20100177 Approval(1)S TAFF REPOR T
City of Yelm
Community Development Department
Case Number: 20100177
Applicant/Owner: Salmon Run Yelm Associates
Mark Rozgay
2223 1121 Avenue NE
Suite 102
Bellevue, WA 98004
Agent: Zeck Butler Architects, P.S.
Rod Butler
421 West Riverside Ave, Suite 860
Spokane, WA 99201
Request: Proposed construction of a 40 unit apartment complex
Recommendation: Approval with conditions
Exhibit I: Site plan
Findings of Fact
The proposal includes construction of a 40 unit apartment complex on approximately
2.5 acres located at 10720 Vancil Road SE, Yelm, WA.
A Notice of Application was mailed to local and state agencies and surrounding property
owners on August 16, 2010.
Section 17.84.020 (C) Yelm Municipal Code allows the Site Plan Review Committee to
approve a proposal when the site plan conforms to the standards, provisions and
policies of the City as expressed in its various adopted plans and codes.
Property Characteristics
The property is identified by the Yelm Comprehensive Plan Map as Commercial (C-1)
zone which allows for apartments at a density of 16 units per acre as part of a mixed
use development. Apartments shall represent no more than 60 percent of a mixed use
development. The site was approved fora 48 unit apartment complex in 2001 as part of
a binding site plan and mixed use development project. The Site Plan Approval for the
apartment has expired. This application meets the mixed used development
requirements of the biding site plan. The apartment use is approved pursuant to the
Binding Site Plan. This site plan review is to ensure compliance with current standards.
Pursuant to Chapter 17.45 YMC, A mixed use development consists of two or more
different uses as part of an overall development project. The purpose of a Mixed Use
Planned Development is to encourage imaginative design and the creation of open
space in development by permitting greater flexibility in zoning requirements than is
permitted by other chapters of this title. Toward that end, it is the further purpose of a
Mixed Use Planned Development to:
A. Preserve or create environmental amenities superior to those generally found in
conventional developments;
B. Create or preserve usable open space for the enjoyment of the occupants;
C. Preserve to the greatest possible extent the natural characteristics of the land,
including topography, vegetation, waterways and views;
D. Encourage development of a variety of housing types;
E. Provide for maximum efficiency in the layout of streets, utility networks and other
public improvements;
F. Establish a method for utilizing potential zoned properties.
Based on approximately 2.5 acres, 40 units would be allowed. The applicant is
proposing 40 units. The required commercial element is already constructed.
The subject property is bordered on the north by property which is commercially zoned
and used for commercial purposes. The properties to the west and south are zoned
High Density Residential and are developed with single family and multi-family uses.
The property to the east is outside of City limits, and zoned rural residential.
The City of Yelm will provide police protection, water service, and sewer service. Fire
protection services are provided by The SE Thurston Fire/EMS (Thurston County Fire
Protection District #2).
State Environmental Policy Act
The City of Yelm SEPA Responsible Official adopted the Mitigated Determination of
Non Significance issued for the original apartment complex in 2001. The current
proposal is essentially the same, however creates less impact to the site by reducing
the number of apartments proposed.
Critical Areas
All of Yelm is considered a critical aquifer recharge area. Existing development
regulations require the treatment of stormwater prior to infiltration into the ground as
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well as the containment of hazardous materials on-site address the potential impacts to
this critical area.
The City Critical Area Maps indicate that the property is located outside of wetlands,
flood zones, and high ground water buffer areas.
Concurrency
Chapter 15.40 YMC requires the reviewing authority to determine that required urban
infrastructure is available at the time of development. Concurrency means the facilities
necessary to serve a proposed development are in place or planned for and properly
funded with a reasonable expectation that the facilities will be in place at the time
needed to preserve adopted levels of service.
Concurrency with sewer infrastructure is achieved pursuant to Section 15.40.020 (B)(1)
YMC when the project is within an area approved for sewer pursuant to the adopted
sewer comprehensive plan for the city and improvements necessary to provide city
standard facilities and services are present to meet the needs of the proposed
development.
