HomeMy WebLinkAboutLUA-05-089_HEX Decision.pdfOctober 17, 2006
OFFICE OF THE HEARING EXAMINER
CITY OF RENTON
Minutes
APPLICANT/OWNER:
CONTACT:
LOCATION:
SUMMARY OF REQUEST:
SUMMARY OF ACTION:
DEVELOPMENT SERVICES REPORT:
PUBLIC HEARING:
Terry Defoor
GWCInc.
24633 NE 133 rd Street
Duvall, W A 98019
Debra Eby Ricci
Ricci Grube Aita, PLLC
Attorneys and Counselors at Law
1601 Second Ave., Ste. 1080
Seattle, W A 98101
Defoor Short Plat
LUA 05-089, SHPL-H
900 Renton Avenue South
Hearing Examiner Short Plat approval for the subdivision of
3.2 acres into five lots for the future development of single-
family residences.
Development Services Recommendation: Approve subject to
conditions
The Development Services Report was received by the
Examiner on September 26, 2006.
After reviewing the Development Services Report, examining
available information on file with the application, field
checking the property and surrounding area; the Examiner
conducted a public hearing on the subject as follows:
MINUTES
The following minutes are a summary of the October 3, 2006 hearing.
The legal record is recorded on CD.
The hearing opened on Tuesday, October 3, 2006, at 9:25 a.m. in the Council Chambers on the seventh floor of
the Renton City Hall. Parties wishing to testify were affirmed by the Examiner.
The following exhibits were entered into the record:
Exhibit No.1: Yellow file containing the original Exhibit No.2: Neighborhood Detail Map
application, proof of posting, proof of publication and
other documentation pertinent to this request.
Exhibit No.3: Preliminary Short Plat Map Exhibit No.4: Preliminary Landscape Plan
Defoor Short Plat
File No.: LUA-05-089, SHPL-H
October 17, 2006
Page 2
Exhibit No.5: PreliminalY Grading and Utility Plan
Exhibit No.7: Slope Analysis
Exhibit No.9: City's Determination of the
Unmapped StreamslWetIand Classification
Exhibit No. 11: City's Reconsideration of Unmapped
Stream Determination
Exhibit No. 13: Appeal to City Council of hearing
Examiner's Decision
Exhibit No. 15: Sheet W1.1
Exhibit No.6: Tree CuttinglLand Clearing Plan
Exhibit No.8: Environmental Review Committee
Mitigation Measures
Exhibit No. 10: Reconsideration Request/Appeal of
Determination of Unmapped Streams
Exhibit No. 12: Hearing Examiner's Decision
Exhibit No. 14: Zoning Map
The hearing opened with a presentation of the staff report by Jill Ding. Senior Planner, Development Services,
City of Renton, 1055 S Grady Way, Renton, Washington 98055. The site is located to the west of Renton
Avenue S, east ofI-405, and north ofa Puget Sound Energy right-of-way. It is located in the R-8 zoning
designation and within the Residential Single-Family Comprehensive Plan designation. The property is
approximately 3.2 acres in area.
The proposal is to subdivide the site into 5 lots and one open space tract west of the proposed lots. The site
slopes from east to west with an approximate slope of 26%. The proposal does qualify as a Hillside
Subdivision. There are High Landslide Hazard Areas, Erosion Hazard Areas, Steep Slope areas and High Coal
Mine Hazard areas located on the site. The majority of these areas are located within the open space tract. The
site is currently forested, approximately 25% of the vegetation would be removed for the development of this
short plat.
There also are four unmapped streams and an unmapped wetland on the site located within the open space tract.
The streams flow east to west on the northern and southern portions of the site. The wetland was classified as a
Category 3 Wetland, which requires a 25-foot buffer. It is located at the northeast comer of the project site.
Stream A has been classified as a Class 4 stream, and is not under appeal. Drainage 1, Stream B and Stream C
are under appeal. Drainage 1 is a Class 4 stream, Stream B a Class 3 stream and Stream C also a Class 4 stream.
Access to the proposed lots would be via single-family residential driveways onto Renton Avenue S.
The Environmental Review Committee issued a Determination of Non-Significance -Mitigated with 3
mitigation measures. No appeals were filed.
The plan is consistent with the Residential Single Family Land Use, Community Design and Environmental
Elements.
The net density for the site would be 1.67 dulac, which complies with the density requirement for the R-8 zone.
