HomeMy WebLinkAboutAppendix A - Renton October 29 Medical Shell
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Appendix A
October 29, 2024 Hearing Transcript
Site Plan and Reasonable Use -- PR24-000052
Note: This is a computer-generated transcript provided for informational purposes only. The
reader should not take this document as 100% accurate or take offense at errors created by the
limitations of the programming in transcribing speech. A recording of the hearing is available at
the City of Renton Community and Economic Development Department should anyone need an
accurate rendition of the hearing testimony.
Examiner Olbrechts: (00:04):
Perfect. I think we're official. Okay. For the record, it's October 29th, 2024, 11:00 AM at Res Hearing
Examiner for the City of Renton and holding a hearing this morning on project file number PR 24 dash 0
0 0 5 2, which is a consolidated applications for hearing exam or site plan review, a reasonable use
exception and a street modification for one story medical office building. So the hearing format is, we'll
start off with a presentation from staff and who's going to be our staff person today It looks like Mr.
Morgan Roth. Are you there? Yep, he's ready to go. He'll give us a summary of the staff report he put
together and the proposal. Once Mr. Morgan Roth is done, we'll move on to the applicant. It looks like
Mr. Funk there is representing the applicant today. He'll have an opportunity to speak Mr. Funk if you
want to after Mr. Rogen Roth is done.
(00:56):
It's not mandatory but if you want to add anything you feel free to do so. Once we're done with the
applicant comments then we'll move on to public comments and it looks like we might have some
members of the public today. We'll see once we get to that part of the hearing and we'll explain how
everyone who wants to say something today, we will be able to have that opportunity. Once we're done
with the public comments, we go back to Mr. OV to answer any questions that were raised and Mr.
Morgan Roth can also add rebuttal evidence as he finds necessary to complete the record. Then the
applicant, Mr. Font gets final word. I get 10 business days. That's usually turns out to be a couple weeks
to issue that final decision at this point. Ms. Cisneros, can you show us the exhibit list and I'll go over the
exhibits real quick.
(01:40):
Projects like this take a lot of work and a lot of documentation reports, that kind of thing. And here we
have an exhibit list put together by Mr. Morgan Roth on all the plans he found pertinent to the review
criteria for these applications, which includes the environmental review. That was a determination by
the city after reviewing all the environmental impacts on whether an environmental impact statement
was necessary and the determination was made that it wasn't, which is pretty typical for a project of this
small scale. We have the site plan, architectural elevations, color rendering, trash enclosure plans,
landscape plan, drainage plans, arbor's plan to tree retention worksheet, geotechnical analysis,
preliminary technical information report, which is probably drainage and we also have a critical area
there, a stream. And so there was some assessment on how to address with impacts to that the trip
generation for traffic impacts. There was a street modification request, concurrency memo, which deals
with whether or not the city's traffic congestion standards are met. Basically we got one public comment
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which was from the Duwamish tribe and that's been addressed at least staff has tried to address those
comments through its cultural resource mitigation measures. And then we have some advisory notes
from the city. So that's exhibits one through 20. And I know Mr. Dero, you've got a couple more you'd
like to throw in there.
Speaker 1 (03:06):
Yes,
Examiner Olbrechts: (03:07):
There they are. Let's see. So we also have the staff report of which is, that's the report. Mr. Morgan Roth
will be summarizing the environmental review determination of nons significance. That's the decision
that an environmental impact statement is not necessary. And finally, just a few more exhibits. 23,
Speaker 1 (03:25):
Oh I think I have the wrong page, I'm sorry.
Examiner Olbrechts: (03:26):
Oh, there we go. And then we also have the staff PowerPoint, the city of Renton maps, which would be
aerial photographs and zoning maps, that kind of thing, that planning information about the project site.
And finally Google Earth giving us some aerial photographs of the project site. So in total we have a total
of 25 exhibits At this point, just want to ask if anyone has any objection to their entry in the record. If
you're participating virtually, just hit click the raise hand button at the bottom of your screen if you need
to see any of these documents or have any objection to their entry. The documents are available at the
city's website if you look up a hearing examiner. Okay, hearing, seeing no objections, we'll admit Exhibits
one through 25. Mr. Morgan Roth, let me swear you in. Just raise your right hand. Do you swear or
affirm to tell the truth, nothing about the truth in this proceeding?
Speaker 3 (04:11):
I do.
Examiner Olbrechts: (04:11):
Okay, great. Go ahead.