The City's Sewer Comprehensive Plan identifies the property as being within the sewer
service area and is not currently connected to the City's STEP sewer system. The
project will be required to connect to the existing sewer main located in Vancil Road and
extend sewer lines to the site and construct all sewer related requirements to the
standards of the Yelm Development Guidelines. The Improvements required to serve
the project will be specifically identified during civil plan review. This satisfies the
requirement for concurrency with sewer infrastructure.
Concurrency with water infrastructure is achieved pursuant to Section 15.40.020 (B)(2)
YMC when the project is within an area approved for municipal water service pursuant
to the adopted water comprehensive plan for the city and improvements necessary to
provide city standard facilities and services are present. The proposed project is
located in the City of Yelm's water service area and must connect City water service.
As of the date of this approval, the City is currently at its approved water connection
limit, and no additional water connections are available. The City is actively working to
increase the source capacity of the water system as well as obtaining additional water
rights, and expects to allow new water system connections within the life of this site plan
review approval.
The State Building Code at Section 19.27.097 RCW requires evidence of water
availability and the issuance of a building permit by the City of Yelm is the City's
commitment to serve a proposal with potable water. The City is presently unable to
make such a finding as noted above.
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Concurrency with transportation infrastructure is achieved pursuant to Section
15.40.020 (5)(c) YMC when the project:
• Makes on-site and frontage improvements consistent with city standards and
roads necessary to serve the proposed project consistent with safety and public
interest;
• Makes such off-site facility improvements, not listed on the capital facilities plan,
as are necessary to meet city standards for the safe movement of traffic and
pedestrians attributable to the project;
• Makes a contribution to the facilities relating to capacity improvements identified
in the adopted six-year traffic improvement program, in the form of a
transportation facility charge.
Frontage improvements are required for all new development within the city. Frontage
requirements include improvements to the roadway from the centerline of right-of-way
back towards your property. The property frontage on Vancil Road is complete.
Construction of the private road entrance may require construction at the current
entrance. The frontage improvements must be repaired to City standards when
construction is complete.
Concurrency with school infrastructure is achieved pursuant to Section 15.40.020 (B)(4)
YMC when the developer provides a letter from the local school district that the school
facilities impacted by the proposed development are present, or are on an approved
and funded plan, to assure that facilities will be available to meet the needs and impacts
of the proposed development.
The developer shall enter into an agreement with Yelm Community Schools to mitigate
project impacts to the School Districts as required through the SEPA determination
process with the City of Yelm. This agreement satisfies the requirement for
concurrency with school infrastructure.
Concurrency with Fire Protection is achieved pursuant to Section 15.40.020 (6) YMC
when the developer makes a contribution to the fire protection facilities as identified in
the most current version of the capital facilities plan adopted by the Yelm Fire District
(SE Thurston Fire/EMS) and endorsed by resolution of the Yelm City Council.
A fire impact fee will be assessed at the time of building permit issuance, based on the
square footages of the buildings.
Design Review
The property lies within the (C-1) Commercial zone, and was designated for apartments
as part of a previous Binding Site Plan and Mixed Use Development. Development on
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the site is required to meet the intent of City of Yelm's design guidelines. The guidelines
are intended to supplement the design standards in the City of Yelm Zoning Code.
Guidelines include provisions, requirements or considerations that are in addition to the
Zoning Code standards.
.~traat Frnntc
All development for properties not on pedestrian oriented streets shall include site
planning measures to create an attractive street edge, accommodate pedestrian
access, and support downtown design objectives. Examples of requirements based on
Downtown Goals and Policies are stated in the following:
• Define street edge with building landscaping or other features.
• Provide direct access to building fronts from the sidewalk.
The residential nature does not lend itself to locating the buildings at the street frontage.
Landscaping between the parking area and sidewalk connection meets the street
frontage intent of the development guidelines.
Side and Rear Yards/Siting Service Areas
The design guidelines indicate that service areas, and outdoor storage be located away
from neighboring properties to reduce conflicts and requires screening of refuse
containers located behind the building. No refuse container shall be permitted between
a street and the front of a building.
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.
The following describes the intent in siting service areas based on the Design
Guidelines:
• To "reduce the visibility of unsightly uses".
• To minimize the visibility of "backs" of buildings where service areas are located.
• To "encourage more thoughtful siting of trash containers and siting areas by
screening its negative aspects".
