HomeMy WebLinkAbout6. Variance request justification v2Application for three-year Administrative Variance
Renton Highland Manor
3612 NE 4th Street, Renton, WA 98056
APN: 0923059176
Variance Request Justification
Request #1: Allow an exception to the requirement that minimum distance
between mobile homes shall be 15 feet in cases where the rear end walls of two
mobile homes abut each other back to back
Explanation of request:
o 24 of the community’s 49 homes are located on lots which abut other lots,
back to back
o Specifically, these 24 homes are the 24 homes that are located closest to
the eastern boundary of the property.
o The back of each of these lots is separated from the abutting lot by a 2’6”
common area sidewalk
o In almost all cases, the existing home on the lot uses essentially the entire
depth of the lot. The rear end wall of the home is typically located
approximately 12” from the rear lot line. There is then a 2’6” separation
(due to the common area sidewalk). There is then approximately 12” to
the rear end wall of the abutting home.
o Thus, in practice, the total distance between the rear end walls of the two
homes is typically 4’6” (12” setback + 2’6” sidewalk + 12” setback)
o In practice, when bringing in new homes, it would be impossible to expand
this existing 4’6” distance to the 15’ distance required per RMC 4-2-HOE.
o The reason it is impossible to comply with the 15’ distance requirement is
because of the small size of the existing lots, and the comparatively large
size of the smallest manufactured homes that are commercially available.
o The depth of these lots ranges from 53’ to 56’.
o A typical scenario would be one where a resident wishes to bring in a new
home, but their existing rear-abutting neighbor is not prepared to
simultaneously upgrade their home, so the existing rear-abutting home
remains in place.
o In such a case, we would position the new home as far “forward” on the lot
as possible, in order to maximize the distance between the new home and
its rear-abutting neighbor.
o But even then, the distance to the rear-abutting home range from 1’ (on a
53’ lot) to 4’ (on a 56’) lot, plus the 2’6” for the existing sidewalk, plus 12”
from the sidewalk to the existing rear end wall of the neighboring home. In
total, the distance would be 4’6” to 7’6”.
o This does not meet the 15’ minimum distance standard, which is why a
variance is being sought.
North
“Allow an exception to the requirement that
minimum distance between mobile homes shall
be 15 feet in cases where the rear end walls of
two mobile homes abut each other back to back”
North
Requested alternative:
1) The minimum back-to-back distance between a new mobile home and an
existing mobile home shall be 5 feet.
2) The minimum back-to-back distance between two new mobile homes shall
be 10 feet.
Required showings:
1) The applicant suffers practical difficulties and unnecessary hardship
and the variance is necessary because of special circumstances
applicable to subject property, including size, shape, topography, and
location or surroundings of the subject property, and the strict
application of the Zoning Code is found to deprive subject property
owner of rights and privileges enjoyed by other property owners in the
vicinity and under identical zone classification.
o The applicant suffers practical difficulties: In practical terms, if this
variance is not granted, then for 26 of the mobile home park’s 49
lots, it will be impossible to replace obsolete mobile homes with
new homes, and those obsolete homes will remain in place
permanently. This constitutes a practical difficulty.
North
o The applicant suffers a hardship: The applicant is one of the very
few mobile home park owners who wants to upgrade their mobile
home park in order to provide high-quality, attractive, and safe
affordable housing. Obsolete aluminum 1960s mobile homes
present a heightened health and safety risk to residents, and
aesthetically detract from the neighborhood. To be permanently
saddled with these obsolete homes creates a hardship for the
applicant, as well as the applicant’s residents and neighbors. The
specific hardships can be described as heightened fire risk,
aesthetic blight, and economic hardship due to impact on rental
revenue.
o This hardship is unnecessary: This hardship can be readily avoided
by granting a waiver to the 15’ minimum distance requirement for
those specific lots where a 15’ minimum distance is physically
impossible to achieve.
o The variance is necessary because of special circumstances
applicable to the subject property, namely:
1. The small size of the mobile home lots at Renton Highland
Manor. These lots were designed and built in the 1950s,
prior to current zoning and building codes. And they were
designed for homes which were smaller than today’s
manufactured homes.
2. The peculiar lay-out of the mobile home lots at Renton
Highland Manor, including back-to-back lot configurations
which reduce the physical distance between units
o The strict application of the Zoning Code deprives the subject
property owner of rights and privileges enjoyed by other property
owners in the vicinity and under identical zone classification:
The ability to upgrade the mobile homes in a mobile home
park is a fundamental, routine, and ongoing component of
operating a mobile home park.
Mobile homes built in the 1960s are past their useful life.