Speaker 3 (04:13):
Okay, thanks Mr Lexander. One second. Let me share my PowerPoint here. Alright, you guys got that all
right?
Examiner Olbrechts: (04:29):
Yeah, looks good.
Speaker 3 (04:30):
Okay, perfect. Thank you. Well, hello, I'm Alex Morgan Roth, principal planner with the city going to be
making a staff recommendation for a project known as the medical office show, building L Uua 24 0 0 0
2 1 8 is our file number. A little bit about the project site. I've got a map down there and just keep in
mind for anyone listening from the public or anyone else, all these exhibits are available online. So I
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know it's a little bit small in the PowerPoint, but you might look at any of these a little bit bigger. You
can do that after the hearing. So again, sites highlighted there, just south of Northeast Sunset Boulevard,
the corner of Northeast Sunset and Anacortes Avenue Northeast. It does has one street frontage along
Sunset there, it's about 0.81 acres zoning is commercial arterial. And then our Urban Design District D
overlay, which is a design district that's applicable to all of our zoning, commercial mixed use,
comprehensive plan, land use designation. Right now it's an undeveloped site, mostly kind of packed
gravel and some unmaintained vegetation. So no building structures, anything else there right now as
far as critical areas, we've got sensitive slopes and then there's a type F stream we'll get into a little bit
more later that cuts across the southeast corner of the site.
(05:51):
So the applicant's proposing environmental review, hearing examiner site plan review, reasonable use
exemption or variance used interchangeably here in a street modification. And this project is for, they're
proposing an office building specifically for probably a medical use. So under our code we have kind of
medical office as a use and that's usually dental veterinarian, maybe kind of small like outpatient
doctor's office, things like that. So one story building, 5,200 square feet, 25 foot max height, the top of
the highest roof peak there. And again for future medical use, no, my understanding in the applicant can
address this later, but no current tenants lined up, but just kind of planning for a future 1 26 surface
parking stalls proposed. Now they're proposing access via one driveway off of Northeast Sunset
Boulevard. They're proposing improvements along Northeast Sunset Boulevard. So that's a sidewalk and
a planter strip. The street modification is not for the improvements or for the pedestrian improvements,
it's for keeping the current curb to curb width of sunset.
(07:03):
Our transportation department reviewed that section, determined that we don't really need any wider
there. So they're still doing the required improvements. The landscape strip with street trees and the
new sidewalk, they're just not moving the curb line there. So staff is supportive of that request. And
then the reasonable use variance or exemption exemption, it's a request to encroach approximately 62
feet into the Honey Creek buffer. And again, I'll get a little bit more into this later, but just for tho se
listening to the reasonable use variance is essentially, it is kind like a typical variance, although it's
specifically for critical areas and allows an applicant to request that to modify buffers to critical areas
that might not otherwise be allowed for our critical areas regulations. And it's really for sites like this,
like this site and staff's opinion, that development would be a really big challenge if you strictly applied
the buffers. There's also other considerations that we look at. How is the buffer functioning right now
for the critical area In this case it's a stream. What will the improvements, will they improve the
ecological function of the stream section on the site? But that's kind of what this is. So it's the
requesting basically the ability to encroach further into that buffer than might otherwise be allowed per
our code.
(08:29):
Here's the site plan. Again, you can see this a little easier in the PDF, you pull it up after, but you've got
the building along northeast Sunset Boulevard meeting all of our setbacks. You've got a driveway
entrance to the west of the building and then you've got the surface parking lot to the south and then a
couple spots to the west of the building. And again, we'll get into this more. We can kind of see the line
there to the south side of the site. That's basically the new buffer line, which would be 40 feet. And you
can see the stream, the delineated stream on the very, it just kind of cuts across the corner there. It
comes from the site to the east stream where McDonald's is, it's piped under there, it's lighted on this
site, piped a little bit on the next site and then goes under sunset.
(09:11):
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So it is a type F stream meaning that it's considered, it could be fish bearing. I think it'd be challenging
for fish to get through a lot of these culverts and stuff. But that's where the stream is located, kind of
where it goes there. Here's some elevations of the building as you getting see the 25 foot max height is
on the northwest corner there near the entrance you've got, they're mostly CMU materials in multiple
colors, which you'll see in the rendering coming up next. Metal canopies, metal paneling along the
facades. A decent amount of modulation, articulation of the facade. So overall a nice looking building
that generally conforms with our urban design standards for this zone. I'll just jump back really quick to
the site plan. It actually has two entrances to the building. I'm sorry, not two primary entrances. Then a
few more on the backside here.
