HomeMy WebLinkAboutD_Staff Report_and _Decision_Renton Highlands Manor VarianceDEPARTMENT OF COMMUNITY
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Staff Report_Renton Highlands Manor Setback Variance
A. ADMINISTRATIVE REPORT & DECISION
Decision: APPROVED PARTIALLY APPROVED, SUBJECT TO
CONDITIONS DENIED
Report Date: June 25, 2019
Project File Number: PR19-000181
Project Name: Renton Highland Manor Setback Variance
Land Use File Number: LUA19-000078, VA
Project Manager: Angelea Weihs, Associate Planner
Owner: Renton Highland Manor, LLC; 1232 19th St, Suite 17, Oakland CA, 94607
Applicant/Contact: Daniel Weisfield, 1232 19th St, Suite 17, Oakland, CA 94607
Project Location: 3612 NE 4th Street
Project Summary: The applicant, Renton Highland Manor, LLC, is requesting a setback variance in order
to replace existing mobile home units within a mobile home park, Renton Highland
Manor, located at 3612 NE 4th Street (Parcel number 0923059176). The property is
located within the Commercial Arterial (CA) Zoning District and Commercial Mixed
Use (CMU) land use designation. The community is comprised of 49 existing
manufactured home lots. The site has street frontage on NE 4th ST to the south and
Queen Ave NE to the east. The applicant proposes to gradually replace existing
manufactured home units (built in the 1950s and 1960s) with new manufactured
homes. Per RMC 4-2-110E, mobile home parks constructed before August 1, 2010
require a minimum distance of 15 feet between mobile homes, a minimum distance
of 15 feet between a mobile home and a service building, and a minimum distance
of 20 feet between a proposed mobile home and a public street. The existing,
nonconforming manufactured units do not comply with these setbacks. In order to
replace the existing units, the applicant proposes a minimum back-to-back distance
of 5 feet between new and existing manufactured homes, a minimum side-to-side
distance of 5 feet between new and existing mobile homes, and a minimum 10 foot
setback between new manufactured homes and NE 4th Street. The applicant
proposes to maintain access to Renton Highland Manor via two existing curb cuts off
of NE 4th ST. No critical areas are mapped on the project site.
Site Area: 131,986 Square Feet (3 acre)
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
City of Renton Department of Community & Economic Development
Renton Highland Manor Setback Variance
Administrative Report & Decision
LUA19-000078, VA
Report of June 25, 2019 Page 2 of 10
Staff Report_Renton Highlands Manor Setback Variance
B. EXHIBITS:
Exhibit 1: Administrative Decision
Exhibit 2: Site Plan
Exhibit 3: Project Narrative
Exhibit 4: Variance Justification
Exhibit 5: Unit Floorplans
Exhibit 6: Unit Elevations
Exhibit 7: Advisory Notes
C. GENERAL INFORMATION:
1. Owner(s) of Record: Renton Highland Manor, LLC; 1232 19th St, Suite 17,
Oakland, CA 94607
2. Zoning Classification: Commercial Arterial (CA)
3. Comprehensive Plan Land Use Designation: Commercial Mixed Use (CMU)
4. Existing Site Use: Legal, Nonconforming Manufactured Home Park
5. Critical Areas: None
6. Neighborhood Characteristics:
a. North: Residential Multi-Family (RM-F) Zone; Multi-family housing
b. East: Queen Ave NE; RM-F Zone and CA Zone; Multi-family housing and Retail
c. South: NE 4th Street; Residential-8 (R-8) Zone; Cemetery
d. West: CA Zone; Auto Service and Repair, Nonconforming Single Family
7. Site Area: 131,986 Square Feet (3 acre)
D. HISTORICAL/BACKGROUND:
Action Land Use File No. Ordinance No. Date
Comprehensive Plan N/A 5758 06/22/2015
Zoning N/A 5758 06/22/2015
Annexation N/A 1480 04/29/1954
E. APPLICABLE SECTIONS OF THE RENTON MUNICIPAL CODE:
1. Chapter 2 Land Use Districts
a. Section 4-2-110: Residential Development Standards
2. Chapter 4 City-Wide Property Development Standards
3. Chapter 9 Permits – Specific
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City of Renton Department of Community & Economic Development
Renton Highland Manor Setback Variance
Administrative Report & Decision
LUA19-000078, VA
Report of June 25, 2019 Page 3 of 10
Staff Report_Renton Highlands Manor Setback Variance
a. Section 4-9-250: Variances, Waivers, Modifications, and Alternates
4. Chapter 11 Definitions
F. FINDINGS OF FACT (FOF):
1. The Planning Division of the City of Renton accepted the above master application for review on April 18,
2019, and determined the application complete on May 1, 2019. The project complies with the 120-day
review period.
2. The project site is located at 3612 NE 4th Street (Parcel number 0923059176).
3. The project site is currently developed with 49 existing manufactured home lots.
4. The applicant proposes to maintain access to Renton Highland Manor via two existing curb cuts off of NE
4th ST.
5. The property is located within the Commercial & Mixed Use (CMU) Comprehensive Plan land use
designation. The project complies with the goals and policies of this Comprehensive Plan land use
designation.
Compliance Comprehensive Plan Analysis
Policy L-3: Encourage infill development of single-family units as a means to meet
growth targets and provide new housing.
Goal HHS-H: Actively work to increase the availability of healthy, equitable, and
affordable housing for people in all demographic groups and at all income levels and
promote a balance of housing and the amenities needed by residents at a
neighborhood level, such as childcare, availability of fresh food, recreational
opportunities, and medical care.
