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HomeMy WebLinkAboutC_Pre-application Interpretation Letter_01242023 January 24, 2023 City of Renton Department of Community and Economic Development Planning Division 1055 South Grady Way, 6th Floor Renton, WA 98057 425-430-7200 RE: Code Interpretation: PRE 22-000411 Planning Staff: A pre-application meeting (PRE 22-000411) for a small new construction project located at 400 S. 43rd Street (Valley Medical Center Campus) was held on January 19th, 2023 at 10:00am. The proposed project is a new 500 square foot accessory use storage building. CLARK | BARNES PLLC prepared Meeting Minutes which are attached for reference. During the meeting it was conveyed by City Planner Andrew Van Gordon, that the proposed 500 gross square foot development would trigger SEPA Environmental Review per RMC 4-9-070, as well as site plan review per RMC 4-9-200(B)(2)(a), refer to section 5.7 of Meeting Minutes. We believe this evaluation to be inaccurate, since the proposed project satisfies the categorical exemption identified by RMC 4-9- 070(G)(1)(c). RMC 4-9-070(G)(1)(c): For office, commercial, or service buildings in WAC 197-11-800(1)(b)(iv): four thousand (4,000) square feet or less of gross floor area; changes of use of four thousand (4,000) square feet or less when located in an existing office, commercial, or service building of four thousand (4,000) square feet or larger. 1. Justification The proposed building, which is 500 gross square feet, is under the 4,000 square foot threshold identified by RMC 4-9-070(G)(1)(c). Furthermore, nothing in the code (Renton Municipal Code or Washington Administrative Code) suggests that the area requirement is accumulative among multiple existing buildings on the same site or is based upon accumulative use for an entire site, which is what was stated during the pre-application meeting and noted on page 5 of the DCED memorandum provided to the applicant prior to the meeting. The memorandum section states: Environmental Review: The proposal would require environmental review pursuant to the State Environmental Policy Act (SEPA) as the gross square floor area of the use exceeds 4,000 square feet of floor area. The RMC 4-9-070(G)(1)(c) code section identifies two separate exemption conditions governed by area thresholds – one for buildings less than 4,000 gross square feet, and the other for change of use less than 4,000 gross square feet. The proposal is for a new building under 4,000 gross square feet. We believe the reference provided within the DCED memorandum is a misinterpretation of the code, as it appears to January 24, 2023 CLARK | BARNES 2 combine the language from both exemption conditions. “Gross square floor area of the use” does not appear in the code. RMC 4-9-070(G)(1)(c) specifically states “gross floor area”, and gross floor area as defined in Chapter 2 of the current 2018 International Building Code is “The floor area within the inside perimeter of the exterior walls of the building under consideration”. The code is referring to a singular building (new or existing) and not an accumulative area. 2. Conclusion Because the proposed building is less than four thousand (4,000) square feet, we believe the project complies with the code language and intent outlined by local exemption ‘c’ per RMC 4-9-070(G)(1)(c) and is therefore a SEPA Exempt Development per RMC 4-9-200(C)(2)(b). As a SEPA Exempt Development, the project should also be exempt from Site Plan Review. The purpose of this letter is to confirm with the City Planning staff that our interpretation of the RMC 4-9- 070(G)(1)(c) code section is correct and that SEPA and Site Plan Review are not required for the proposed development. Respectfully, W. Scott Clark, Partner, AIA, NCARB, AIBC CLARK | BARNES PLLC CC: Thomas McDaniel – Valley Medical Center Becky Hardi – Valley Medical Center Andrew Van Gordon – City of Renton Planning Division Chip Vincent – City of Renton Planning Division 1.1 Meeting Minutes Project: VMC Haz-Mat Storage Building Meeting Date: January 19, 2023 Meeting Location: Microsoft Teams Meeting Meeting Attendees: Andrew Van Gordon (AG), Planner, City of Renton Scott Warlick (SW), Public Works, City of Renton Corey Thomas (CT), Fire Prevention, Renton Regional Fire Authority Thomas McDaniel (TM), Senior Project Manager, Valley Medical Center Becky Hardi (BH), Manager, Valley Medical Center Johnathon Cave (JC), Project Manager, Clark|Barnes ITEM ACTION 2.0 Schedule 2.1 Pre-application meeting held on 01/19/2023 @ 10:00am INFO 3.0 General Discussion 3.1 Andrew Van Gordon (AG) (City planner) hosted and led the meeting INFO 3.2 Attendee introductions INFO 4.0 Project Description 4.1 The scope of work consists of building a new 500 sf, Type V-A construction, single-story accessory use storage building within the existing Valley Medical Center Campus located at 400 South 43rd Street. INFO 5.0 Pre-application Discussion 5.1 Cory Thomas (CT) reviewed the fire-related requirements for the project outlined in the pre-application memo. The preliminary fire flow is 1,500 gpm, and two fire hydrants are required. Based on the existing site documentation, there are sufficient fire hydrants to meet the requirement. Fire impact fees are $0.15 per square foot of storage space and is due at the time of building permit