupancy Issues
October 12, 2009
102.8 Subjects not regulated by this code. Where no applicable standards or
requirements are set forth in this code, or are contained within other laws,
codes, regulations; ordinances or bylaws adopted by the jurisdiction,
compliance with applicable standards of the National Fire Protection
Association or other nationally recognized fire safety standards, as approved,
shall be deemed as p~rtma tacte evtdence of compliance wtth the intent of this
code ~~~~~~~~1~~~ ~~~~~a~o~itl~'tl~~~'il`~~'~~e
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See the highlighted part of the paragraph. It is my experience that the fire code official's
(usually the fire marshal or the tiro chief) decision on topics regarding fire safety and code
interpretation are controlling. In my experience, if the fire code official says that the house
may be occupied and that a fire at the house could be successfully fought using existing fire
mains and hydrants, that would be accepted.
Sewer seal:
It is my understanding that the city is concerned about maximum sewer line flows from this
plat. I understand that there are-a total of 24 house sites platted. However, only the Smith
residence has been developed.
The purpose of the sewer sea] is to keep peak sewer flows from backing up in the manhole
below the plat and flowing out the top of the manhole onto the street or out of the manhole
into the soil. While I absolutely agree that one does not want the sewage contaminating the
soil nor flowing out the top of the manhole, there is a significant difference between one
house and 24 houses. One house will develop roughly 4.2% of the peak sewage flow as 24
houses combined. It is highly improbable that one house, could actually supply enough
water to overwhelm the capacity of the first downstream manhole and sewer line system.
If you have any questions or I may be of further help, please feel free to contact me by
telephone at 360-791-4478 or a-mail at mcclureplte(a~comcast.
Yours sincerely,
~~
r ~.~------ ~~ ~,
Vince McClure, SE, PE, PhD
McClure, PLLC
-page 2 of 2 -
C
October L2, 2009
Andrew & Cynthia Smith
Public Hearing before Yelm City Council, 10/13/09 7 pm
Points to Make on Behalf of Applicant
My clients, Andy & Cindy Smith, were issued a building permit by the City of Yelm on
September 17, 2008 for the construction of their house on Lot 15 in the Plat of Palisades
West. Their home was completed in April of 2009, but the Building Official has so far
refused to issue an occupancy permit on the basis that it would not comply with the plat
conditions added by the City Council to this final plat in December of 2007. Those two
plat conditions required that a booster pump station be installed before any building
permit could be issued (except for a model home), and also required the installation of a
sewer roll seal before any occupancy could be granted. My clients' home was never
portrayed as a model home, yet it was in fact granted a building permit The building
permit application clearly identifies the Smiths as the owner and Triance Homes as the
builder, and indeed all fees, including school mitigation fees were paid prior to the
issuance of the building permit. Based on that fact alone, we believe the City has a
responsibility to participate in the correction of this error.
To put this situation right, we have proposed a minor plat amendment, wherein an
exception to these two plat conditions be made for Lot 15 only. This would allow the
Smiths to occupy the home they are financially committed to pay for, yet prevent any
other houses in the plat. until the two upgrades are made by the developer of the plat or
his successor. At this time, there is no indication when the developer might be able to
obtain the necessary funding to make the improvements. However, the requested plat
amendments can be made, now, without any compromise to the public health and safety,
and without further liability to the City.
The statutory requirement for plat amendments is set forth at RCW 58.17.215, which
states: "The legislative body shall determine the public use and interest in the proposed
alteration..." You as the City Council need to determine that the requested plat
amendment serves the public interest. For the following reasons, we believe it does.
Fire Flow Issues -The water booster pump is required for the plat so that full water
pressure will be available up on the hill for all of the houses. While that is necessary at
full build-out, it is not necessary for one house. Discussions. with the SE Thurston Fire &
EMS -and the resulting Apri16, 20091etter from the Fire Chief and Deputy Fire Chief
confirm a plan whereby even a 100% involved fire can be successfully fought by using
the hydrant at the site with a supply line laid to the other hydrant located at the main road,
or an alternate plan using a relay of tender trucks. Because of the quick 3-minute
response time, there is adequate time for the trucks to refill and return. Also because of
the close proximity of the fire station, as explained by the Fire Chief it would be unlikely
that a fire at the Smith residence would ever get beyond 25% involved. However, such
an assessment is premised upon the occupied home, in which the residents would be there
to hear the alarm from the smoke detector.
This means that until occupancy is granted, the City is at greater exposure for liability in
case of a fire at this structure. Moreover, a vacant home is at even greater risk of damage
due to vandalism than an occupied home. Vandalism takes many forms, and arson is one
of the more common results. While it might be assumed that an occupied house has less
risk of a death from fire, in this situation, that assumption is not necessary true. The same
arsonists who would find an unoccupied resident an attraction, could most certainly cause
not only the loss of their own lives, but others as well. The City only exposes itself to
further risks of liability until the house is occupied.
The Fire District currently successfully serves homes in the vicinity, located not only
within the Yelm City limits and UGA, but also abutting County lands, including the two
homes on County land adjacent to the Smith house. There used to be two houses located
on the land that is now platted as Palisades West and were served for years without a
water booster pump. There is simply no physical reason what the water booster pump
would need to be installed prior to granting occupancy to the Smith house on I,ot 15.
We notice the staff report recommends denial of the plat amendment on the basis the
amendment would "waive a clear requirement of the International Fire Code and Health
Regulations..." But that is not true. The International Fire Code, at Section 102.8 gives
full authority to the fire code official to determine compliance. This means that the Fire
Chiefs' April 6, 20091etter to approve the occupancy prior to operation of the pump
station supersedes whatever conflicting regulations there may be. We are providing a
letter from Professional Engineer Vince McClure, SE, PE, PhD which addresses this
point (he would have been here tonight, but had a schedule conflict). To note for the
record, however, we did not actually find any conflicting regulations, since Yelm's
Comprehensive Water Plan requires single-family homes to have 750 gpm water
pressure, and the fire fighting plan devised by the Fire Department identifies that at least
1065 gpm can be obtained through the use of two relayed fire hydrants or tender trucks.
Sewer Issues. It is our understanding that the purpose of the sewer roll seal is to prevent
effluent overflow during times of peak usages. While this upgrade is necessary for the
plat at full build out, it is not necessary for the addition of one single-family home. One
house simply will not create apeak-use situation which would cause such an overflow.
Until other lots in Palisades Wcst are built, the Smith's single-family residence will be no
different than any other single-family residence in the City, and there is no regulation that
we could find requiring every single-family home in Yclm to install a sewer roll seal.
Liabilit Issues. While it is unfortunate that the economic downturn has prevented the
developer of Palisades West from completing the water and sewer upgrades, there is no
actual public safety or health reason to continue to deny my clients occupancy of this one
single-family home. We understand that the City has expressed concern that it would be
liable in the event of a fre. IIowever in this current state of limbo, the City is in fact
presently more liable. Further, the Smiths have agreed to provide the City with a Release
and agree to waive any claims due to fire that they could make against the City, but will
only do so if they are issued their occupancy permit. Based on the facts of this matter,
the City Council can and should find that the requested plat amendments serve the public
use and interest, and approve the Smiths' application for the requested amendments to the
Final Plat of Palisades West.