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HomeMy WebLinkAbout04-07-2025 - Appeal of Admin Decision - EmailedPage 1 of 3 KARL G. ANUTA LAW OFFICE OF KARL G. ANUTA, P.C. 735 SW FIRST AVENUE, 2ND FLOOR TRIAL ATTORNEY PORTLAND, OREGON 97204 E-MAIL LICENSED IN (503) 827-0320 OREGON & WASHINGTON FACSIMILE (503) 386-2168 KGA@LOKGA.NET COREY@LOKGA.NET April 7, 2025 VIA EMAIL AND FEDEX Jason A. Seth City Clerk, Renton WA Renton City Hall 1055 South Grady Way Renton, WA 98057 cityclerk@rentonwa.gov RE: Appeal of Administrative Decision Approving Building Permit B24004855 Dear Clerk: This is an Appeal of a decision to approve a Building Permit. This Appeal is filed on behalf of Lake Washington Working Families (“LWWF”), a coalition of King County residents, activists and organizations that support sustainable growth and good jobs in King County, while limiting impacts to climate change and our natural environment. LWWF has standing to appeal this decision as a party of record under RMC 4-8- 110(C)(1), because LWWF submitted written comments during the administrative review of this decision.1 A check for $577 (specifically check #282) made out to City of Renton, accompanies the paper copy of this Appeal. This appears to be the proper fee, per the RMC 4-8-110(C)(4) and the published Renton Fee Schedule. This Appeal is timely filed, as it has been submitted less than 14 days after the City publicly posted a notice of this Permit being moved to “Approved” status. That occurred on March 27, 2025. That was the first notice of any sort that a decision to approve had been made on the Permit.2 1 See, Letter dated 10/22/2024 from my office to the City of Renton Community and Economic Development Department, raising concerns about this application. 2 We are well aware that no Permit has yet been issued. We are also well aware that there has been no formal Notice to our firm (or LWWF) via mail or electronic mail issued by your office, as specified in RMC 4-8-100(C)(2). We file this Appeal nonetheless, out of an abundance of caution, just in case the Applicant tries to contend later that either: (a) no formal Notice to LWWF was required; and/or (b) that it was the decision to Approve (rather than a decision to Issue) the Permit that triggers the Appeal timeline. Page 2 of 3 LWWF has identified the following legal deficiencies in the approval of this permit: 1. Lack of Required Site Plan Review Under RMC 4-9-200(B)(2)(a), Site Plan Review is required for "all development" in the UC-2 zone in which this project is located. RMC 4-11-040(U) defines “development” to include "conversion,” "structural alteration," and “construction” and “enlargement” of “any structure.” The building at issue was formerly an electronics store. It is being converted into a grocery store. Thus, there is a conversion occurring. Moreover, it appears that approximately 500 micropiles will be installed and connected to bedrock to “support an interior slab” and “provide additional support for the perimeter wall footings.”3 Retrofitting the entire foundation of the building under specifications provided by a structural engineer is - by any rational definition - a structural alteration. The addition of a concrete slab in the compactor area, a slab that appears to be is integrated with or tied to the existing foundation, and the new exterior walls to screen that area4 meet the definitions of enlargement and construction. The same is true of closing off an existing ingress or exit onto Garden Ave N.5 In addition, because "[t]he proposed project is more than three hundred (300) parking stalls," 6 RMC 4-9-200(D)(2)(b)(v) also mandates Site Plan Review for this project. Because no Site Plan Review was completed for this application, despite the fact that multiple criteria that trigger Site Plan Review are present in the development application, the decision to approve the Building Permit without Site Plan Review was unlawful. That decision is also contrary to City Staff’s prior pre-application review, which recognized that Site Plan Review was necessary. This project must meet all of Site Plan Decision Criteria in RMC 4-9-200(E), including consistency with the Comprehensive Plan, Design Regulations, Reducing Parking Impervious Areas, Access and Circulation, and Stormwater. LWWF requests that the application be re-opened, and a full Site Plan Review process undertaken. Since the project requires Site Plan Review, the Planning Division should notify the Public per RMC 4-9-200(F)(5) once a complete application has been accepted, and the City should open a public comment period on the application. 3 See, 9/04/2024 Letter from Keller North America including plans for the micropile retrofit, including calculations for “structural loads” provided by the “project structural engineer.” 4 See, e.g., P_Structural_Construction_Plans_250206_v3, p. 3. 5 See e.g., P_Landscape_Construction_Plans_240920_V1, p. 2. 6 See, e.g., P_Civil_Construction_Plans_250102_v3, Sheet SP-01. Page 3 of 3 2. Lack of Required SEPA Review This project also requires SEPA Review under WAC Chapter 197. This project is not categorically exempt under WAC 197-11-800(3). That exemption applies to work on structures that involves “no material expansions or changes in use beyond that previously existing.” As outlined, the previous use of the building will change. And there will be expansions and/or structural changes to the building. Revising the structural integrity of the foundation, adding in a compactor slab, and altering street access to or exit from the site, goes well beyond the “minor alteration” description in that rule section. LWWF requests that a full SEPA review, with proper public notice and opportunity to comment, be conducted by the City for this project. Conclusion Without Site Plan Review and an adequate SEPA process, Renton cannot competently evaluate or approve this project. Public notice and input is needed to assure that all impacts of the project are thoroughly documented, and any necessary mitigation or alteration for those impacts is in place. That should have happened prior to project or building Permit approval. Compliance in this way will ensure that a correct, legally sufficient decision will result. Respectfully submitted, /s/ Karl G. Anuta Karl G. Anuta KGA/ev Enclosure cc:Client Patrice Kent, City Atty – via email