• To reduce the noise impacts of service areas.
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Refuse collection areas must be designed to contain all refuse generated on site and
deposited between collections, and refuse should not be visible from outside the refuse
enclosure. 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 structures.
The proposed locations of refuse containers are acceptable. The design guidelines
sizing for residential units requires a minimum 4 cubic yard dumpster for each 20 units
and that the walls of the enclosure be 7 feet in height. The proposed 120 square foot
dumpster size may be too small to accommodate the minimum size dumpster and
recycle bin. Dumpster location must be approved by Lemay, Inc during civil plan
review.
Pedestrian Circulation
The following elements must be provided as part of the site plan for new developments:
• All pedestrian paths must comply with the ADA.
• Adequate lighting must be provided for pedestrian access.
• Walkways should be integrated with the required parking lot landscaping.
• Provide pathways through parking lots
• Integrate transit stops into the planning of site improvements
• Provide weather protection such as a canopy to create a covered pedestrian
open space.
• Provide at least 200 square feet of landscaping at or near the entry.
• Provide pedestrian facilities such as benches, kiosks, or bicycle racks.
• Provide pedestrian scaled lighting
• Adjacent window displays
• Provide artwork or special pedestrian scaled signs
There are accessible walking paths from the street frontage to all buildings within the
site. The sidewalks fronting the building appear to be only 48 inches feet in width, while
City of Yelm Design Guidelines requires 60 inches. The site plan does not show any
pedestrian connection to the commercial development to the north. An accessible
pathway to the commercial development to the north must be provided.
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Building Design and Details
To encourage buildings that are comfortable at a human scale, at least three of the
following features must be incorporated into the building design:
• Balconies in upper stories
• Bay windows
• Pedestrian oriented space
• Individual windows
• Gable or hipped roof
• Porch or covered entry
• Spatially defining building elements that define an occupied space
• Upper story setbacks
• Composing smaller building elements near the entry or pedestrian oriented street
fronts
To ensure new development is compatible with Yelm's architectural size and character,
at least two of the following features must be incorporated into the building design:
• Upper story setback
• Horizontal building modulation
• Modulated roof line
• Building articulation
To encourage unique, identifiable architectural features at intersections, at least one of
the following features must be included on a facade facing a public street:
• Decorated roofline
• Decorative treatment of windows and doors
• Decorative railings, grill work, or landscape guards
• Landscape trellises
• Decorative light fixtures
• Decorative building materials (masonry, wood details or patterns)
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Concrete block walls must use textured blocks, colored mortar or a mix of other
masonry types. Concrete must be architecturally treated.
The apartments will incorporate pedestrian scale lighting and landscaping at or near the
building entrances.
Metal roofing must be of high quality with a standing seam and can not be brightly
colored.
Blank walls must be treated through trellis and plantings, landscaping beds or other
methods.
Preliminary elevation plans show building articulation, balconies and windows. The
elevation plans meet the design guidelines for building details.
Transportation
Yelm is a small compact community most directly affected by two state highways, SR
510 and SR 507, which bisect the community. These state routes are used by local
residents for transportation throughout the City, and for access to commercial and
residential areas throughout the community as well as serving regional traffic.
The updated Transportation element of the Yelm Comprehensive Plan identifies a
number of improvements designed to avoid the need to significantly widen existing
streets, and particularly Yelm Avenue. New development impacts the transportation
system in Yelm and, unless the improvements identified in the transportation plan are
constructed, the City would need to require developers to pay the cost of internal street
widening.
Frontage improvements are required for all new development within the city. Frontage
requirements include improvements to the roadway from the centerline of right-of-way
back towards the property. The property frontage on Vancil Road is complete.
Construction of the private road entrance may require construction at the current
entrance. The frontage improvements must be repaired to City standards when
construction is complete.
The City has adopted a Transportation Facility Charge (TFC) of $1,321.00 per peak PM
trip. The concurrency chapter of the Municipal Code provides a default table that is
used to determine new peak PM trips generated by a proposed use. Amulti-family
dwelling unit creates .60 new pm peak hour trips.
Water Supply
The City's Water Comprehensive Plan identifies the property as being within the water
service area. The proposed site is not currently connected to the City's water system.