6. The site is located within the Commercial Arterial (CA) zoning classification.
7. There are approximately 19 significant trees located on-site. No trees are proposed to be removed or
disturbed with this project.
8. No critical areas are mapped on the project site.
9. The applicant is proposing to begin construction for two of the homes (Lot 41 and 43; See Exhibit 2)
following land use and building permit approval.
10. Per RMC 4-2-110E, mobile home parks constructed before August 1, 2010 require a minimum distance of
15 feet between mobile homes, a minimum distance of 15 feet between a mobile home and a service
building, and a minimum distance of 20 feet between a proposed mobile home and a public street. The
existing, nonconforming manufactured units do not comply with these setbacks. The applicant is
requesting approval of a variance in order have a minimum back-to-back distance of 5 feet between new
and existing manufactured homes, a minimum side-to-side distance of 5 feet between new and existing
mobile homes, and a minimum 10-foot setback between new manufactured homes and NE 4th Street.
11. No public or agency comments were received.
12. The applicant requested that the variance be valid for three years after the date of decision. Staff
recommens approval of this request.
13. Representatives from various city departments have reviewed the application materials to identify and
address issues raised by the proposed development. These comments are contained in the official file,
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City of Renton Department of Community & Economic Development
Renton Highland Manor Setback Variance
Administrative Report & Decision
LUA19-000078, VA
Report of June 25, 2019 Page 4 of 10
Staff Report_Renton Highlands Manor Setback Variance
and the essence of the comments has been incorporated into the appropriate sections of this report and
the Departmental Recommendation at the end of this report.
14. Variance Analysis: The applicant is requesting a variance from RMC 4-2-110E in order to allow an
exception to the requirement that the minimum distance between mobile homes be 15 feet. The
applicant proposes to replace the units slowly over time.
The applicant requests that the minimum back-to-back distance between a new mobile home and an
existing mobile home be 5 feet, and that the minimum back-to-back distance between two replaced
mobile homes be 10 feet. Once all units are replaced, the minimum back-to-back distance for all units
would be 10 feet.
The applicant requests that the minimum side-to-side distance for mobile homes be 8 feet, except in cases
where 8-foot side-to-side clearance is not feasible between a new and existing mobile unit due to space
restrictions. The applicant requests that in cases where 8-foot side-to-side separation is not feasible, that
the City approve a 5-foot sided-to-side distance until both units are replaced. Once all units are replaced,
the minimum side-to-side distance for all units would be 8 feet.
The proposal is compliant with the following variance criteria, pursuant to RMC 4-9-250.B.5. Therefore,
staff recommends approval of the requested variance, with conditions.
Compliance Variance Criteria and Analysis
Compliant
provided
conditions of
approval are
met.
a. That 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, 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.
Staff Comment: Per King County Department of Assessments records, Renton Highlands
Manor mobile home park was originally built in 1958. The mobile home park is
nonconforming in regards to both land use and development standards. The existing
mobile homes do not comply with current mobile home park development standards.
In addition, the existing individual unit lot sizes do not comply with current requirements
for mobile home lots. Current code requires that the minimum lot width for new parks
be 40 feet for interior lots and 50 feet for corner lots. The current minimum lot depth
for new parks is 75 feet. The Renton Highlands Manor mobile home park is not
consistent with these standards. The existing lot widths range from 26.68 feet to 38.39
feet. The existing lot depths range from 45.85 feet to 59.66 feet. As a result of current
code requirements, the applicant asserts that if this variance is not granted, then it will
be impossible to replace obsolete mobile homes with new homes, and those obsolete
homes will remain in place permanently. In addition, The applicant states that the
obsolete aluminum 1960s mobile homes present a heighted health and safety risk to
the residents and aesthetically detract from the neighborhood. The applicant states
that approval of this variance is not a grant of special privilege, as other mobile home
parks are permitted to replacing aging manufactured homes.
Staff agrees that the mobile home lots and required manufactured home separation
results in practical difficulties for the replacement of the manufactured homes, and that
approval of this variance will not constitute a grant of special privilege. Staff
recommends approval of the variance to allow a back-to-back distance between a new
mobile home and an existing mobile home be 5 feet, and that the minimum back-to-
back distance between two replaced mobile homes be 10 feet. In order to ensure that
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City of Renton Department of Community & Economic Development
Renton Highland Manor Setback Variance
Administrative Report & Decision
LUA19-000078, VA
Report of June 25, 2019 Page 5 of 10
Staff Report_Renton Highlands Manor Setback Variance
the final back-to-back distance between all replaced mobile homes is 10 feet, staff
recommend as a condition of approval that the applicant submit an overall site plan, in
addition to a close-up unit site plan, with each building permit application that identifies
new proposed units and highlights all units replaced after the date of this decision.
Building permit numbers shall be labeled on the overall site plan.
The applicant also requests that the minimum side-to-side distance for mobile homes
be 8 feet, except in cases where 8-foot side-to-side clearance is not feasible between a
new and existing mobile unit due to space restrictions. The applicant requests that in
cases where 8-foot side-to-side separation is not feasible, that the City approve a 5-foot
sided-to-side distance until both units are replaced. Staff recommends approval of an
8-foot side-to-side distance between mobile homes. Staff does agree that for certain
mobile unit spaces, an 8-foot clearance between a new unit and an existing unit will not
be a feasible unit both units are replaced; however, 8 feet is the minimum necessary
clearance in order to provide space for parking between the mobile units. Therefore,
staff recommends approval of a 5-foot side-to-side separation between a new mobile
home and an existing mobile home (built prior to the date of this decision) provided the
applicant can demonstrate that the new replacement unit will be no greater in square
footage than the existing unit it is replacing. In addition, staff recommends as a
condition of approval that, in cases where the applicant proposes a 5-foot side-to-side
separation, the applicant submit a parking analysis with the building permit application
that shows where the mobile unit occupants will park in the interim, until units on either
side of the unit are replaced.
