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HomeMy WebLinkAboutD__Old Highlands Library Admin Staff Report_170301_v1DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT Project Location Map D__Old Highlands Library_170301_v1 A. ADMINISTRATIVE REPORT & DECISION DECISION: APPROVED APPROVED SUBJECT TO CONDITIONS DENIED REPORT DATE: March 1, 2017 Project Name: Old Highlands Library Short Plat Owner: City of Renton, 1055 S. Grady Way, Renton, WA 98057 Applicant/Contact: Michael Kirk, City of Renton, 1055 S. Grady Way, Renton, WA 98057 Cassandra Haavisto, Northwest Select Real Estate, PO Box 489, Maple Valley, WA 98038 File Number: LUA16-000960,SHPL-A Project Manager: Matthew Herrera, Senior Planner Project Summary: The City of Renton's Community Services Department is requesting an administrative short plat to subdivide the former Highlands Library property located at 2902 NE 12th Street into two lots and modify the property boundary to the southeastern adjacent lot. The existing properties total 146,561 square feet (3.36 acres) and are zoned Residential 14 (R-14) and Center Village (CV). The short plat would result in the former library site to be subdivided into two lots; Lot 1 comprised of 1.40 acres (61,133sf) and Lot 2 comprised of 1.64 acres (71,628sf). The short plat would separate the northern alley from the former library property and provide a lot line adjustment with the neighboring property located at 2908 NE 12th Street resulting in a boundary consistent with the current fence line separating the properties. No construction improvements are proposed with the short plat application. Project Location: 2902 NE 12th St. Site Area: 3.36 acres City of Renton Department of Community & Economic Development Administrative Report & Decision OLD HIGHLANDS LIBRARY SHORT PLAT LUA16-000960,SHPL-A Report Date: March 1, 2017 Page 2 of 10 Old Highlands Library Short Plant D__Old Highlands Library_170301_v1 B. EXHIBITS: Exhibit 1: Staff Report Exhibit 2: Short Plat Plan Exhibit 3: Proposed Sunset Area Street Classification Exhibit 4: Sunset Area Community Planned Action Environmental Impact Statement (EIS) C. GENERAL INFORMATION: 1. Owner(s) of Record: Michael Kirk, City of Renton, 1055 S. Grady Way, Renton, WA 98057; Edwin McRory, MJS LLC, PO Box 489, Maple Valley, WA 98038 2. Zoning Classification: Residential-14 (R-14) and Center Village (CV) 3. Comprehensive Plan Land Use Designation: Residential High Density and Commercial and Mixed Use 4. Existing Site Use: Vacant former library building, alley, and abutting apartment building 5. Critical Areas: Wellhead Protection Zone 2 6. Neighborhood Characteristics: a. North: R-14; various single-family and duplex dwellings b. East: CV and R-14; Fire station and various single-family and duplex dwellings c. South: CV; Multi-family and shopping center d. West: R-14; Various single-family and duplex dwellings and school 6. Site Area: 3.36 acres 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 Sunset Area Planned Action EIS LUA10-052 N/A 06/06/2011 Epstein Annexation N/A 1246 04/16/1946 E. PUBLIC SERVICES: 1. Existing Utilities a. Water: Water service is provided by the City of Renton. There is an existing 8-inch water main in NE 12th St. City of Renton Department of Community & Economic Development Administrative Report & Decision OLD HIGHLANDS LIBRARY SHORT PLAT LUA16-000960,SHPL-A Report Date: March 1, 2017 Page 3 of 10 Old Highlands Library Short Plant D__Old Highlands Library_170301_v1 b. Sewer: Sewer service is provided by the City of Renton. There is an existing 8-inch gravity sewer main in NE 12th St. c. Surface/Storm Water: An existing 12-inch stormwater main is located in NE 12th St. 2. Streets: The subject property fronts NE 12th Street a collector street currently improved with pavement, curb, gutter, sidewalk, and streetlights. 3. Fire Protection: Renton Fire Authority F. APPLICABLE SECTIONS OF THE RENTON MUNICIPAL CODE: 1. Chapter 2 Land Use Districts a. Section 4-2-020: Purpose and Intent of Zoning Districts b. Section 4-2-070: Zoning Use Table c. Section 4-2-110: Residential Development Standards 2. Chapter 3 Environmental Regulations a. Section 4-3-050: Critical Area Regulations 3. Chapter 4 Property Development Standards 4. Chapter 7 Subdivision Regulations a. Section 4-7-070: Detailed Procedures for Short Subdivision 5. Chapter 11 Definitions G. APPLICABLE SECTIONS OF THE COMPREHENSIVE PLAN: 1. Land Use Element H. FINDINGS OF FACT (FOF): 1. The Planning Division of the City of Renton accepted the above master application for review on December 22, 2016 and determined the application complete on January 18, 2017. The project complies with the 120-day review period. 2. The project site is located at 2902 NE 12th Street. 3. The project site is currently developed with the City’s former Highlands Library building (now vacant) and an unimproved alley. 4. Access to the site remains as existing with two 14-foot wide driveways (one-way in and one-way out) along the NE 12th St. frontage. The unimproved alley also remains unchanged with access approximately 16-feet wide located on Harrison Ave NE between NE 16th St. and Index Ave NE. 5. The property is located within the Residential High Density Comprehensive Plan land use designation. 6. The site is located within the Residential-14 (R-14) zoning classification. 7. There are approximately 53 trees located on site. No trees are proposed to be removed. 8. The site is mapped with a Wellhead Protection Area Zone 2. 9. No construction or the need to cut and fill soils is proposed with the application. 10. Proposed Lot 3 alterations as shown on the short plat map (Exhibit 2) are limited to a lot line adjustment along the abutting Lot 1. Lot 3 is zoned Center Village (CV). The proposed adjustment will follow the existing fence line that is currently acting as a property boundary for the former library on Lot 1 and City of Renton Department of Community & Economic Development Administrative Report & Decision OLD HIGHLANDS LIBRARY SHORT PLAT LUA16-000960,SHPL-A Report Date: March 1, 2017 Page 4 of 10 Old Highlands Library Short Plant D__Old Highlands Library_170301_v1 apartment building on Lot 3. The lot line adjustment will not result any change to existing vehicle access to Lot 3 or for the lot to become nonconforming with regard to building setbacks, driveway setbacks, or lot size. 11. Proposed Lot 2 currently functions as an alley and is referred to as such in the Proposed Sunset Area Street Classification (Exhibit 3) and Sunset Area Community Planned Action EIS (Exhibit 4). 