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PRELIMINARY PLAT - 1
BEFORE THE HEARING EXAMINER FOR THE CITY OF RENTON
RE: Cyprus Lane Preliminary Plat
Preliminary Plat and Street
Modification
LUA21-000287, PP, MOD
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FINDINGS OF FACT, CONCLUSINS OF
LAW AND FINAL DECISION UPON
REHEARING
SUMMARY
The Final Decision of the above-captioned matter issued on November 23, 2022 is re-
adopted and remains unchanged, except as supplemented with the information provided in this Final
Decision Upon Rehearing.
A rehearing was held on January 18, 2022 due to defects in the public notice of hearing for
the original hearing held on the plat application on November 23, 2021. The additional testimony
provided at the rehearing was primarily focused upon public requests for additional information on
the project. The hearing transcript, Appendix A, provides a good outline of the information
exchanged at the hearing.
In addition to the information requested at the hearing, neighboring property owners also
requested that Pasco Ave NE just north of the project site be fully developed as an alternative
connection point to the plat. Neighbors also requested that the sewer mains be installed at sufficient
depth to avoid the need for grinder pumps for homes to the north. As outlined in the Conclusions of
Law below, some accommodation for sewer main depth can be made during the civil review of the
project so long as the depth is a proportionate response to the needs created by the proposal. As
further outlined in the Conclusions of Law, the City is statutorily and constitutionally barred from
requiring the Applicant to make off-site improvements to Pasco Ave NE.
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PRELIMINARY PLAT - 2
Exhibits
Exhibits 1-19 identified in the exhibit list presented by City staff at the rehearing were
admitted into the record. The following documents were also admitted during the rehearing:
Exhibit 20: Public rehearing notice.
Exhibit 21: November 23, 2021 Final Decision
Exhibit 22: Recording of November 23, 2021 hearing.
Testimony
A computer-generated transcript of the hearing has been prepared to provide an overview of the
hearing testimony. The transcript is provided for informational purposes only as Appendix A.
Findings of Fact
1. Findings Adopted by Reference. Findings of Fact No. 1-5 of the November 23, 2021 Final
Decision are adopted by reference as if set forth in full.
2. Setting of Rehearing. A rehearing was held on the subject preliminary plat application on
January 18, 2022. The rehearing was ordered by the hearing examiner by email order dated
December 15, 2021 due to a defect in the hearing notice for the November 23, 2021 hearing. Ex. 17.
Specifically, the City’s address program erroneously only provided addresses for properties within
30 feet of the project site as opposed to 300 feet. Id. The November 23, 2021 Final Decision was
also vacated in the same email order. Id.
3. Rehearing Testimony. As outlined in the Summary section of this Final Decision Upon
Rehearing, comments made at the rehearing were primarily focused upon inquiries about road
connectivity, availability of sewer connections and tree protection. Requests were limited to
ensuring that the proposed sewer main extensions were deep enough to facilitate gravity flow to
properties north of the project site and also for exterior extension of Pasco Ave NE to connect to the
plat’s interior road network.
4. Sewer Main Depth. In setting the required depth for sewer mains, City public works staff
consider a multitude of factors that involves a balancing of the expense to the developer and the
benefits to the public. Those factors were outlined in the following exchange between the Hearing
Examiner and Mr. Janders (Renton public works) during the rehearing:
Hearing Examiner:
Okay. And Mr. Janders, a question I have for you then, I mean, do the city's
engineering standards specify how you evaluate required depth? Is there anything
specific or is it one of those things that's left to engineering judgment?
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PRELIMINARY PLAT - 3
Mr. Janders:
So our side sewers and sewer stubs do have requirements for depth. I believe it's
three feet minimum at property lines. The sewer main, I would have to go take a
look back. I don't have that off the top of my head. It is pretty typical for standard. It
is gravity main, but individual grinder pumps are a necessity on a lot of lots when
depth becomes too... It's just not attainable.
Hearing Examiner:
How's the decision made if you go deeper then? Are you weighing the cost of goin g
deeper versus the cost of grinder pumps? Is that the kind of analysis that goes into
it or I mean, what are the factors that are considered there?
Mr. Janders:
That would be one that could be considered. Maintainability of systems as well
needs to be considered for maintenance crews to be able to access service and
maintain the lines as well as material, ensuring that the materials are suitable for
various depths. So I think what is being questioned is an individual lot where full
engineering has not been done. The proposal does not take into account the
elevations of all properties to the north at this point, is this a one off property? Is it
the entirety of the block?