issuance. An approved fire sprinkler and fire alarm VMC Haz-Mat Storage Building CLARK | BARNES Page 2 of 3 Meeting Minutes 01/24/23 system is required for the building. Existing fire department access roadways will be maintained. COR 5.2 A Hazardous Materials Inventory Statement is required before building permit issuance. COR · Johnathon Cave (JC) to follow up with (CT) via email to determine if the level of information shown in our feasibility narrative for the existing material inventory is sufficient for the Hazardous Materials Inventory Statement. C|B 5.3 Scott Warlick (SW) reviewed the water, sewer, storm drainage and transportation/ street requirements for the project outlined in the pre-application memo. Domestic fixtures, i.e. eye wash station, will require a new ¾” domestic meter with a reduced pressure backflow assembly. As noted by (CT), an approved fire sprinkler system is required for the building, and a dedicated fire service line from the existing 12” water main will be needed. As a result, the existing water main may need to be extended. As noted in the pre-application memo for sewer and storm drainage, any service lines that are currently running under the proposed building will need to be re-routed around the new building foundation. Utility line separation requirements were provided and address the design teams pre-app question. COR · (JC) and Becky Hardi (BH) asked if there were any exceptions for the re-routing of the existing sewer and storm drainage lines under the proposed site, as the cost to relocate those utilities will drastically impact whether or not the project moves forward. (SW) explained that an exception would be unlikely, but requested that the design team follow up with an email and (SW) would review in further detail and discuss with other Public Works Department staff. C|B 5.4 (SW) noted in the pre-application memo for transportation that the proposed project does not trigger frontage improvements. COR 5.5 (AG) reviewed the general land use requirements for the project outlined in the pre- application memo. Because the scope of work consists of constructing a new building, the project will need to demonstrate how the existing parking complies with the parking requirements for new construction. COR 5.6 (AG) explained that because the scope of work includes the removal a significant tree located in the middle of the site (trees greater than 6-inch caliper), a tree inventory and retention plan, as well as an arborist report shall be provided as part of the land use application. COR 5.7 (AG) noted that because the gross square floor area of the use of the property exceeds 4,000 square feet, SEPA environmental review would be required. As a result of developing in the CO Zone per RMC 4-9-200, Administrative Site Plan Review would also be required. (AG) explained that Site Plan Review and approval would be needed prior to submitting for the Building and Land Use permits; however, SEPA VMC Haz-Mat Storage Building CLARK | BARNES Page 3 of 3 Meeting Minutes 01/24/23 environmental review can be submitted and reviewed in tandem with the Site Plan Review. COR · (BH) and (JC) asked for clarification on the exceptions for SEPA and Site Plan Review. (AG) explained that the project would only be exempt from Site Plan Review if SEPA environmental review was not required. (JC) explained that per RMC 4-9-070(G)(1)(c), the project is under the 4,000 gross square footage threshold, and (BH) noted that per previous conversations and review with Renton Senior Planner Clark Close, a building under 4,000 gross square feet would be exempt from Site Plan Review, on the basis that it would be a SEPA Exempt Development per RMC 4-9-200(C)(2)(b). (BH) asked (AG) for clarification on whether this prior exemption was strictly due to the fact that the proposal at that time was an addition and not a new structure. (AG) explained that he could not provide clarification for a determination provided by another reviewer for a separate project. (JC) stated that he would review the municipal code sections pertaining to categorical exemptions and SEPA Exempt Development and follow up with (AG) and the rest of the team via email or official letter. · (BH) asked (AG) what the anticipated review timeline would be for the Administrative Site Plan Review if required. (AG) responded with 6-8 weeks from the application submittal. C|B 5.8 (JC) asked for clarification on which permits would be applicable to the proposed project, as outlined in the applicant’s pre-application letter (in particular separate permits for Civil Construction, Grading, and Preload/Site Prep). (AG) explained that it would be best to either send a follow up email to (SW) asking for confirmation of the required permits or reaching out to a Renton permit tech. (JC) to follow up. C|B · (AG) explained that it would be best to either send a follow up email to (SW) asking for confirmation of the required permits or reaching out to a Renton permit tech. (JC) to follow up. COR Prepared By: Issued: 01/24/23 Johnathon Cave, CLARK | BARNES These meeting minutes represent CLARK | BARNES understanding of the items discussed at the meeting. We shall rely upon the contents unless notified of any discrepancies or inaccuracies within one week of the final issuance date posted at the end of these minutes.