The applicant has proposed larger lot sizes than required in the R-8 zoning standards, the lots are proposed to be
located on a portion of the site that does not contain steep slopes and they appear to be adequate. Lots 1,2 and 3
Defoor Short Plat
File No.: LUA-05-089, SHPL-H
October 17, 2006
Page 3
should be adjusted to provide a minimum lot width of 50-feet for each of the proposed lots. Staff requested a
revised short plat map be submitted prior to approval of the final short plat.
A Homeowner's Association or Maintenance Agreements should be created to establish responsibility for any
common improvements and the proposed open space tract.
The preliminary plat map indicates the setback lines on each lot. The setbacks will be verified at the time of
building permit review, each lot appears to provide adequate area to comply with the required setbacks.
The building height and lot coverage appear to be in compliance with the R-8 zone, these building standards will
be verified prior to the issuance of building permits for each individual structure.
Access to all lots would be via single-family residential driveways off of Renton Avenue S. Half street
improvements including sidewalks, curb and gutter, paving, storm drainage, street lighting and street signs are
required fronting the site on Renton Avenue S.
Traffic, Parks and Fire mitigation fees have been recommended for this project.
The subject site slopes from east to west and has an average slope of approximately 26%. A Geotechnical
Report and Grading Plan has been submitted. The eastern portion of the site has been deemed suitable for
development. There are no steep slopes on that portion of the site.
The City's Critical Area Regulations permit averaging of stream buffers, Class 4 streams to a minimum of a 25-
foot buffer and a Class 3 stream to a minimum of 37.5-foot buffer. Nothing below those minimums has been
proposed for this site.
A Native Growth Protection Easement must be established over critical areas and their associated buffers. The
majority of the critical areas and their buffers are located within the open space tract. There are a few areas
where the buffer areas will be extended into the setback areas of the individual lots, which is permissible.
Approximately 25% of the vegetation would be removed from the plat. This project came in prior to the rule of
saving 25% of the trees, therefore, they do not have to meet that requirement. However, they are retaining a
significant amount of trees. A landscape plan was submitted indicating 2 trees for each front yard or planting
areas of each lot. A minimum 5-foot landscape strip is required along Renton Avenue S and that was not on the
landscape plan. It was determined that if no additional area is available within the public right-of-way due to
required improvements, the 5-foot landscaped strip may be located within private property abutting the public
right-of-way. A revised landscape plan must be submitted prior to recording the final short plat.
The site is located within the Renton School District, they have indicated that they can handle the proposed 2
additional students.
The existing storm water runoff sheet flows to the west across the site and eventually is collected in one of the
existing stream channels. The surface water runoff that will be created as a result of the construction will be
directed to a series oflevel spreaders, detention would not be required on this site.
The project is located within the City of Renton water and sewer service areas. There is an 8-inch water main in
South 9th Street and a 4-inch water main in Renton Avenue S. There is an existing 8-inch sewer main fronting
the site in Renton Avenue S. Separate sewer stubs will be provided to each building lot prior to recording of the
short plat.
Defoor Short Plat
File No.: LUA-05-089, SHPL-H
October 17, 2006
Page 4
Debra Ricci, 1601 Second Avenue, Ste. 1080, Seattle, W A 98101 stated the engineers at Pace felt that they
could modify the width of the lots to conform with the 50-foot provision, they just need a little extra time to
make those adjustments.
Jason Walker, Talasaea Consultants, 15020 Bear Creek Road NE, Woodinville, WA 98077 stated that he is a
landscape architect and environmental planner with Talasaea.
Regarding buffer averaging, there is a little over 10,150 square feet of buffer reduction that has been proposed to
reduce the buffers to their minimum allowable dimension under the Code. There is 30,000 square feet available
in the open space tract to accommodate the buffer replacement.
Drainage 1 is proposed to be relocated into Stream A, which has a very rounded channel, it is not incised and
has more flow capacity to handle increase in flow rates. Drainage 1 is an eroded channel and they are proposing
to reconvey that channel to a pre-existing structure at the mouth of Stream A which also receives storm water
runoff from that stream. That will help to stabilize and stop the erosion of that drainage. Stream A would also
be enhanced with a number of native plants that have soil binding properties.
Stream B, also proposed to be enhanced, is experiencing erosion from stormwater flows. Stream B is more
significantly disturbed as far as erosion and is highly incised. The proposal is to provide approximately 20
pieces of large woody debris within that channel to provide energy dissipation for the stormwater.