The project will be required to connect to the existing water main located in Vancil Road
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and extend the water system as needed to support the intended uses. A "looped"
system may be required.
Water connections are based on a consumption rate of 875 cubic feet a month and are
charged at a rate of $5,036.00 per a connection (fee subject to change). The fees will
be calculated utilizing the water consumption calculations provided by a civil engineer.
These fees are payable at building permit issuance.
The apartment building and irrigation systems are required to provide for cross-
connection control through the provisions of a back flow assembly device installed on
the water services. A list of approved devices can be found at Chapter 246-290-490
WAC.
Any existing well(s) will need to be abandoned per Department of Ecology standards
and any water rights will need to be dedicated to the city.
Identified in the 2002 City of Yelm Water Comprehensive Plan is a requirement to install
fire hydrant locks as part of the City's water conservation and accountability program.
Sewer System
The City's Sewer Comprehensive Plan identifies the property as being within the sewer
service area and the site is not currently connected to the City's STEP sewer system.
The project will be required to connect to the existing sewer main located on Vancil
Road.
The preliminary site plan shows a sewer force main located behind the apartment
buildings. The force main is required to be located within the drive lane with service
extended to the front of the buildings.
This proposal will be required to install step tank(s) and associated equipment needed
to operate with the City of Yelm's step sewer system. Improvements required to serve
the project will be specifically identified during civil plan review to determine tank size
based on water consumption.
Any on-site septic systems will need to be abandoned prior to connecting to the STEP
sewer system.
It is unclear from the preliminary site plan the intent and build out of the community
building. The type of kitchen construction may require the need fora grease
interceptor. This can be determined during civil plan review.
The current fee to connect to the City sewer system is $6,050.00 per Equivalent
Residential Unit (each ERU equals 875 cubic feet of water consumption per month, fee
subject to change). An inspection fee of $145.00 per a connection will also be required.
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Stormwater Quality and Quantity
Impervious surfaces create stormwater runoff which, when uncontrolled and untreated
can create health, safety, and environmental hazards. The City of Yelm has adopted
the 1992 Department of Ecology Stormwater Manual, which requires all development to
treat and control stormwater when over 5,000 square feet of impervious surface is
created.
The applicant has submitted a preliminary stormwater report which includes a
conceptual design for the treatment and infiltration of the stormwater. This design uses
the 2005 Department of Ecology Stormwater Manual as the proposal includes an
Underground Injection Well for stormwater that requires a permit from Ecology. The
Community Development Department has reviewed this report and is concerned that
the conceptual treatment and infiltration system appears to be undersized. The
Western Washington Hydraulic Model should be used for stormwater system sizing.
Section 17.80.050(F) requires landscaping to provide visual relief in stormwater areas.
If chain link fencing is used around the storm pond, it must be green or black vinyl
coated.
Stormwater facilities must be located 10 feet from any property lines The conceptual
plan does not meet this minimum standard.
Stormwater facilities require continued maintenance to ensure they remain in proper
working condition.
Parking
The City of Yelm Development Guidelines, Design Guidelines, and Municipal Code
address parking regulations from many aspects, including, but not limited to the design
of lots, the number of stalls required, pedestrian pathways within lots, and safety.
The requirements of off-street parking and loading facilities 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
or its arrangement is in excess of the minimum set forth. All parking areas must be
surfaced with asphalt or concrete, and shall be striped and landscaped to the standards
of the development guidelines.
Chapter 17.72 YMC requires multi-family dwelling units to provide (2) two parking
spaces per unit. For the proposed 40 units, 80 parking spaces would be required. The
community building has an occupancy rating of 130 which requires 13 stalls. The site
plan shows only 80 parking stalls. The site plan does not meet minimum requirements
for parking.
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Parking Lot Illumination
Adequate internal parking lot lighting is necessary to provide safety to pedestrians and
vehicles. All parking areas and driveways must be lighted to a level of at least .5 foot
candle average as measured on the ground. Parking lot light fixtures shall be non-glare
and mounted no more than 20 feet above the ground to minimize the impact onto
adjacent properties.
Fire
Fire protection to the buildings shall be provided pursuant to the International Fire Code.