Compliant
provided
conditions of
approval are
met.
b. That 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.
Staff Comment: The applicant states that approval of the variance request will allow
obsolete and aesthetically unappealing homes to be replaced with new, attractive
homes that comply with building and fire codes. Therefore, the applicant asserts that
the proposal will not be materially detrimental to the public welfare or injurious to the
property or improvements in the vicinity.
While staff agrees that the proposed back-to-back and side-to-side distances will not be
injurious to the property or surrounding community, staff notes that the existing
manufactured homes on unit space numbered 13, 14, and 15 encroach onto the
neighboring property to the north. Per RMC 4-2-110E, mobile homes are required to
have a minimum setback of 5 feet from an exterior boundary of a mobile home park. In
order to ensure compliance with the required exterior boundary setback, staff
recommends a condition of approval that new manufactured units located on unit space
numbers 13, 14, and 15 shall be no longer in depth than 40 feet. Survey accurate site
plans, stamped by a licensed surveyor, shall be submitted with the building permit
applications for unit space numbers 13, 14, and 15 in order to ensure that the units
maintain a distance of 5 feet from the property line. In addition, the applicant shall
string the northern property line along units 13, 14, and 15 to verify setbacks prior to
manufactured home installation.
The existing site does not meet current fire hydrant requirements for all units. The fire
flow requirement for a single family homes is a minimum of 1,000 GPM (gallons per
minute) for dwellings up to 3,600 square feet (including garage and basements). If the
dwelling exceeds 3,600 square feet, a minimum of 1,500 GPM fire flow is required. A
minimum of one new fire hydrant is required within 300 feet of the proposed buildings
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
City of Renton Department of Community & Economic Development
Renton Highland Manor Setback Variance
Administrative Report & Decision
LUA19-000078, VA
Report of June 25, 2019 Page 6 of 10
Staff Report_Renton Highlands Manor Setback Variance
and two hydrants if the fire flow goes up to 1,500 GPM. The applicant will be required
to demonstrate compliance with fire hydrant requirements at the time of building
permit application for each unit.
In addition, the site does not meet current fire access requirements for all units. Fire
department apparatus access roadways are required within 150 feet of all points on the
building. Fire access roads are required to be a minimum of 20 feet unobstructed width
with turning radius of 25 feet inside and 45 feet outside minimum. Roadways are
required to support a minimum of a 30-ton vehicle and 75-psi point loading. In addition,
fire lane signage is required for the onsite roadways. The applicant will be required to
demonstrate compliance with fire access requirements at the time of building permit
application for each unit.
c. That approval shall 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.
Staff Comment: See comments under criterion a.
d. That the approval is a minimum variance that will accomplish the desired purpose.
Staff Comment: Provided conditions of approval are complied with, staff agree that the
requested variance is the minimum variance necessary to allow for replacement of the
manufactured homes.
15. Variance Analysis: The applicant is requesting a variance from RMC 4-2-110E in order to allow an
exception to the requirement that the minimum distance between a mobile home and a public street be
20 feet. Instead the applicant requests that the new units maintain a setback of 10 feet from NE 4th Street.
Approximately 30 feet of Queen Ave NE is located within a perpetual easement on the subject property
which was conveyed to the City for the purposes of public utilities and services. Currently existing mobile
units are encroaching into this easement. The applicant proposes to locate the replacement units outside
of the easement, and requests that the City approval a 0-foot setback from the easement. The proposal
is compliant with the following variance criteria, pursuant to RMC 4-9-250.B.5. Therefore, staff
recommends approval of the requested variance, with conditions.
Compliance Variance Criteria and Analysis
Compliant
provided
conditions of
approval are
met.
a. That 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, 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.
Staff Comment: The applicant states that 16 of the 49 existing mobile home lots at
Renton Highland Manor abut a public street. Four of the homes abut NE 4th Street, and
12 homes abut Queen Avenue NE. Approximately 30 feet of Queen Ave NE is located
within a perpetual easement on the subject property which was conveyed to the City
for the purposes of public utilities and services. Currently approximately 11 existing
mobile units are encroaching into this easement. The applicant states that if a 20-foot
setback is required from both streets, replacement of the existing, obsolete homes will
be infeasible, due to the small sized of the mobile home spaces. The applicant states
that approval of this variance is not a grant of special privilege, as other mobile home
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
City of Renton Department of Community & Economic Development
Renton Highland Manor Setback Variance
Administrative Report & Decision
LUA19-000078, VA
Report of June 25, 2019 Page 7 of 10
Staff Report_Renton Highlands Manor Setback Variance
parks are permitted to replacing aging manufactured homes. Staff agrees with the
applicants justification and recommends approval of a 10-foot setback from NE 4th
Street and a 0-foot setback from the 30-foot public utility easement along Queen Ave
NE; however, in order to ensure that the proposal meets the intent of the setback code
regulations, which is to encourage open space between structures and a property line,
staff recommend as a condition of approval that the no parking spaces be located
between the new units and a public street.