(10:04):
So you got the primary one off of sunset is right in this little corner here. There's also another entrance
off the parking lot here. And then I think two more over a little further that connect up to the sidewalk
there. So perhaps opportunities for multiple tenants or just if there needs to be deliveries or other staff
entrances, things of that nature. So it's kind hard to see on the elevations. I just wanted to call that out.
Here's a rendering of looking, I guess this would be southeast. So you can see kind of this is the main
pedestrian entrance there with the sidewalk connection to a little mini plaza. You can see the material
variation there, the large upper story windows, which we like just to help again, break up that facade.
You got the metal canopies there and then kind the shed style roof.
(10:56):
So about zoning, so this is our Highlands Planning and Area community planning area ca zone, just
commercial arterial as far as zoning around the area, so you've got zoning basically southeast and west.
You've got mostly commercial uses there. The one except to that is to the east, I'm sorry, the west
where there is a single family house. It is zoned, it is in a ca zone, but it's located I think about 150 feet
from the building. There's a lot of vegetation on that site that does a pretty good job screening to the
north. We got R mfs, that's residential multifamily across Sunset Boulevard there. And then as far as the
use of medical office are permit permitted outright in the ca zone critical areas you can see, got a little
bit of slope in the back but really not much. And then you've got the stream, which is that yellow line
Honey creek is what it's known as Type F stream. The standard buffer is 115 feet. That's from measured
from the ordinary high watermark. And then you typically have a 15 foot structure setback from that
buffer where you couldn't have any structures. You can kind of see here where the stream goes under
an artists under the McDonald's site daylight, a little bit piped again, a little bit daylighted again and it
kind of goes back and forth until it goes north of sunset there.
(12:23):
So site plan review, one of the requested reviews there will took a look at primary access. So again
accessing off of northeast sunset into that surface parking lot with 26 stalls. There's a lot of new
landscaping proposed, especially compared to what's out there now. Mostly between the street and the
building and around the perimeter of the site actually pretty substantial landscaping as you can see
here. Q minus does not show the landscaping proposed that white area. That'll be the mitigation for this
in the stream buffer, there's a separate, they'll submit a final plan for that, so they'll take a look at it.
That'll include all native plants and things that'll help promote the health of the stream. This is just for
the onsite or non-critical area, non buffer area, a lot of parking lot landscaping as well. One of the
concerns we can talk about more, but just a quick overview is just with customer vehicular circulation
and delivery.
(13:16):
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So we were just looking at this, we didn't obviously have turning movements and stuff and showing, but
we looked a little with these kind of angle and spots as a little concern of how someone would come in
there and then maybe they look back out and if they would kind of get trapped or make it difficult to get
out the parking lot's full. So there's a condition related to that, just asking for basically a traffic
circulation analysis or it might take amending the site plan of we're just changing the parking lot,
reconfiguring it a little bit, but it's not for sure a problem. It's just look, be looked at it a little bit and
measured a couple things and it looked like it might be a little tricky for cars to get in and out of there.
And the other concern related to the parking lot as part of the site plan review was the delivery area.
(13:58):
So medical use can get testing stuff or other things that kind of daily deliveries. Usually not large trucks
but smaller ones. So just making sure again that there's not just a total any pedestrian vehicular conflicts
in the parking lot when you've got delivery trucks coming in and out and people trying to back in and out
of these angled stalls. So think just maybe a little more work on that. And there were just a little more
analysis on that from the applicant demonstrating that that will work and maybe where they plan to
have those deliveries. So there's a condition, a recommended condition related to that, then you've got
a garbage enclosure there in the back of the site. We just want to get something from Republic Services,
the garbage and recycling provider that says that they're okay with this location or how it's going to
work just because they often have issues with accessing sites where it's kind of tight like this. So they did
submit a traffic, they impact analysis with 130 new daily trips that didn't include many trips. I think it
was four during the am I think in six during the PM peak hour or something like that. Single digits. So no
substantial impact to traffic. And so there was no specific traffic mitigation recommended as part of the
environmental review.