Stream C is in a remote comer of the site and will not be affected by any of these proposals.
The proposed grading plan shows that they will be leveling the frontages of the lots to bring vehicular entry up
to Renton Avenue S. It appears to be exceeding 12 yards of fill. The plan appears to be stair stepped so that
they will have a daylight basement house with a garage entry located at street level.
Bill Collins, 420 Cedar Avenue S, Renton, W A 98055 stated that they were concerned with during and after
construction and how any introduced fill would be prevented from introducing itself into the buffer setbacks,
Stream A and B setbacks. The sides are very steep and a retaining wall will have to be built up to the edge of
the stream buffers.
Jason Walker stated that there would be wall systems available that could be placed with minimal impact to the
streams. It appears from the drawings that there would be six to seven feet of fill. Without the final design, he
could not be positive how it would actually be handled.
Kayren Kittrick, Development Services stated that Renton Avenue is wide enough there is no need for any
addition to it. It will have to be verified that there is 20-feet of pavement to the north for access.
The water line and fire flow requirements have been reviewed both by Staff and the Fire Department and is well
taken care of.
The stream buffers are the first thing to be marked when construction starts, double fencing is put up so that it is
impossible to go beyond it, they try to minimize the errors. Without building plans it is difficult to say what is
really going to happen with the walls and fill. With 12-feet offill, there will have to be an engineered wall or
rockery. A condition could be that the engineered wall must be in place before the final recording.
Cedar Avenue stops at that location, it was never intended to go through. She did not believe that there was a
dedicated right-of-way there.
Defoor Short Plat
File No.: LUA-05-089, SHPL-H
October 17, 2006
PageS
Jill Ding stated that she did some calculations on the lots and the lot line between Lots 2 and 3 could be adjusted
to meet the required lot width.
The Examiner called for further testimony regarding this project. There was no one else wishing to speak, and
no further comments from staff. The hearing closed at 10:25 a.m.
FINDINGS, CONCLUSIONS & RECOMMENDATION
Having reviewed the record in this matter, the Examiner now makes and enters the following:
FINDINGS:
1. The applicant, Terry Defoor, filed a request for a short plat.
2. The yellow file containing the staff report, the State Environmental Policy Act (SEP A) documentation
and other pertinent materials was entered into the record as Exhibit #1.
3. The Environmental Review Committee (ERC), the City's responsible official issued a Determination of
Non-Significance -Mitigated (DNS-M).
4. The subject proposal was reviewed by all departments with an interest in the matter.
5. The subject site is located at 900 Renton Avenue South. The subject site is located on the southwest
comer of the intersection of Renton Avenue and South 9th Street. The parcel is located on Renton Hill,
east and upslope ofI-405.
6. The map element of the Comprehensive Plan designates the area in which the subject site is located as
suitable for the development of single-family uses, but does not mandate such development without
consideration of other policies of the Plan.
7. The subject site is currently zoned R-8 (Single Family - 8 dwelling units/acre).
8. The subject site was annexed to the City with the adoption of Ordinance 1547 enacted in June 1956.
9. The subject site is approximately 140,723 square feet or 3.2 acres in size. The subject site is trapezoidal
in shape with the south property line slanting from the southeast toward the northwest. The parcel is
approximately 329 feet wide (east to west) by approximately 491 feet deep.
10. The subject site has complex topography. The site slopes downward to the west from Renton Avenue at
an average grade of 26%. The site also contains landslide hazard areas, erosion hazard areas, both
protected and sensitive slopes and coal mine hazard areas. Since the average slopes exceed 20% the
subject site is classified as a "Hillside Subdivision." The "Hillside Subdivision" categorization required
submission of additional geotechnical information, detailed grading information and larger lots, if
appropriate. The applicant proposes importing approximately 7,000 cubic yards offill material and
grading approximately 7,100 cubic yards including approximately 100 cubic yards of cut.
11. Four unmapped streams and an unmapped wetland are located on the subject site. The applicant has
appealed the classification of three of those streams and that appeal is pending before the City Council.