In addition, in order to ensure that new units are not installed within the 30-foot public
utility easement, staff recommend as a condition of approval that survey accurate site
plans, stamped by a licensed surveyor, shall be submitted with the building permit
applications for units along Queen Ave NE. In addition, the applicant shall string the
edge of the utility easement prior to manufactured home installation.
b. That 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.
Staff Comment: The applicant states that the granting of the variance will allow
obsolete, non-code-compliant, mobile homes to be replaced by safe, attractive,
contemporary manufactured homes. The applicant further states that 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.
The applicant states that replacing the obsolete mobile homes that abut the public
streets, which are the most visibly prominent homes, will help improve the community
as seen from the street. Provided conditions of approval are met, staff agree that
approval of this variance request 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
c. That approval shall 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.
Staff Comment: See comments under criterion a.
d. That the approval is a minimum variance that will accomplish the desired purpose.
Staff Comment: Provided conditions of approval are complied with, staff agree that the
requested variance is the minimum variance necessary to allow for replacement of the
manufactured homes.
16. Variance Analysis: The applicant is requesting a variance from RMC 4-2-110E in order to allow an
exception to the requirement that the minimum distance between a mobile home and a service building
be 15 feet. There is currently one site-built service building onsite (used for laundry and storage). The
applicant requests that the distance between the new mobile units and the existing service building be
reduced to 5 feet rather than 15 feet. The proposal is partially compliant with the following variance
criteria, pursuant to RMC 4-9-250.B.5. Therefore, staff recommends a denial of the requested variance.
Compliance Variance Criteria and Analysis
Not
Compliant
a. That the applicant suffers practical difficulties and unnecessary hardship and the
variance is necessary because of special circumstances applicable to subject
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City of Renton Department of Community & Economic Development
Renton Highland Manor Setback Variance
Administrative Report & Decision
LUA19-000078, VA
Report of June 25, 2019 Page 8 of 10
Staff Report_Renton Highlands Manor Setback Variance
property, including size, shape, topography, 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.
Staff Comment: Based on the survey-accurate site plan provided with the project
application, the existing units abutting the site-built service building are approximately
14 feet and 2 inches away from the service building. The applicant is requesting a 5 foot
setback from the service building, rather than the code required setback of 15 feet.
However, based on the proposed floor plans (Exhibit 5) provided with the project
application and the existing dimensions the abutting lots, replacement of these units is
feasible with compliance of the required 15-foot separation requirement. Therefore,
staff does not recommend approval of a variance to allow a 5-foot separation from
service buildings, as the size and shape of the unit lots does not create a hardship.
Not
Compliant
b. That 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.
Staff Comment: The purpose of manufactured home distance requirements, including
the 15-foot distance requirement from an on-site service building, is to provide residents
with a livable community that includes a variety of open spaces throughout the
neighborhood. As stated above, replacement of these units is feasible with compliance
of the 15-foot separation requirement. Therefore, approval of this variance does not
meet the intent of the code, and can therefore be detrimental to the community
welfare. See additional comments under criterion a.
Not
Compliant
c. That approval shall 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.
Staff Comment: As stated above, based on the proposed floor plans provided with the
project application and the existing dimensions the lots abutting the existing service
building, replacement of these units is feasible with compliance of the required 15-foot
separation requirement. Therefore, approval of this variance is not necessary to
accomplish the desired objective, and approval of this variance would be a grant of
special privilege inconsistent with the limitations upon uses of other properties in the
vicinity. See additional comments under criterion a.
Not
Compliant
d. That the approval is a minimum variance that will accomplish the desired purpose.
Staff Comment: As stated above, replacement of these units is feasible with compliance
of the required 15-foot separation requirement. Therefore, the desired purpose can be
accomplished without approval of this variance. See additional comments under
criterion a.
G. CONCLUSIONS:
1. The subject site is located in the Commercial & Mixed Use (CMU) Comprehensive Plan designation and
complies with the goals and policies established with this designation, see FOF 5.
2. The requested mobile home back-to-back and side-to-side separation variance meets the four (4) criteria
to be considered in making a decision on a variance request as specified in RMC 4-9-250.B.5, provided
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City of Renton Department of Community & Economic Development
Renton Highland Manor Setback Variance
Administrative Report & Decision
LUA19-000078, VA
Report of June 25, 2019 Page 9 of 10
Staff Report_Renton Highlands Manor Setback Variance
conditions of approval are met. The analysis of the proposal according to variance criteria is found in the
body of the Staff Report, see FOF 13.
3. The requested street setback variance meets the four (4) criteria to be considered in making a decision
on a variance request as specified in RMC 4-9-250.B.5, provided conditions of approval are met. The
analysis of the proposal according to variance criteria is found in the body of the Staff Report, see FOF 14.
4. The requested mobile home and service building separation variance does not meet all four (4) criteria
to be considered in making a decision on a variance request as specified in RMC 4-9-250.B.5. Therefore,
staff recommends denial of the requested variance, see FOF 15.
H. DECISION:
The Renton Highland Manor mobile home and service building separation variance (FOF 15) is denied. The
Renton Highland Manor back-to-back and side-to-side separation variance (FOF 13), as well as street setback
variance (FOF 14), File No. LUA19-000078, VA, are approved and is subject to the following conditions:
1. The applicant shall submit an overall site plan, in addition to a close-up unit site plan, with each building
permit application that identifies new proposed units and highlights all units replaced after the date of
this decision. Building permit numbers shall be labeled on the overall site plan.