(15:15):
So reasonable use variance. So kind of went into it a little bit. But basically what they're requesting is to
provide a 40 foot as opposed to 115 foot, a 40 foot enhanced reduced buffer pursuant to what our code
allows. So again, part of the reason their justification for this is that if you applied the full maximum
buffer plus the building setback, that would eat up about two thirds of the site by the time you build in
setbacks required landscaping, parking, it would make it the applicant that would make it about
impossible to build a viable commercial building there. And I will say we've worked with them. I've had a
number of free apps on this, I've worked with 'em on this for a while. I know the applicant, Mr. Fox
worked on it for a while. I think this is a good after reviewing the mitigation plan and the stream
assessment from the biologist, which basically documented that the stream is not in good shape there
right now it's just kind of debris, black invasive Himalayan Blackberry, the buffers completely degraded
essentially.
(16:20):
And again, it's, it's not providing, considering its pipe on either side, that makes it challenging as well
and is what you can do to improve the ecological value. But they did submit the stream assessment,
which we looked at and that did, the biologists did concur that this would be a substantial improvement.
Talking about planting native plants and removing the invasives garbage, installing the cedar rail fencing
that would protect it. Doing the native growth protection easement. All of that would really contribute
to a much higher quality stream buffer, even though it's reduced over what the standard would be. So
I'm not going to get into all this, but these are kind of the five criteria we looked at and did find. I did
find that they met the criteria there. And so recommending approval of that reasonable use variance
pending the final mitigation plan that we would review as part of the civil construction permit.
(17:17):
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So this is again, we will require a very conceptual plan at this time. So we can see the buffer there. 40
feet, you can see where the max buffer, or sorry, the standard buffer would be, how that would come all
the way up there. And so it's about 40, 4500 square feet of buffer enhancement and that there's going
to be more landscaping outside the buffer. We just don't count it as technically part of the buffer just
because the type of plants use and being so close to the parking lot there. And then again, they will
submit a final mitigation plan at a later time.
(17:53):
So some of the key project features I wanted to call out. So significant landscaping across the site, the
stream buffer enhancement, we want them to retain at least one landmark tree on the site. That's a
condition of approval. And then the high quality design and proposed building, I think they definitely put
some effort in try to meet the design standards with the different materials used and the use of the
metal canopies, the large upper story windows, things of that nature. So we will review the design a
little bit more when building permit comes in, understanding that some changes occasionally happen
between the landings entitlement and the building permit, but do expect it to end up looking pretty
close to this environmental review. So as you mentioned, Mr. Examiners did go through environmental
review with the city acting as the CPA lead agency. So determination of not significant mitigate was
issued on September 30th. No appeals were filed. We did get one comment as you noted from the
Duwamish tribe as part of the land use public comment period. And that was just related to the
potential discovery of artifacts.
(19:06):
That was the environmental review committee took that recommended mitigation measure. I'm not
going to read through each, I kind of do a really high level summary of each one of these, but there's 13
conditions of approval that staff is recommending. First ones related to retaining one of the trees that's
on the site just to make sure we're meeting our tree retention requirements, requiring a screening detail
for any proposed surface or roof mounted equipment at a later time that comes in the letter from the
garments and recycling service, just that they're okay with the location of that. A little more info on the
bike parking we wanted to see just to make sure complying with our bike parking requirements, a
lighting plan, want to see that for the site that shows actually kind of photo metrics and stuff. The
service area screening detail. We did ask for the sidewalk connecting, sorry, the private sidewalk.
(20:05):
So the private pathway that they proposed connecting the front door with the public sidewalk being
widened to six feet just to give a little more room is it just looked a little tight there, especially for
people in wheelchairs, stuff like that possibly coming in. And it gives a little more room for potentially
adding things like a bench, which is actually the next condition. We're looking just for maybe a little
more, they did show a few things there, but a couple more options proceeding against, again, just
considering what the use is here, asking for materials board to be submitted so we can take a little
better look at the materials before construction, the traffic circulation analysis demonstrating how
vehicles will safely enter, exit the site. Talked about that a little bit. And then the last three, the loading
delivery area again talked about that. A licensed letter from a geotech engineer saying that they've
reviewed the construction plans and the specs of the building meet their intent.
(21:00):
And then the last is related to a sewer easement, which we were fairly certain is on the site. We just
want to have documentation of that sewer easement. So our public works review, we can take a look at
it and then if there is no easement, making sure that gets recorded prior to issuing a C of O. And then
lastly, the long condition, but making sure we have a paid access to that sewer manhole on the site just
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so we can access it. Other than that, those are the 13 mitigation measures. So I'm recommending
approval of the medical office shell site plan and reasonable use variance and street modification
subject to those conditions. And I'm happy to answer any questions.