They are obsolete, energy-inefficient, out of compliance with
current health and safety code, and need to be replaced.
Other mobile home park owners in the vicinity and under
identical zone classification have the right to replace
obsolete mobile homes with new homes.
Indeed, the City’s regulatory process for mobile homes
(including guidelines on how mobile home park owners are
allowed to install new homes) takes for granted a basic
proposition: that mobile home park owners have the right
and the privilege to remove obsolete homes from their parks
and replace those homes with new homes.
2) The granting of the variance will not be materially detrimental to the
public welfare or injurious to the property or improvements in the
vicinity and zone in which subject property is situated.
o The granting of the variance will allow obsolete, non-code-
compliant, eyesore mobile homes to be replaced by safe, attractive,
contemporary manufactured homes.
o This will not be materially detrimental to the public welfare or
injurious to the property or improvements in the vicinity and zone in
which subject property is situated.
o If anything, this will be beneficial to the public welfare and to the
property and improvements in the vicinity, because it will reduce the
risk of fire, beautify the community, and raise property values.
3) The approval does not constitute a grant of special privilege
inconsistent with the limitation upon uses of other properties in the
vicinity and zone in which the subject property is situated.
The approval does not constitute a special privilege for Renton
Highland Manor vis-à-vis other properties in the vicinity and
zone, because there is no change in density or change in use.
The existing use and existing density remains in effect – but will
be safer and more attractive.
This actually benefits the other properties in the vicinity and
zone.
4) The approval is the minimum variance that will accomplish the desired
purpose.
o Due to the small size of the lots at Renton Highland Manor, five feet
is the minimum back-to-back clearance that will allow us to install a
new home on a lot that backs up to an obsolete home.
Request #2: Allow an exception to the requirement that minimum distance
between mobile homes shall be 15 feet in cases where side-to-side clearances do
not permit 15 foot clearances
Explanation of request:
o Typical lots at Renton Highland Manor are 30’ to 32’ wide
o These lots must accommodate the width of a manufactured home, as well
as the width of a parked car
o The typical width of a manufactured home that is viable on these lots is 22’
10” (e.g. Skyline Westridge model E920CT) or 23’ 4” (e.g., Fleetwood
Weston Super Value model 24382V). Such homes accommodate three
bedrooms in orde to meet the needs of the existing residents at the
property, which primarily consist of families with four to six family
members per household.
o It is possible to obtain new manufactured homes that are 14’ or 15’ wide,
but such homes would be single-wide homes, park model RVs, or tiny
homes, with one or possibly two bedrooms, which does not meet the need
of the multi-generational family demographic at Renton Highland Manor.
o Homes that are 22’ 10” wide or 23’ 4” meet the demographic needs of our
resident population.
o In our experience managing 19 mobile home parks in 4 states, 8’ is the
minimum viable width for parking on a mobile home lot. Eight feet of width
will accommodate most vehicles
o After the 8’ of width for a driveway, the neighboring lot may have an
existing home on it which is essentially all the way up to the lot line. In
such a case, there would be a total of 8’ of distance between the two
manufactured homes.
North
“Allow an exception to the requirement that
minimum distance between mobile homes shall
be 15 feet in cases where side-to-side clearances
do not permit 15 foot clearances”
Requested alternative:
The minimum side-to-side distance between all mobile homes (new and/or
existing) shall be 8 feet for compliance with parking requirements, unless
the applicant provides a parking analysis that demonstrates compliance
with a minimum of two parking spaces per unit and provides a proposal for
North
North
where the tenants will park if 8 feet is not provided on either side of the
residence. If compliance with parking regulations can be adequately
demonstrated, 5 feet (between new and existing units) will be taken into
consideration until abutting units are replaced.
Required showings:
1) The applicant suffers practical difficulties and unnecessary hardship
and the variance is necessary because of special circumstances
applicable to subject property, including size, shape, topography, and
location or surroundings of the subject property, and the strict
application of the Zoning Code is found to deprive subject property
owner of rights and privileges enjoyed by other property owners in the
vicinity and under identical zone classification.
The applicant suffers practical difficulties: In practical terms, new
manufactured homes less than 22’10” wide are not viable on this
site. Thus, if this variance is not granted, then it will be impossible
to replace obsolete mobile homes with new homes, and the
obsolete homes will remain in place permanently. This
constitutes a practical difficulty.