Three of the streams cross the site at its eastern property line (Drainage 1, and Streams A and B), while
Defoor Short Plat
File No.: LUA-05-089, SHPL-H
October 17, 2006
Page 6
the fourth, Stream C, runs across the northwest comer of the site for a short distance. The streams and
their CITY CLASSIFICATIONS and buffers from south to north are:
Drainage 1: Class 4; 35-foot buffer
Stream A: Class 4; 35-foot buffer
Stream B: Class 3; 75-foot buffer
Stream C: Class 4; 35-foot buffer
In addition, Wetland B is located in the northeast comer of the site. It is approximately 196 square feet
and generally centered on Stream B. It is designated as follows:
Wetland B: Category 3; 25-foot buffer
12. Since the appeal of the stream classifications are still pending, the applicant submitted a short plat based
on the City's classifications. The plat would work around and with the streams by using buffer
averaging, rerouting Drainage 1 and creating five, somewhat irregularly shaped lots that all front along
Renton Avenue. Buffer averaging would allow a reduction in the buffers to 25 feet for Class 4 streams,
Stream A, and 37.5 feet for Class 3 streams, Stream B. The location of Stream C, in the northwest
comer of the parcel, would not be affected by the proposed platting. Wetland B, a Category 3 wetland,
would be unaffected as it is located entirely within the buffer proposed for Stream B. In addition, the
majority of the subject site would be left undisturbed in protected areas containing the steeper slopes,
coal mine areas, and enlarged stream buffer areas. No development on the subject site is proposed north
of Stream B and there would be no reason to reduce its buffer between the stream and the north property
line.
13. Staff noted that approximately 25 percent of existing vegetation along the eastern portion of the subject
site where the five lots would be developed would be cleared of vegetation. Some areas of the five
private lots would contain required buffer areas and staff recommended that those be protected along
with other undeveloped portions of the site into a Native Growth Protection Easement. Code also
requires two trees be planted in each front yard and that there be landscaping in the street right-of-way.
14. Proposed Lots 1,2 and 3 (north to south) would be located south of Stream B and its narrowed 37.5 foot
buffer and north of Stream A and its narrowed 25 foot buffer. Proposed Lots 4 and 5 would be located
south of Stream A. Proposed Lot 4 would be located in the area where Drainage 1 would be relocated
into Stream A.
15. In keeping with the hillside subdivision requirements, all of the proposed lots exceed the R-8 zone's
required 4,500 square feet with lots ranging in size between 7,137 square feet to 10,198 square feet. As
staff noted, the Proposed Lots 1 and 2 appear to be narrower than the required 50-foot average for width
but that Proposed Lot 3 appears to have sufficient width to allow an appropriate adjustment to the other
two lots. This adjustment would modestly alter the lot area calculations but all of the lots already
exceed 4,500 square feet. The open space tract would be 96,919 square feet.
16. Access to all the lots would be via Renton Avenue. Grading will be done to create appropriate driveway
grades and reasonable building pads. The applicant proposes constructing retaining structures adjacent
to the stream buffer areas. This would create trench-like, unnatural slopes adjacent to the creeks.
17. The density for the plat would be 1.67 dwelling units per acre after subtracting sensitive areas such as
the steep slopes, coal mine and wetland areas. This falls below the generally accepted range of 4 to 8
Defoor Short Plat
File No.: LUA-05-089, SHPL-H
October 17, 2006
Page 7
units per acre but is the result of the constraints found on the site including the creeks, their buffers, the
other sloping areas and access issues.
18. The subject site is located within the Renton School District. The project is expected to generate
approximately 2 school age children. These students would be spread across the grades and would be
assigned on a space available basis.
19. The development will increase traffic approximately 10 trips per unit or approximately 50 trips for the 5
single-family homes. Approximately ten percent of the trips, or approximately 5 additional peak hour
trips will be generated in the morning and evening.
20. Stormwater currently sheet flows to the west in general. Some would enter the various drainages that
flow east to west across the site. The ERC imposed drainage requirements if detention were determined
to be required. Level spreaders would collect and disperse runoff resulting from the proposed
construction on the site. Downspouts would be tightlined.
21. Sewer and water service will be provided by the City. The applicant will have to meet fire flow
requirements for single-family homes and such requirements depend on home size and other factors that
will be determined when building plans are submitted.
22. The City has adopted mitigation fees for transportation improvements, fire services and parks and
recreational needs based on an analysis of the needs and costs of those services. These fees are applied
to new development to help offset the impacts new homes and residents have on the existing community
and the additional demand for services.