Examiner Olbrechts: (21:39):
Okay. Yeah, I think at the beginning of your presentation you said they were proposing about a 60 or 62
foot encroachment into the stream buffer, but the staff report notes that it gets 40 feet at the closest
point to the ordinary high water mark. And I noticed later in your presentation you said that they
wanted to have a 40 foot buffer. So what was the 62 foot encroachment referring
Speaker 3 (22:00):
To that? Well, I think that might've been, so the 62 feet was the 115. It was basically the closest, how do
I explain this? So if you took, you can see my screen, the 115, it's about 62 feet and it's basically the
edge of the parking lot. They called it a 40 foot buffer. It's really more of like a 40, probably four foot
buffer. They're not actually proposing any paving in this area. They just didn't really counter as the
buffer because it's so close to the parking lot essentially. It's still going to be vegetation. It's just where
the actual cedar rail fence is going to be. That's at the 40 feet
Examiner Olbrechts: (22:35):
Okay's
Speaker 3 (22:35):
One of our stand. Yeah, just around.
Examiner Olbrechts: (22:38):
So the encroachment really is more like 75 feet, isn't it? If you're going all the way up to 40 feet from the
ordinary high water mark, you have 115 foot buffer.
Speaker 3 (22:49):
Yes, I've written poorly. So basically the 75 feet, yes, it would be all the way to the fence. I guess I was
trying to imply that I didn't get right. Didn't articulate that very well, is that the parking lot itself? The
actual last on the site would be at that 62 feet above.
Examiner Olbrechts: (23:07):
Oh, okay. So between that edge and the cedar fence, it's going to be natural. Basically
Speaker 3 (23:11):
A little buffer for the buffer essentially.
Examiner Olbrechts: (23:13):
So you're,
Speaker 3 (23:14):
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It'll be some vegetation in there, the plane, the actual buffer or the cedar rail that is going to be the 40
feet. So yeah, apologize for that.
Examiner Olbrechts: (23:21):
No, I was just trying to understand what's going on there. And kind of a more complicated question, and
this is something I always struggle with, the reasonable use for commercial use is the minimum
reasonable use requirement. Obviously you have a smaller building, you get less parking required. That
could be of significant benefit to the stream itself. I mean you determine that the proposed size is
minimum reasonable use here.
Speaker 3 (23:45):
Yeah, great question. So you hit around the head, the reasonable use exemption or variance process
that we have is, I don't want to say it's a gray area, but we don't have, there's no exact way to calculate
what would be considered a reasonable use. And I'm not going to lie that it's a totally objective way of
doing it, but there's not really any other way to do it. So typically what we look at and more often we get
reasonable use requests for a single family, which you could argue is a little bit easier. Everyone kind of
knows what is a normal size single family house you would need for family of four in renting. Maybe
you'd be looking at a 3, 2 1500 square feet. Okay, that's easy. But you're right, it is a little trickier for a
commercial. For this one we looked at, okay, what are some of the other zone properties developed
with around here? Most of 'em have larger buildings and most of 'em have, the stream is piped. So they
don't, when they did that, it was okay back then it would not be, most of the development around this
wouldn't be allowed under current code.
(24:49):
That's a little bit we look at is comparing under the previous code, what could they do? How do we kind
find the middle ground between the current code, which again really restricts this owner's ability to
develop this in a similar fashion as the other properties nearby. And a lot of it's just kind of finding the
balance. And so the other factor too is what is the actual stream buffer to look like? In this case, again,
the site's been vacant for decade or more, Mr. Kwan can talk about that. It's been heavily degraded just
from development around it. So that's partly what we look at too is it's a little bit of a trade off, I guess.
Can we get some better ecologically functioning, buffer and stream with providing, again, the
reasonably sized, the reasonably dense whatever kind of use you're looking at development away from
it. So kind of a roundabout way of saying, yeah, we look at a few different factors. I don't have a formula
though to say, oh, that we landed on 5,200 square feet. I will say we did work with the applicant, they
did have more intense proposals at other times, and I think 5,200 square feet was kind of landed on as
kind of the smallest viable medical office building you could have with the required parking that meets
our parking requirements. And with the required setbacks and landscaping and all of that,
Examiner Olbrechts: (26:16):
I mean, can you kind generally compare this building size to other building sizes in the vicinity, both in
terms of just commercial buildings and then maybe more specifically medical office. Can you make any
observations about that? Yeah,
Speaker 3 (26:29):
We've had, so I, not necessarily right in this area, but in the ca zone, similar zone, I've had a medical
office, this is small, I would say more often you're seeing them probably in the 75, 10,000 square foot for
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an urgent care or even maybe not a veterinary clinic. Those are oftentimes a little bit smaller. There's
not another medical office right by this site. I'll tell you, McDonald's is bigger.