The specific requirements for installation of all fire hydrants, fire sprinklers and fire lanes
will be determined during civil and building plan review.
The International Building Code (IBC) provides occupancy ratings for different types of
uses. The fire coverage and sprinkler system for the proposed use must meet
International Building Code requirements.
A Fire Impact Fee pursuant to Section 15.40.020 (B)(6) YMC is established at a rate of
$0.32 per square foot of development for all new development in the City of Yelm.
Landscaping
Landscaping and screening are necessary to provide screening between compatible
and incompatible land uses, to safeguard privacy and to preserve the aesthetic assets
of the City. Chapter 17.80 YMC requires all development to provide on site
landscaping.
The Design Guidelines prohibit the use of chainlink fencing in the design guideline
areas. If the proposal includes a perimeter fence, wood or other fencing material must
be used.
Type 11 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. It is used around the perimeter of a site with a minimum
planting area of eight-feet in width. When used adjacent to a building, a minimum five-
foot planting area shall be provided. Minimum requirements for Type II landscaping are
a mix of evergreen and deciduous trees, and shrubs that are to cover the landscaped
area in 3 years. The conceptual site plan shows a mix of trees, but not the 8 foot
planting area. The site plan also shows a stormwater treatment swale located within the
required landscape area at the east and south side of the property. The stormwater
retention and slopes are not conducive to the proper planting and health of the required
Type II landscaping. The planter strips shown on the southwest corner do not meet the
required 8 foot planting width. The site plan shows a 5 foot planting strip. Anew site
plan with the required minimum landscaping is required.
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Type 111 landscaping is intended to provide visual relief where clear sight is desired.
This type is utilized along pedestrian corridors and walks for separation of pedestrians
from streets and parking areas. The minimum width for Type III landscaping shall be six
feet. Type III landscaping is required as a part of street frontage improvements and is
complete along the frontage of Vancil Road. Any disturbance during construction will
need to be replaced.
Type IV landscaping is intended to provide visual relief and shade in parking areas.
Parking shall have 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.
Type V landscaping is to provide visual relief in storm water retention/detention areas
with vegetation that is suitable and will thrive in hydric soils. The landscaping of the
stormwater facility shall be incorporated with all on-site landscaping.
Section 17.80.090 (F) YMC states that the owner/developer of any project requiring site
plan review approval, subdivision approval, or short subdivision approval shall provide a
performance assurance device in order to provide for maintenance of the required
landscaping until the tenant or homeowners' association becomes responsible for
landscaping maintenance. The performance assurance device shall be 150 percent of
the anticipated cost to maintain the landscaping for three years.
The City of Yelm also promotes water conservation and will require the final
landscaping plan to address the following requirements:
• Specify Water efficient plant species for the Pacific Northwest.
• Limit the amount of turf grass in landscape design.
• Choose irrigation devices and design the irrigation system to positively prevent
runoff or overspray onto impermeable hardscape under all conditions regardless
of wind or possible equipment misalignment.
• Assign separate station/zones (hydrozones) to areas with dissimilar water or
scheduling requirements. For example; separate zones should be designed for
trees, shrubs, flowers, shady areas, sunny areas, drip irrigation and sprinklers.
• Locate sprinkler heads based on a thorough evaluation of physical,
environmental, and hydraulic site conditions, including wind. The design must
not permit sprinklers to overspray onto impermeable hardscape under any
condition.
• Specify drip irrigation for all zones planted in one-gallon or larger size.
• Specify weather-based irrigation controllers (WBIC).
• Specify check valves wherever necessary to prevent low-head drainage.
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The final landscaping plan shall provide complete detail of the landscape plants,
features and irrigation requirements.
Open Space
The Growth Management Act establishes a goal for open space and recreation that
states "encourage the retention of open space and development of recreational
opportunities, conserve fish and wildlife habitat, increase access to natural resource
lands and water, and develop parks" [RCW 36.70A.020(9)].
Chapter 14.12 YMC provides guidelines for the retention and creation of open space
within the City. This chapter requires a minimum of 10 percent of the gross area of a
multi-family development be dedicated as usable open space. Appropriate uses are
listed in Chapter 14.12.050. The applicant is proposing an outside play area with play
equipment and a community building. This meets the intent of the open space
requirement.