2. The new manufactured units located on unit space numbers 13, 14, and 15 shall be no longer in depth
than 40 feet. Survey accurate site plans, stamped by a licensed surveyor, shall be submitted with the
building permit applications for unit space numbers 13, 14, and 15 in order to ensure that the units
maintain a distance of 5 feet from the north property line. In addition, the applicant shall string the north
line to verify setbacks prior to manufactured home installation.
3. Survey accurate site plans, stamped by a licensed surveyor, shall be submitted with the building permit
applications for units along Queen Ave NE. In addition, the applicant shall string the edge of the utility
easement prior to manufactured home installation.
4. The new units shall maintain a minimum side-to-side distance of at least 8 feet from new and existing
units for compliance with parking requirements, unless the applicant can demonstrate that the new
replacement unit will be no greater in square footage than the existing unit it is replacing, in which case,
the setback between a new unit and an existing unit (built prior to this decision) shall be a minimum of 5
feet until units on either side are replaced.
5. In cases where the applicant proposes a 5-foot side-to-side separation, the applicant shall submit a
parking analysis with the building permit application that shows where the mobile unit occupants will park
in the interim, unit units on either side of the unit are replaced. Parking shall be provided on-site with a
safe walking rout to the new unit.
6. All attached future carports or canopies shall maintain a distance of at least 5 feet separation on all sides,
for all units.
7. No parking spaces shall be located between the new units and a public street.
DATE OF DECISION ON LAND USE ACTION:
SIGNATURE:
Jennifer Henning, Planning Director Date
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City of Renton Department of Community & Economic Development
Renton Highland Manor Setback Variance
Administrative Report & Decision
LUA19-000078, VA
Report of June 25, 2019 Page 10 of 10
Staff Report_Renton Highlands Manor Setback Variance
TRANSMITTED on June 25, 2019 to the Owner/Applicant/Contact:
Owner: Applicant/Contact:
Renton Highland Manor LLC
1232 19th St, Suite 17
Oakland, CA 94607
Daniel Weisfield
1232 19th St, Suite 17
Oakland, CA 94607
TRANSMITTED on June 25, 2019 to the following:
Chip Vincent, CED Administrator
Brianne Bannwarth, Development Engineering Manager
Amanda Askren, Property Services
Vanessa Dolbee, Current Planning Manager
Rick Marshall, Fire Marshal
I. LAND USE ACTION APPEALS, REQUEST FOR RECONSIDERATION, & EXPIRATION:
The administrative land use decision will become final if the decision is not appealed within 14 days of the decision
date.
APPEAL: This administrative land use decision will become final if not appealed in writing to the Hearing
Examiner on or before 5:00 PM on July 9, 2019. An appeal of the decision must be filed within the 14-day appeal
period (RCW 43.21.C.075(3); WAC 197-11-680), together with the required fee to the Hearing Examiner, City of
Renton, 1055 South Grady Way, Renton, WA 98057. RMC 4-8-110.B governs appeals to the Hearing Examiner and
additional information regarding the appeal process may be obtained from the City Clerk’s Office, (425) 430-6510.
EXPIRATION: The Variance decision will expire three (3) years from the date of decision. A single one (1) year
extension may be requested pursuant to RMC 4-9-250.
RECONSIDERATION: Within 14 days of the decision date, any party may request that the decision be reopened by
the approval body. The approval body may modify his decision if material evidence not readily discoverable prior
to the original decision is found or if he finds there was misrepresentation of fact. After review of the
reconsideration request, if the approval body finds sufficient evidence to amend the original decision, there will
be no further extension of the appeal period. Any person wishing to take further action must file a formal appeal
within the 14-day appeal time frame.
THE APPEARANCE OF FAIRNESS DOCTRINE: provides that no ex parte (private one-on-one) communications may
occur concerning the land use decision. The Doctrine applies not only to the initial decision, but to Appeals to the
Hearing Examiner as well. All communications after the decision/approval date must be made in writing through
the Hearing Examiner. All communications are public record and this permits all interested parties to know the
contents of the communication and would allow them to openly rebut the evidence in writing. Any violation of
this doctrine could result in the invalidation of the appeal by the Court.