Examiner Olbrechts: (26:59):
Okay, that's my next question. Yes, totally
Speaker 3 (27:01):
Different use obviously.
Examiner Olbrechts: (27:02):
Right, right. But it is bigger
Speaker 3 (27:04):
To that. Yeah, you look at this building and you look at the surrounding kind of development pattern for
commercial buildings, it's on the far small
Examiner Olbrechts: (27:12):
End. Okay. That's,
Speaker 3 (27:13):
So with the medical building, you also get, you have more large testing equipment, you need separate
rooms. It'd be a little different if this was more of an offsite service where it's just a couple offices and
you don't have customers coming to it, maybe an HVAC repair or something could have a really small
little footprint and then they just kind of do their work out of there. So I think it is about as small as you
can get, again, have a economically viable medical office, whether that's again, urgent care, dental or
anything like that.
Examiner Olbrechts: (27:46):
Okay, sounds good. No, I know it's a tough issue. I've dealt with it a few times before and I mean, unless
you actually had some economists or something do a business analysis of all the comparable medical
clinics in the city and what the smallest sizes were, you can't get much better information. So no, that's
really good. Thank you. Alright, well let's move on to the applicant. Mr. Funk, did you want to add
anything at this point?
Speaker 1 (28:10):
Hope. I think you're muted.
Examiner Olbrechts: (28:11):
Yeah, you're muted, sir. Yeah. Mr. Funk, I'll have to swear in. Just raise your right hand. You swear affirm
to tell the truth, nothing but the truth in this proceeding.
Speaker 1 (28:18):
I do.
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Examiner Olbrechts: (28:19):
Okay, great. Go ahead.
Speaker 1 (28:21):
I think Alex has made a very thorough and accurate presentation. We've had the report in our hands for
a few days anyway, maybe four or five days. We've read through it myself and the other members of our
team and we've not seen anything in there that seems like it would be onerous to comply with. So
basically we're good with it.
Examiner Olbrechts: (28:47):
Okay, thank you sir. Pretty straightforward. Alright, well let's move on to public comments at this point.
And we do have a lot of attendees, but they may all be part of the applicant team. It's hard to tell at this
point. If anybody wants to add anything at this point, click on the raise hand button at the bottom of
your screen. Not seeing any takers yet. Mr. Cisneros, do you see anyone who wants to say anything at
this point?
Speaker 1 (29:10):
I do not, but I'm just kind of
Examiner Olbrechts: (29:11):
Oh, sure. Yeah, yeah, let's do it.
Speaker 1 (29:13):
Anybody would like to comment
Examiner Olbrechts: (29:20):
Still? No takers. Okay. Yeah, it looks like from the names I see, it looks like they may all be applicant
team and that's just fine. I will say if there's somebody out there who's trying to participate and you just
can't figure out how, go ahead and email Ms. Cisneros there. She's got her email address right behind
her, jay cisneros renton.wa.gov. I'll give the applicants then an opportunity to and staff an opportunity
to respond to those emailed comments and then consider that as part of the decision just to get those
comments in by 5:00 PM tomorrow. And again, that's only if you're having technical problems today and
can't figure out how to participate today. So I guess with that, since we haven't had any public
comments, I can go ahead and close the hearing at this point. And like I said, I have 10 business days to
issue that decision.
(30:05):
It seems to meet all the criteria pretty well. I think, as you probably gathered from my discussion with
Mr. Morgan Roth, a reasonable use process is a fairly subjective process and especially when it comes to
figuring out minimum reasonable use. But I think Mr. Morgan Roth provided some really useful
testimony so that I can make the conclusion it is minimum reasonable use and it meets the reasonable
use criteria. So we'll get that approval out within the next 10 business days. Assuming we don't get any
new comments coming in by tomorrow if something pertinent comes in from the public and that could
make a difference. But from the information I have so far, I think it's a pretty good chance I'll be issuing
an approval. So thanks all for participating and we're adjourned. Have a great day.