Conclusions of Law
A. The Site Plan Review Committee has jurisdiction to consider and decide the
issues presented by this request.
B. The applicant has established that the request for site plan review approval
satisfies all criteria set forth in Section 17.84.020(C) YMC, meets all
requirements of the (I) Industrial zoning classification, and meets all other
requirements of the Yelm Municipal Code. Therefore, the site plan should be
approved subject to the following conditions:
1. The conditions of the Mitigated Determination of Non-significance are hereby
referenced and are considered conditions of this approval.
2. Any disturbance of existing frontage improvements and landscaping must be
replaced to City standards.
3. The site shall connect to the City's water system. This can only occur when
the City of Yelm has capacity to serve the project. The connection fee and
meter fee will be established at the time of building permit issuance. All
conditions for cross connection control as required in Section 246-290-490
WAC shall be met prior to issuance of certificates of occupancy
4. An engineers estimate for additional water usage shall be submitted as part of
the civil plan submission.
5. The proposed site shall connect to the City's STEP sewer service. The
connection fee will be based on water usage calculations and established at
the time of building permit issuance.
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6. Civil plans shall show the sewer force main located within the drive lane, and
grease interceptor for the community building if required.
7. Any existing wells and on-site sewage disposal systems shall be abandoned
pursuant to applicable Washington State and Thurston County health
regulations. Evidence that all wells and sewage disposal systems have been
abandoned in an approved manner is required prior to approval of civil
engineering plans.
8. The civil engineering plans shall include plans for the collection, treatment,
and infiltration of stormwater. If the 2005 stormwater manual for Western
Washington is used, the Western Washington Hydraulic Model should be
used for system sizing.
9. A 10-foot setback from all property lines and easements are required for
stormwater facilities. Best Management Practices (BMP's) are required
during construction.
10. Parking shall be provided in accordance with the City of Yelm Development
Guideline standards. Based on the proposed 40 units and the community
center, a minimum of 93 parking stalls are required. Parking lot lighting must
meet Design Guideline standards.
11. Pedestrian access to the adjacent commercial property is required. All
pedestrian access and sidewalks shall be a minimum of 60 inches wide.
12. When service areas are visible from the sidewalk or adjacent properties, the
elements must be screened with a screening wall and landscaping. A
minimum 4 cubic yard dumpster for each 20 units is required, with the
enclosure wall 7 feet in height. The location and access to all refuse
enclosures shall be approved in writing, by LeMay, Inc. prior to civil plan
approval.
13. Fire protection shall be provided in accordance with the International Fire
Code, as adopted by the City of Yelm, and may include FDC's, fire hydrants,
and/or fire lanes. Fire Impact Fee pursuant to Section 15.40.020 (B)(6) YMC
is established at a rate of $0.32 per square foot of development for all new
development in the City of Yelm
14. The civil engineering plans shall include final landscaping and irrigation plans
which are consistent with the preliminary plans and include the following
required landscaping:
• All required landscaping shall consist of drought tolerant shrubs and
bark or other ground cover instead of grass.
• Type II landscaping is required around the perimeter of the site. Type
II landscaping areas must be a minimum of 8 feet in width.
• Type IV landscaping is required in parking areas.
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• Type V landscaping is required for above ground stormwater facilities.
15. To promote water conservation, any irrigation shall be in the form of a Drip
System.
C. The Site Plan is valid for eighteen (18) months from the date of this approval.
The applicant may request asix-month extension on the approval, if the request
is made in writing prior to the expiration date of this approval. If you need
additional information or assistance, please call the Community Development
Department at (360) 458-3835.
Decision
The request for site plan review approval is hereby granted subject to the conditions
contained in the conclusions above.
PREPARED by Tami Merriman, Associate Planner
APPROVED this 13t" day of October, 2010.
Gra Be ,Director of Community Development
Site Plan Review Committee
City of Yelm
Appeal
Site Plan Approval is a Type II Administrative land use approval. An appeal of this
decision can be filed within 14 days from the date of this approval, pursuant to YMC,
Chapter 15.49, Integrated Project Review Process. Any appeal must be in writing,
contain specific factual objections, and include the appeal fee of $50.00.
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