The applicant suffers a hardship: The applicant is one of the very
few mobile home park owners who wants to upgrade their mobile
home park in order to provide high-quality, attractive, and safe
affordable housing. Obsolete aluminum 1960s mobile homes
present a heightened health and safety risk to residents, and
aesthetically detract from the neighborhood. To be permanently
saddled with these obsolete homes creates a hardship for the
applicant, as well as the applicant’s residents and neighbors. The
specific hardships can be described as heightened fire risk,
aesthetic blight, and economic hardship due to impact on rental
revenue.
This hardship is unnecessary: This hardship can be readily
avoided by granting a waiver to the 15’ minimum distance
requirement for those specific lots where a 15’ minimum distance
is physically impossible to achieve.
The variance is necessary because of special circumstances
applicable to the subject property, namely, the small size of the
mobile home lots at Renton Highland Manor. These lots were
designed and built in the 1950s, prior to current zoning and
building codes. And they were designed for homes which were
smaller than today’s manufactured homes.
The strict application of the Zoning Code deprives the subject
property owner of rights and privileges enjoyed by other property
owners in the vicinity and under identical zone classification:
The ability to upgrade the mobile homes in a mobile home
park is a fundamental, routine, and ongoing component of
operating a mobile home park.
Mobile homes built in the 1960s are past their useful life.
They are obsolete, energy-inefficient, out of compliance with
current health and safety code, and need to be replaced.
Other mobile home park owners in the vicinity and under
identical zone classification have the right to replace
obsolete mobile homes with new homes.
Indeed, the City’s regulatory process for mobile homes
(including guidelines on how mobile home park owners are
allowed to install new homes) takes for granted a basic
proposition: that mobile home park owners have the right
and the privilege to remove obsolete homes from their parks
and replace those homes with new homes.
2) The granting of the variance will not be materially detrimental to the
public welfare or injurious to the property or improvements in the
vicinity and zone in which subject property is situated.
The granting of the variance will allow obsolete, non-code-
compliant, eyesore mobile homes to be replaced by safe, attractive,
contemporary manufactured homes.
This will not be materially detrimental to the public welfare or
injurious to the property or improvements in the vicinity and zone in
which subject property is situated.
If anything, this will be beneficial to the public welfare and to the
property and improvements in the vicinity, because it will reduce the
risk of fire, beautify the community, and raise property values.
3) The approval does not constitute a grant of special privilege
inconsistent with the limitation upon uses of other properties in the
vicinity and zone in which the subject property is situated.
a. The approval does not constitute a special privilege for Renton
Highland Manor vis-à-vis other properties in the vicinity and
zone, because there is no change in density or change in use.
b. The existing use and existing density remains in effect – but will
be safer and more attractive.
c. This actually benefits the other properties in the vicinity and
zone.
4) The approval is the minimum variance that will accomplish the desired
purpose.
o As described above, the smallest viable home that we can place on
these lots is 22’10” in width. This is the minimum home size that
will accomplish the desired purpose. Given the configuration of the
existing lots, this will result in a minimum side-to-side clearance
between homes of 8’.
Request #3: Allow an exception to the requirement that the minimum distance
between a mobile home and a site-built service building shall be 15 feet
Explanation of request:
o Under RMC 4-2-HOE, there is 15’ of required distance between a mobile
home and a site-built service building
o At Renton Highland Manor, there is one site-built service building. It is a
cinderblock building, approximately 600 square feet, used for laundry and
storage.
o There are approximately 6 mobile home lots abutting the service building
o In the existing condition, as built, the homes on those lots do not uniformly
maintain 15’ of distance to the service building
o These lots were built before RMC 4-2-HOE was implemented, and the
homes were installed before RMC 4-2-HOE was implemented
o Maintaining 15’ of distance between new homes installed on these lots
and the service building would make it impossible to install new homes on
these lots
North
“Allow an exception to the requirement that the
minimum distance between a mobile home and
a site-built service building shall be 15 feet”
Requested alternative:
The units shall maintain a distance of at least 5 feet of separation on all
sides, for all units.
Therefore, the variance shall allow a distance of at least 5 feet
between a mobile home and the site-built service building
Required showings:
1) The applicant suffers practical difficulties and unnecessary hardship and
the variance is necessary because of special circumstances applicable to
subject property, including size, shape, topography, and location or
surroundings of the subject property, and the strict application of the
Zoning Code is found to deprive subject property owner of rights and
privileges enjoyed by other property owners in the vicinity and under
identical zone classification.