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CITY OF RENTON
DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT
ADMINISTRATIVE REPORT & DECISION
EXHIBITS
Project Name:
Renton Highland Manor Setback Variance
Land Use File Number:
LUA19-000078, VA
Date of Report
June 25, 2019
Staff Contact
Angelea Weihs
Associate Planner
Project Contact/Applicant
Daniel Weisfield
1232 19th St, Suite 17
Oakland, CA 94607
Project Location
3612 NE 4th Street
The following exhibits are included with the Administrative report:
Exhibit 1: Administrative Decision
Exhibit 2: Site Plan
Exhibit 3: Project Narrative
Exhibit 4: Variance Justification
Exhibit 5: Unit Floorplans
Exhibit 6: Unit Elevations
Exhibit 7: Advisory Notes
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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30.5'30.3'19.7'19.4'18.5'18.8'29.1'28.9'272628293031323334353637494847464544434241403938151413121110987612345LAUNDRY&STORAGE25241617181920212252.2'
11.8'17.7'18.1'4.4'4.0'4.8'4.4'3.5'3.0'1.5'3.5'24.4'8.5'8.8'25.3'PARKING AREAPARKING AREABROKEN CONCRETEBROKEN CONCRETEGRAVEL PARKING AREAPLANTERUNDERGROUNDMARKING PAINTSIGNUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUUPERPETUAL EASEMENT#5247236EAST 30 FEET OF THE EAST 1/2OF THE SE 1/4 OF THE SW 1/4OF THE SE 1/4 SECTION 9(30')(30')ACCESS ACCESS TELEPHONE LINE EASEMENT#5217313WEST 10 FEET OF THE EAST 25FEET OF THE SOUTH 45 FEETEAST LINE OF SUBJECTPROPERTY(20')STONE COURT CONDOMINIUM (VOL. 147 P. 67-69)30.0'25.0'(30')
25')9.7'3.2'2.8'6.3'5.0'R/WȭȭȭȭȭRV IN THIS LOCATIONVAULT46.01'28.47'46.12'31.00'35.00'52.65'35.01'103.48'103.48'
50.65'35.00'50.75'26.85'35.00'35.00'70.01'35.00'35.00'35.00'32.00'32.00'103.18'103.18'32.00'32.00'38.39'45.85'35.00'45.85'35.00'45.85'35.00'95.16'52.83'95.16'103.76'35.00'52.88'35.00'31.88'51.55'35.01'51.87'35.00'52.59'35.00'52.53'32.00'52.47'32.00'45.85'33.06'36.24'
47.50'35.38'47.63'35.00'46.77'36.43'46.92'34.00'47.34'36.09'34.00'59.52'34.00'59.39'
47.20'35.72'34.00'34.00'59.27'
47.03'42.02'34.00'34.00'59.14'26.68'34.00'34.00'59.01'
46.48'34.21'46.63'34.82'34.00'58.88'33.63'37.80'37.80'58.75'31.00'46.25'28.82'46.38'34.82'58.62'31.00'29.39'29.39'58.49'31.00'31.69'58.37'31.00'58.25'35.32'49.93'35.33'50.25'35.65'35.66'50.61'33.61'33.62'50.87'36.48'36.49'51.20'38.94'38.95'34.43'34.43'52.18'33.70'33.70'52.46'29.48'29.48'52.72'30.53'30.53'53.00'32.22'32.23'53.27'27.78'30.01'53.54'20.00'20.00'31.00'31.00'35.00'20.00'20.00'
59.66'
58.14'
1807.19 SF
(0.04 AC +/-)
1647.60 SF
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8536.05 SF(0.20 AC +/-)1759.86 SF(0.04 AC +/-)1449.52 SF(0.03 AC +/-)
10709.50 SF
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1839.52 SF(0.04 AC +/-)1678.18 SF(0.04 AC +/-)
2021.62 SF
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2017.23 SF
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2012.84 SF
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2008.44 SF
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1720.93 SF(0.04 AC +/-)1807.73 SF(0.04 AC +/-)
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2000.50 SF
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1791.04 SF(0.04 AC +/-)1762.92 SF(0.04 AC +/-)1550.07 SF(0.04 AC +/-)1613.55 SF(0.04 AC +/-)1711.95 SF(0.04 AC +/-)1659.56 SF(0.04 AC +/-)1811.38 SF(0.04 AC +/-)
2085.67 SF
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1804.07 SF(0.04 AC +/-)20.0'20.0'20.0'20.0'20.0'31.69'28.47'32.86'31.00'34.21'33.63'36.42'26.68'42.02'35.72'36.09'35.37'1311.06 SF(0.03 AC +/-)1463.45 SF(0.03 AC +/-)1331.78 SF(0.03 AC +/-)1592.31 SF(0.04 AC +/-)
1706.03 SF
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1679.98 SF(0.04 AC +/-)1483.47 SF(0.03 AC +/-)
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1438.99 SF(0.03 AC +/-)30.0'2' P.S.P. & L. CO. TRANS LINEAS SHOWN ONKING COUNTY TAXMAPSE 09-23-05WLEGENDHYD OHIMASPHALTLIGHT POLESIGNIRRIGATION METER / VALVEWATER METERWATER VALVEFIRE HYDRANTCATCH BASINTELEPHONE BOXUTILITY CONNECTIONSPOWER POLE / SERVICE POLESTORM DRAIN MANHOLESANITARY SEWER MANHOLEGAS VALVETRAFFIC SIGNALTELEPHONE MANHOLESUBJECT PROPERTY BOUNDARYCENTERLINEEASEMENT LINESOVERHEAD LINESMOBILE HOME FOOTPRINT /RVMOBILE HOME LOT DESIGNATIONSHED21EXHIBIT 2DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
Variance application
Renton Highland Manor
3612 NE 4th Street, Renton, WA 98056
APN: 0923059176
Project Narrative
Project name, size and location of site
Project name: Renton Highland Manor, an existing 49 unit mobile home park
providing affordable housing to approximately 200 residents of Renton without
government subsidy
Size: 131,986 square feet
Location: 3612 NE 4th Street, Renton, WA 98056
APN: 0923059176
Land use permits required for proposed project
o We are professional mobile home park owners seeking to upgrade the sub-
standard housing stock at Renton Highland Manor by replacing obsolete
1960s manufactured homes with new, energy efficient, code-compliant
manufactured homes. This will increase the supply of high-quality
affordable housing in Renton.
o In order to do this, we require a three-year Administrative Variance to the
City of Renton’s setback requirements for mobile homes installed in mobile
home parks constructed before 8/1/2010, as illustrated in RMC 4-2-HOE
(Illustrations).
o We will begin by installing two homes, on lot #41 (replacing an obsolete
home which was destroyed in a fire) and lot #43 (replacing an obsolete
home).
o Over time, we intend to gradually replace obsolete homes throughout the
property with new, safe, energy efficient homes.
o This process will take decades, because the homes in the park belong to
tenants. We do not control their homes, so we cannot cause these
upgrades to happen on a timeline of our choosing. The upgrades will occur
gradually as tenants vacate the park or choose to upgrade their own
homes.
o Therefore, in accordance with the advice we received from Planning during
our pre-application meeting, we are seeking a blanket variance that would
apply to the entire property, and which could be applied in the future at any
time when we apply for a building permit to replace an obsolete home with
a new manufactured home.