CONCLUSIONS:
1. The proposed plat appears to generally serve the public use and interest. The applicant has attempted to
design a plat that works around a number of site constraints and severe site constraints. Currently, three
water features affect the more level, developable area of the subject site. The wetland has minimal
impact since it is wholly contained within a proposed narrowed stream buffer. Similarly, Stream C is
located out of the proposed development envelope and does not affect the site. The coal mine and
protected slopes will be confined to a Native Growth Protection Easement. This leaves the eastern one-
third of the site for development. The proposed buffer averaging allows the applicant to make use of the
site in an almost reasonable fashion, although staff noted, some lots will have to be reconfigured to
provide appropriate width.
2. The construction of improvements to retain and define the slopes and narrowed buffers along the
streams should be more natural and blended or terraced even if this means the homes have to be
designed to take advantage of the more natural or stepped slopes or are constrained by creating more
gradual slope changes. The streams should be treated as natural, or, at least, aesthetic features of the
subject site rather then be hemmed by either vertical rockeries or concrete walls. The required buffer on
the north side of Stream B shall not be reduced as a result of constructing this plat.
3. The reduced density on this clearly compromised parcel appears appropriate. As noted, there are coal
mine hazards, steep slopes, wetland and creeks all affecting the subject site. Creating five lots may even
be taxing the site given its constraints but the applicant is entitled to some reasonable use of its
approximately three-acre parcel. Given the constraints the reduced density appears as an acceptable
tradeoff.
Defoor Short Plat
File No.: LUA-05-089, SHPL-H
October 17, 2006
Page 8
4. The development will create infill development in an area where urban services are available. The
development will increase the tax base to help offset some of the impacts that the development will
create on the City but those taxes will not completely reduce the impacts of new homes and their
residents.
5. The development will increase the demands on the City's parks, roads and emergency services. The
applicant shall therefore help offset those impacts by providing mitigation that matches the fees
established by the City.
6. The applicant will have to provide appropriate onsite landscaping and street frontage landscaping per
code requirements.
7. All required buffers shall be clearly delineated and incorporated into a Native Growth Protection
easement even if they fall within any of the proposed five lots.
8. In conclusion, the proposed plat appears to provide a reasonable development scenario for this
compromised parcel subject to the conditions enumerated below.
DECISION:
The proposed Short Plat is approved subject to the following conditions:
1. The applicant shall comply with the conditions imposed by the ERC.
2. The proposed short plat map shall be revised to show each lot with a minimum width of 50-feet. The
revised short plat map shall be submitted to the Development Services division project manager prior to
the approval of the final short plat.
3. A homeowner's association or maintenance agreement shall be created concurrently with the recording
of the plat in order to establish maintenance responsibilities for this development. A draft of the
document(s), if necessary, shall be submitted to the City of Renton Development Services Division for
review and approval by the City Attorney and Property Services section prior to the recording of the
short plat.
4. A Transportation Mitigation Fee based on $75.00 per net new average daily trip attributed to the project
shall be paid prior to the recording of the short plat. Each new lot is expected to generate approximately
9.57 new average weekday trips. The fee for the proposed short plat is estimated at $3,588.75 ($75.00 x
9.57 trips x 5 lots = $3,588.75).
5. A revised Wetland Study, Stream Assessment, Habitat Study, Watershed Restoration and Mitigation
Plan shall be submitted to the Development Services Division project manager for review and approval
prior to the approval of the final short plat. The revised report shall include an onsite buffer averaging
plan for the proposed impacts to the buffers of Streams A and B.
6. A revised short plat map showing a Native Growth Protection Easement over the proposed open space
tract and the side yard areas of Lots 1,3, and 4 where the stream buffer extends into the side yards shall
be submitted to the Development Services Division project manager prior to the approval of the final
short plat. The Native Growth Protection Easement shall be recorded prior to or concurrent with the
recording of the finals short plat map.
Defoor Short Plat
File No.: LUA-05-089, SHPL-H
October 17, 2006
Page 9
7. The Native Growth Protection Easement shall be delineated with a split rail fence and identified with
signage as approved by the Development Services Division Project Manager. A fencing and signage
detail shall be submitted to the Development Services Division project manager at the time of Utility
Construction Permit for review and approval and that such fencing and signage shall be installed prior to
the recording of the final short plat.
8. A revised conceptual landscape plan shall be submitted to the Development Services Division project
manager prior to the recording of the final short plat showing a minimum 5-foot wide planting strip
along Renton Avenue S.