The applicant suffers practical difficulties: The existing mobile
home lots at Renton Highland Manor surrounding the service
building, which were built before RMC 4-2-HOE was
implemented, are configured in such a way that any new home
installed on those lots will violate RMC 4-2-HOE, because there is
not 15’ of clearance physically available. In practical terms,
maintaining a 15 foot minimum distance between a mobile home
North
Pre-code lots are configured so that
manufactured homes are sited less than 15’ from
the site-built service building
and the service building will make it impossible to install new
homes on those lots. Thus, if this variance is not granted, then it
will be impossible to replace obsolete mobile homes with new
homes, and the obsolete homes will remain in place permanently.
This constitutes a practical difficulty.
The applicant suffers a hardship: The applicant is one of the very
few mobile home park owners who wants to upgrade their mobile
home park in order to provide high-quality, attractive, and safe
affordable housing. Obsolete aluminum 1960s mobile homes
present a heightened health and safety risk to residents, and
aesthetically detract from the neighborhood. To be permanently
saddled with these obsolete homes creates a hardship for the
applicant, as well as the applicant’s residents and neighbors. The
specific hardships can be described as heightened fire risk,
aesthetic blight, and economic hardship due to impact on rental
revenue.
This hardship is unnecessary: This hardship can be readily
avoided by granting a waiver to the 15’ minimum distance
requirement for those lots abutting the service building where a
15’ minimum distance is physically impossible to achieve.
The variance is necessary because of special circumstances
applicable to the subject property, namely:
1) The small size of the mobile home lots at Renton
Highland Manor. These lots were designed and built
in the 1950s, prior to current zoning and building
codes. And they were designed for homes which were
smaller than today’s manufactured homes.
2) The presence of a site-built service building at Renton
Highland Manor
3) Existing lots abutting the service building, which are
configured such that homes installed on those lots will
be less than 15’ from the service building
The strict application of the Zoning Code deprives the subject
property owner of rights and privileges enjoyed by other property
owners in the vicinity and under identical zone classification:
The ability to upgrade the mobile homes in a mobile home
park is a fundamental, routine, and ongoing component of
operating a mobile home park.
Mobile homes built in the 1960s are past their useful life.
They are obsolete, energy-inefficient, out of compliance with
current health and safety code, and need to be replaced.
Other mobile home park owners in the vicinity and under
identical zone classification have the right to replace
obsolete mobile homes with new homes.
Indeed, the City’s regulatory process for mobile homes
(including guidelines on how mobile home park owners are
allowed to install new homes) takes for granted a basic
proposition: that mobile home park owners have the right
and the privilege to remove obsolete homes from their parks
and replace those homes with new homes.
2) The granting of the variance will not be materially detrimental to the public
welfare or injurious to the property or improvements in the vicinity and
zone in which subject property is situated.
The granting of the variance will allow obsolete, non-code-
compliant, eyesore mobile homes to be replaced by safe, attractive,
contemporary manufactured homes.
This will not be materially detrimental to the public welfare or
injurious to the property or improvements in the vicinity and zone in
which subject property is situated.
If anything, this will be beneficial to the public welfare and to the
property and improvements in the vicinity, because it will reduce the
risk of fire, beautify the community, and raise property values.
3) The approval does not constitute a grant of special privilege inconsistent
with the limitation upon uses of other properties in the vicinity and zone in
which the subject property is situated.
a. The approval does not constitute a special privilege for Renton
Highland Manor vis-à-vis other properties in the vicinity and zone,
because there is no change in density or change in use.
b. The existing use and existing density remains in effect – but will be
safer and more attractive.
c. This actually benefits the other properties in the vicinity and zone.
4) The approval is the minimum variance that will accomplish the desired
purpose.
o As described above, the existing condition includes homes that are
less than 15’ from the service building. A five foot distance is the
minimum variance that will allow new homes to be installed on
these sites while still maintaining adequate fire safety standards.
Request #4: Allow an exception to the requirement that minimum distance
between a mobile home and a public street shall be 20 ft.
Explanation of request:
o Under RMC 4-2-HOE, there is 20 feet of required distance between a
mobile home and any public street.
o At Renton Highland Manor, 16 of the 49 existing mobile home lots at
Renton Highland Manor abut a public street. Four homes abut NE 4th
Street, and 12 homes abut Queen Avenue NE.
o None of these 16 mobile homes have 20 feet of clearance to the public
street. In fact, many of them have zero feet of clearance to the public
street.
o In order to replace these obsolete homes with new homes, it will be
necessary to maintain the same positioning on the lot, which will require a
distance of less than 20 feet between the home and property line.
Requested alternative:
New units will not be placed within the 30 foot City of Renton utility
easement on Queen Avenue.
No setback from the utility easement will be required.
Therefore, any new units abutting Queen Street may extend
eastward as far as the utility easement, but shall extend no further
eastward than the utility easement.