Zoning designation of the site and adjacent properties
o The site and the adjacent properties are zoned Commercial Arterial (CA).
The existing Comprehensive Plan Map Designation is Commercial Mixed
Use (CMU).
EXHIBIT 3
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
Current use of the site and any existing improvements
o The site is currently used as a 49 unit mobile home park, providing
affordable housing to 49 working families in Renton with zero government
subsidies.
Special site features (i.e. wetlands, water bodies, steep slopes)
o The site has no special site features
o The site is flat
o The site does not have any wetlands or bodies of water
o The site has approximately 19 significant trees (greater than 6 caliper
inches). None of these trees will be removed or disturbed. See item #15,
Tree Retention Worksheet.
o The site has been in continuous use as a mobile home park since the
1950s
o Based on the City’s Critical Areas Maps, there appear to be no Critical
Areas on site
Statement addressing soil type and drainage conditions
o To our best knowledge, the site has normal soil composition and normal
drainage conditions
o No flooding has been observed at the property
o As part of a parking lot and landscaping improving project in 2018, a
French drain was added to the property to further facilitate surface water
drainage
Proposed use of the property and scope of the proposed development
o The proposed use of the property will not change. We will continue to
operate the property as a 49 unit mobile home park providing affordable
housing without government subsidy to approximately 200 residents of
Renton.
o However, by replacing obsolete, 1960s, aluminum-sided “eyesore”
manufactured homes with new, attractive, energy-efficient manufactured
homes, we will significantly upgrade the aesthetic profile of the property,
which will create a positive aesthetic impact for adjacent properties, as
well as for the general public passing by this highly visible property on the
NE 4th Street arterial.
o Additionally, by replacing obsolete 1960s homes with new, code-compliant
homes, we will reduce health and safety risks for our residents, and
reduce the risk of fire for the neighborhood at large.
For plats indicate the proposed number, net density and range of sizes (net lot
area) of the new lots
o N/A
Access
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
o Access to Renton Highland Manor will remain via two curb cuts off of NE
4th Street.
Proposed off-site improvements (i.e. installation of sidewalks, fire hydrants,
sewer main, etc.)
o N/A
Total estimated construction cost and estimated fair market value of the
proposed project
o Each new manufactured home that we install in the community costs
approximately $80,000
o Fair market value (and likely sale price) of each new manufactured home
that we install in the community is approximately $90,000
o After obtaining this Administrative Variance, we initially plan to install two
new manufactured homes in the community
o Thus, estimated construction cost is $160,000, and estimated fair market
value is $180,000
Estimated quantities and type of materials involved if any fill or excavation is
proposed
o No fill or excavation is proposed
Number, type and size of any trees to be removed
o No trees will be removed
Explanation of any land to be dedicated to the City
o No land will be dedicated to the City
Any proposed job shacks, sales trailers, and/or model homes
o There will be no job shacks, sales trailers, or model homes
Any proposed modifications being requested (include written justification)
o Our objective is to replace obsolete 1960s mobile homes at Renton
Highland Manor with new, attractive manufactured homes, thereby
improving the aesthetic profile of the community, while reducing health,
safety, and fire risk for our residents and the broader community
o The lots at Renton Highland Manor were built in the 1950s in order to
accommodate 1950s-era mobile homes.
o The lots are abnormally small by today’s standards
o Due to the small size of the lots, it is impossible to install new, attractive
manufactured homes on these lots while remaining in compliance with the
City’s setback requirements for mobile homes (as illustrated in RMC 4-2-
HOE)
o For reference, please note that under RMC 4-2-HOE, setback
requirements for mobile home parks constructed before August 1, 2010
are as follows:
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
a) Minimum distance between mobile homes shall be 15 feet
b) Minimum distance between canopy and mobile home on an
abutting space shall be 5 ft.
c) Minimum distance between proposed mobile home and exterior
property boundary of the mobile home park shall be 5 ft.
o See illustration (on following page) illustrating RMC 4-2-HOE
o Therefore, in order to replace obsolete manufactured homes with safe,
attractive, new homes, we request a modification to the City’s setback
requirements for mobile homes (as illustrated in RMC 4-2-HOE)
o Specifically, we seek a three-year Administrative Variance to enable the
following:
a) New units will not be placed within the 30 foot City of Renton
utility easement.
b) No setback from the utility easement will be required.
c) Therefore, any new units abutting Queen Avenue may extend
eastward as far as the utility easement, but shall extend no further
eastward than the utility easement.
d) The minimum street frontage setback shall be 10 feet. In
practice, this setback shall only apply to the property’s boundary
abutting NE 4th Street. There shall be no setback from Queen Avenue
other than the requirement (described above) that no new homes
extend into the 30 foot City of Renton utility easement.
e) Any setback abutting an exterior property boundary of the mobile
home park shall be a minimum of 5 feet. In practice, this applies to
the north and west boundaries of the property.
f) The units shall maintain a distance of at least 5 feet of separation
on all sides, for all units. This is to include the units themselves and
any attached future carports or canopies.
g) 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 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.
h) The minimum back-to-back distance between a new mobile home
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
and an existing mobile home shall be 5 feet.
i) The minimum back-to-back distance between two new mobile
homes shall be 10 feet.
j) The minimum distance between a canopy and a mobile home on
an abutting lot shall be 5 feet.