Mr. Janders:
And the ability to use grinder pumps though is also considered. And grinder pumps,
like I have said, are used and it is standard practice to use them where necessary at
individual lots when gravity cannot be achieved. I think further assessment with the
developer would be something to look into as to what would the depth be th at is
being requested.
5. Pasco Ave NE: According to the uncontested testimony of Jill Ding at rehearing, Pasco
Ave is unimproved along the frontage of two adjoining lots that collectively adjoin the north
property line of the project site.
Conclusions of Law
1. Conclusions adopted by reference. Conclusions of Law No. 1-29 of the November 23, 2021
Final Decision are adopted by reference as if set forth in full.
2. Sewer Main Depth. The depth required by the City for the proposed sewer main will be
appropriately ascertained during civil review of the proposal by balancing the factors identified in
Finding of Fact No. 4.
As noted in Finding of Fact No. 3, concerns were expressed at the hearing about ensuring that the
water main be installed at a depth sufficient to facilitate gravity flow to neighboring properties.
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PRELIMINARY PLAT - 4
Unfortunately, the City likely cannot make the developer incur significant additional costs solely for
the benefit of other property owners. There is no direct case law on this issue for utility lines, but the
principle is clearly laid out in road circulation cases. As a matter of constitutional due process and
takings law, developers cannot be required to dedicate land to create road connections solely for the
benefit of pre-existing landlocked properties since the developer has not created and therefore is not
responsible for that condition. See, e.g., Luxembourg Group v. Snohomish County, 76 Wn. App.
502, review denied, 127 Wn.2d 1005 (1995). Similarly, the Applicant cannot be made to bear
substantial added expense in increasing sewer main depth solely for the benefit of other property
owners.
As noted in the case law above, the road connections cannot be required “solely” for the benefit of
land locked parcels. Road connections can often be justified on the basis that th e developer also
benefits from the road connection by improved road connectivity and emergency access. Arguably,
some reciprocity is also inherent in sewer main connection improvements directed at facilitating
connections with neighboring properties. Oversizing mains and increased depth requirements can be
justified on the basis that the developer benefits from these requirements being previously imposed
upon other property owners upstream from the project. However, case law also imposes a
proportionality requirement on project mitigation. A city is barred by the takings clause from
requiring a developer to mitigate more than its own proportionate share of impacts. See Dolan v.
City of Tigard, 512 US 374 (1987); RCW 82.02.020. Consequently, a developer could not be
required to incur an exorbitant amount of extra expense to help neighbors avoid the cost of grinder
pumps. The factors the City uses to consider required depth during civil review, as described in
Finding of Fact No. 4, adequately address the proportionality requirements that likely apply to
mainline depth requirements. No specific requirements for depth can be imposed by this decision
because the record is not developed enough to make that determination1.
3. Pasco Avenue Connection. There is no basis for requiring off-site street improvements to
Pasco Ave NE.
At the rehearing, one neighbor requested that off-site improvements be used to connect Pasco Ave
NE to the north side of the project in the unimproved road area identified in Finding of Fact No. 5.
As determined in the November 23, 2021 decision, the plat meets all plat design requirements as
they apply to the preliminary plat conceptual stage of development review. The plat already
includes two access points. There is nothing in the record that establishes that an additional access
point is necessary or warranted for the project. In the absence of any evidence establishing a need
for the third road connection, no such additional connection can be required. See, e.g., Benchmark
Land Co. v. City of Battle Ground, 146 Wn.2d 685, 49 P .3d 860 (2002)(record must contain
1 The City has the burden of proof in suppo rting the need for mitigation of development impacts. See Isla Verde Int'l
Holdings, Inc. v. City of Camas , 146 Wash.2d 740, 761 (2002); RCW 82.02.020. The City has not presented any
set of facts supporting a requirement for a sewer main depth, since the City conducts that analysis during the civil
review of the preliminary plat.
761 (2002).
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PRELIMINARY PLAT - 5
substantial evidence that subdivision will increase traffic along adjoining road within no direct
access to require frontage improvements).
DECISION
The Final Decision of the above-captioned matter issued November 23, 2022 is re-adopted
and remains unchanged, except as supplemented with the information provided in this Final
Decision Upon Rehearing.
DATED this 10th day of February, 2022.
City of Renton Hearing Examiner
Appeal Right and Valuation Notices
RMC 4-8-080(G) classifies the application(s) subject to this decision as Type III applications
subject to closed record appeal to the City of Renton City Council. Appeals of the hearing
examiner’s decision must be filed within fourteen (14) calendar days from the date of the decision.
A request for reconsideration to the hearing examiner may also be filed within this 14-day appeal
period.
Affected property owners may request a change in valuation for property tax purposes
notwithstanding any program of revaluation.