For other street frontages (i.e. NE 4th Street), the minimum street frontage
setback shall be 10 feet.
1) The applicant suffers practical difficulties and unnecessary hardship and
the variance is necessary because of special circumstances applicable to
subject property, including size, shape, topography, and location or
surroundings of the subject property, and the strict application of the
Zoning Code is found to deprive subject property owner of rights and
privileges enjoyed by other property owners in the vicinity and under
identical zone classification.
The applicant suffers practical difficulties: Sixteen of the 49
existing mobile home lots at Renton Highland Manor abut a public
street. These mobile home lots, which were built before RMC 4-
2-HOE was implemented, are configured in such a way that any
new home installed on those lots will violate RMC 4-2-HOE,
because there is not 20’ of clearance physically available between
these homes and the public street. In practical terms, maintaining
a 20 foot minimum distance between a mobile home and the
public street will make it impossible to install new homes on those
lots. Thus, if this variance is not granted, then it will be impossible
to replace obsolete mobile homes with new homes, and the
obsolete homes will remain in place permanently. This
constitutes a practical difficulty.
The applicant suffers a hardship: The applicant is one of the very
few mobile home park owners who wants to upgrade their mobile
home park in order to provide high-quality, attractive, and safe
affordable housing. Obsolete aluminum 1960s mobile homes
present a heightened health and safety risk to residents, and
aesthetically detract from the neighborhood. To be permanently
saddled with these obsolete homes creates a hardship for the
applicant, as well as the applicant’s residents and neighbors. The
specific hardships can be described as heightened fire risk,
aesthetic blight, and economic hardship due to impact on rental
revenue.
This hardship is unnecessary: This hardship can be readily
avoided by granting a waiver to the 20’ minimum distance
requirement for those lots abutting the public street, when a 20’
minimum distance is physically impossible to achieve.
The variance is necessary because of special circumstances
applicable to the subject property, namely:
1) The location of the existing lots at Renton Highland
Manor in relation to public streets. These lots were
designed to abut Queen Avenue (with zero feet of
clearance), and to be separated from NE 4th Street by
the width of the sidewalk, which is approximately 5’.
The strict application of the Zoning Code deprives the subject
property owner of rights and privileges enjoyed by other property
owners in the vicinity and under identical zone classification:
The ability to upgrade the mobile homes in a mobile home
park is a fundamental, routine, and ongoing component of
operating a mobile home park.
Mobile homes built in the 1960s are past their useful life.
They are obsolete, energy-inefficient, out of compliance with
current health and safety code, and need to be replaced.
Other mobile home park owners in the vicinity and under
identical zone classification have the right to replace
obsolete mobile homes with new homes.
Indeed, the City’s regulatory process for mobile homes
(including guidelines on how mobile home park owners are
allowed to install new homes) takes for granted a basic
proposition: that mobile home park owners have the right
and the privilege to remove obsolete homes from their parks
and replace those homes with new homes.
2) The granting of the variance will not be materially detrimental to the public
welfare or injurious to the property or improvements in the vicinity and
zone in which subject property is situated.
The granting of the variance will allow obsolete, non-code-
compliant, eyesore mobile homes to be replaced by safe, attractive,
contemporary manufactured homes.
This will not be materially detrimental to the public welfare or
injurious to the property or improvements in the vicinity and zone in
which subject property is situated.
If anything, this will be beneficial to the public welfare and to the
property and improvements in the vicinity, because it will reduce the
risk of fire, beautify the community, and raise property values.
Indeed, from a neighborhood aesthetics perspective, the obsolete
mobile homes that abut the exterior property line are exactly the
homes that need to be replaced. These are the most visible
homes, and the neighborhood would benefit from having them
replaced.
3) The approval does not constitute a grant of special privilege inconsistent
with the limitation upon uses of other properties in the vicinity and zone in
which the subject property is situated.
a. The approval does not constitute a special privilege for Renton
Highland Manor vis-à-vis other properties in the vicinity and zone,
because there is no change in density or change in use.
b. The existing use and existing density remains in effect – but will be
safer and more attractive.
c. This actually benefits the other properties in the vicinity and zone.
4) The approval is the minimum variance that will accomplish the desired
purpose.
o As described above, the community was designed such that many of the
mobile homes literally abut Queen Avenue. Our desired purpose is to
replace obsolete homes with new, safe, code-compliant homes. Given the
dimensions of the lots, the location of the lots in relation to Queen Ave and
NE 4th Street, and the dimensions of commercially available manufactured
homes, the minimum variance that will accomplish the desired purpose is
the requested variance.