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
Application 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.
EXHIBIT 4
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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.
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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.
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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”
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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:
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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”
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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.
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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.
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
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.
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
EXHIBIT 5DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
EXHIBIT 6DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
DEPARTMENT OF COMMUNITY
AND ECONOMIC DEVELOPMENT
Page 1 of 2 LUA19-000078
ADVISORY NOTES TO APPLICANT
The following notes are supplemental information provided in conjunction with the administrative land use
action. Because these notes are provided as information only, they are not subject to the appeal process for
the land use action.
Planning:
(Contact: Angelea Weihs, 425-430-7312, aweihs@rentonwa.gov)
1. RMC section 4-4-030.C.2 limits haul hours between 8:30 am to 3:30 pm, Monday through Friday unless
otherwise approved by the Development Services Division.
2. Commercial, multi-family, new single family and other nonresidential construction activities shall be
restricted to the hours between seven o’clock (7:00) a.m. and eight o’clock (8:00) p.m., Monday through
Friday. Work on Saturdays shall be restricted to the hours between nine o’clock (9:00) a.m. and eight
o’clock (8:00) p.m. No work shall be permitted on Sundays.
3. Within thirty (30) days of completion of grading work, the applicant shall hydroseed or plant an
appropriate ground cover over any portion of the site that is graded or cleared of vegetation and where
no further construction work will occur within ninety (90) days. Alternative measures such as mulch,
sodding, or plastic covering as specified in the current King County Surface Water Management Design
Manual as adopted by the City of Renton may be proposed between the dates of November 1st and
March 31st of each year. The Development Services Division’s approval of this work is required prior to
final inspection and approval of the permit.
4. The applicant may not fill, excavate, stack or store any equipment, dispose of any materials, supplies or
fluids, operate any equipment, install impervious surfaces, or compact the earth in any way within the
area defined by the drip line of any tree to be retained.
5. The applicant shall erect and maintain six foot (6') high chain link temporary construction fencing around
the drip lines of all retained trees, or along the perimeter of a stand of retained trees. Placards shall be
placed on fencing every fifty feet (50') indicating the words, “NO TRESPASSING – Protected Trees” or on
each side of the fencing if less than fifty feet (50'). Site access to individually protected trees or groups
of trees shall be fenced and signed. Individual trees shall be fenced on four (4) sides. In addition, the
applicant shall provide supervision whenever equipment or trucks are moving near trees.
6. This permit is shall comply with the Bald and Golden Eagle Protection Act. The permitted is responsible
for adhering to the U.S. Fish and Wildlife Service National Bald Eagle Management Guidelines (2007) and
/or your U.S. Fish and Wildlife Service permit.
Development Engineering:
(Contact: Jonathan Chavez, 425-430-7288, jchavez@rentonwa.gov)
1. No Comment.
Fire Authority:
(Contact: Corey Thomas, 425-430-7024, cthomas@rentonwa.gov)
1. See attached comments.
Technical Services:
(Contact: Amanda Askren, 425-430-7369, aaskren@rentonwa.gov)
1. No Comment.
Community Services: EXHIBIT 7
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
ADVISORY NOTES TO APPLICANT
Page 2 of 2 LUA19-000078
(Contact: Leslie Betlach, 425-430-6619, lbetlach@rentonwa.gov)
1. See attached comments.
Police:
(Contact: Cyndie Parks, 425-430-7521, cparks@rentonwa.gov)
1. No Comment.
Building:
(Contact: Craig Burnell, 425-430-7290, cburnell@rentonwa.gov)
1. No Comment.
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
FIRE & EMERGENCY
SERVICES DEPARTMENT
M E M O R A N D U M
DATE:May 14, 2019
TO:Angelea Weihs, Associate Planner
FROM:Corey Thomas, Lead Plans Review Inspector
SUBJECT:Renton Highland Manor
1.The fire flow requirement for a single family homes is 1,000 gpm minimum for
dwellings up to 3,600 square feet (including garage and basements). If the dwelling
exceeds 3,600 square feet, a minimum of 1,500 gpm fire flow would be required. A
minimum of one new fire hydrant is required within 300-feet of the proposed
buildings and two hydrants if the fire flow goes up to 1,500 gpm. Applicant has not
shown any preliminary utility plan showing compliance with this requirement of a
minimum of one new fire hydrant.
2.Fire impact fees are applicable at the rate of $829.77 per new residential unit. A credit
is given for the demolition of the existing houses. This fee is paid at time of building
permit issuance.
3.Fire department apparatus access roadways are required within 150-feet of all points
on the building. Fire access roads are required to be a minimum of 20-feet
unobstructed width with turning radius of 25-feet inside and 45-feet outside
minimum. Fire lane signage required for the onsite roadways. Roadways shall
support a minimum of a 30-ton vehicle and 75-psi point loading. Existing roadways do
not meet minimum turning radius requirements and shall be required to do so.
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD
c:\users\lbetlach\desktop\community services memo.docx
M E M O R A N D U M
DATE:May 7 2019
TO:Angelea Weihs, Associate Planner
FROM:Leslie Betlach, Parks Planning and Natural Resources Director
SUBJECT:3612 NE 4th Street, Renton Highland Manor, LUA 19-000078
I have completed my review and would appreciate incorporating the following
comments:
Parks Impact Fee for each new housing unit proposed above what currently
exists, applies as per adopted Ordinance.
DocuSign Envelope ID: F2A87C48-C818-48FE-AD59-95616B1012CD