9. A Fire Mitigation Fee based on $488.00 per new single-family lot shall be paid prior to the recording of
the final short plat. The fee is estimated at $2,440.00 (5 new lots x $488.00 = $2,440.00).
10. A Parks Mitigation Fee based on $530.76 per each new single-family lot shall be paid prior to the
recording of the final short plat. The fee is estimated at $2,653.80 (5 new lots x $530.76 = $2,653.80).
11. The construction of improvements to retain and define the slopes and narrowed buffers along the
streams shall be more natural and blended or terraced even if this means the homes have to be designed
to take advantage of the more natural slopes or are constrained by creating more natural slope changes.
The streams shall be treated as natural, or, at least, aesthetic features of the subject site rather then be
hemmed by either vertical rockeries or concrete walls.
ORDERED THIS 17th day of October 2006
TRANSMITTED THIS 17 th day of October 2006 to the parties of record:
Jill Ding
1055 S Grady Way
Renton, W A 98055
Bill Collins
420 Cedar Avenue S
Renton, WA 98055
Eric & Karen Bernard
PO Box 59306
Tukwila, WA 98138
Debra Eby Ricci
Attorney at Law
1601 Second Avenue, Ste. 1080
Seattle, W A 98101
Pat Conger
1301 S 9th Street
Renton, W A 98055
Tim Burkhardt
4927 197th Avenue E
Bonney Lake, W A 98390
Jason Walker
Talasaea Consultants, Inc.
15020 Bear Creek Road NE
Woodinville, W A 98077
Ruth Larson
714 High Avenue S
Renton, W A 98055
Brian Beaman
Icicle Creek Engineers
230 NE Juniper Street
Issaquah, W A 98027
Defoor Short Plat
File No.: LUA-05-089, SHPL-H
October 17, 2006
Page 10
Michael Chen
Core Designs, Inc.
Maryann Reinhart
GeoEngineers
Hugh Mortensen
Watershed Company
1410 Market Street
Kirkland, W A 98033
14711 NE 29th Place, Ste. 101
Bellevue, W A 98007
8410 154th Avenue NE
Redmond, W A 98052
TRANSMITIED THIS 17 th day of October 2006 to the following:
Mayor Kathy Keolker
Jay Covington, Chief Administrative Officer
Julia Medzegian, Council Liaison
Gregg Zimmerman, PBPW Administrator
Alex Pietsch, Economic Development
Jennifer Henning, Development Services
Stacy Tucker, Development Services
King County Journal
Stan Engler, Fire
Larry Meckling, Building Official
Planning Commission
Transportation Division
Utilities Division
Neil Watts, Development Services
Janet Conklin, Development Services
Pursuant to Title IV, Chapter 8, Section 100Gofthe City's Code, request for reconsideration must be filed in
writing on or before 5:00 p.m., October 31, 2006. Any aggrieved person feeling that the decision of the
Examiner is ambiguous or based on erroneous procedure, errors of law or fact, error in judgment, or the
discovery of new evidence which could not be reasonably available at the prior hearing may make a written
request for a review by the E~aminer within fourteen (14) days from the date of the Examiner's decision. This
request shall set forth the specific ambiguities or errors discovered by such appellant, and the Examiner may,
after review of the record, take further action as he deems proper.
An appeal to the City Council is governed by Title IV, Chapter 8, Section 110, which requires that such appeal
be filed with the City Clerk, accompanying a filing fee of$75.00 and meeting other specified requirements.
Copies of this ordinance are available for inspection or purchase in the Finance Department, first floor of City
Hall. An appeal must be filed in writing on or before 5:00 p.m., October 31, 2006.
If the Examiner's Recommendation or Decision contains the requirement for Restrictive Covenants, the
executed Covenants will be required prior to approval by City Council or final processing of the file. You
may contact this office for information on formatting covenants.
The Appearance of Fairness Doctrine provides that no ex parte (private one-on-one) communications may occur
concerning pending land use decisions. This means that parties to a land use decision may not communicate in
private with any decision-maker concerning the proposal. Decision-makers in the land use process include both
the Hearing Examiner and members of the City Council.
All communications concerning the proposal must be made in public. This public communication permits all
interested parties to know the contents of the communication and would allow them to openly rebut the
evidence. Any violation of this doctrine would result in the invalidation of the request by the Court.
The Doctrine applies not only to the initial public hearing but to all Requests for Reconsideration as well as
Appeals to the City Council.