12. Staff received no public or agency written comments during the 14-day comment period. 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, 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. Comprehensive Plan Compliance: The site is designated Residential High Density (RHD) on the City’s Comprehensive Plan Map. The purpose of the RHD designation is to allow a variety of unit types where there is appropriate access, topography, and adjacent land uses. RHD unit types are designed to incorporate features from both single-family and multi-family developments, support cost-efficient housing, facilitate infill development, have close access to transit service, and efficiently use urban services and infrastructure. Lands designated RHD are where projects will be compatible with existing uses and where infrastructure is adequate to handle impacts from higher density uses. The proposal is compliant with the following Comprehensive Plan Goals and Policies if all conditions of approval are met: Compliance Comprehensive Plan Analysis  Policy L-2: Support compact development to improve health outcomes, support transit use, maximize land use efficiency, and maximize public investment in infrastructure.  Policy L-51: Respond to specific site conditions such as topography, natural features, and solar access to encourage energy savings and recognize the unique features of the site through the design of subdivisions and new buildings.  Policy L-56: Preserve natural landforms, vegetation, distinctive stands of trees, natural slopes, and scenic areas that contribute to the City’s identity, preserve property values, and visually define the community and neighborhoods. 15. Zoning Development Standard Compliance: The purpose of the Residential-14 Zone (R-14) is to encourage development, and redevelopment, of residential neighborhoods that provide a mix of detached and attached dwelling structures organized and designed to combine characteristics of both typical single family and small-scale multi-family developments. Structure size is intended to be limited in terms of bulk and scale so that the various unit types allowed in the zone are compatible with one another and can be integrated together into a quality neighborhood. Project features are encouraged, such as yards for private use, common open spaces, and landscaped areas that enhance a neighborhood and foster a sense of community. Civic and limited commercial uses may be allowed when they support the purpose of the designation. The proposal is compliant with the following development standards if all conditions of approval are met: Compliance R-14 Zone Develop Standards and Analysis N/A Density: The density range permitted in the R-14 zone is a minimum 7.0 up to a maximum of 14.0 dwelling units per net acre. Net density is calculated after the deduction of sensitive areas, areas intended for public right-of-way, and private access easements. City of Renton Department of Community & Economic Development Administrative Report & Decision OLD HIGHLANDS LIBRARY SHORT PLAT LUA16-000960,SHPL-A Report Date: March 1, 2017 Page 5 of 10 Old Highlands Library Short Plant D__Old Highlands Library_170301_v1 Staff Comment: Not applicable. No residential development is proposed for short plat. The short plat will result in one lot to accommodate the former Highland’s Library building and one lot to continue to serve as an alley for the abutting residential properties.  Lot Dimensions: The minimum lot size permitted in the R-14 zone is 3,000 sq. ft. for detached dwellings. There is no minimum lot size for attached dwellings. A minimum lot width of 30 feet is required (40 feet for corner lots) and a minimum lot depth of 60 feet is required. The following table identifies the proposed approximate dimensions for Lots 1 and 2 Proposed Lot Lot Size (sq. ft.) Lot Width (feet) Lot Depth (feet) Lot 1 61,133sf 215ft 429ft Lot 2 71,628sf 65ft 1259ft Staff Comment: The proposed lots meet minimum lot size, width, and depth requirements; however neither lot will accommodate dwellings. Lot 1 is the former Highlands Library and Lot 2 will continue to be used as an alley for abutting residences.  Setbacks: The required setbacks in the R-14 zone are as follows: front yard is 15 feet except when all access is taken from an alley then 10 feet, side yard is 4 feet for detached units, for attached units the side yard is 0 feet for the attached sides and 4 feet for the unattached sides, side yard along the street 15 feet, and the rear yard is 10 feet. Staff Comment: The former library building (Lot 1) is currently setback 102ft. from the front property line along NE 12th St., 81-feet from the east side property line, 29-feet from the west side property line, and 173-feet from the proposed rear property line. No setbacks will be applicable for Lot 2 as it functions as an alley.  Building Standards: The R-14 zone has a maximum building coverage of 65% and a maximum impervious surface coverage of 80%. In the R-14 zone, a maximum building height of 3 stories with a wall plate height of 24 feet is permitted. Roofs with a pitch equal to or greater than 4:12 may project an additional six (6) vertical feet from the maximum wall plate height. If the height of wall plates on a building are less than the stated maximum the roof may project higher to account for the difference, yet the combined height of both features shall not exceed the combined maximums. Common rooftop features, such as chimneys, may project an additional four (4) vertical feet from the roof surface. Non-exempt vertical projections (e.g., roofs pitched less than 4:12, decks, railings, etc.) may extend up to six (6) vertical feet above the maximum wall plate height if the projection is stepped back one-and-a-half (1.5) horizontal feet from each minimum building setback line for each one (1) vertical foot above the maximum wall plate height. Wall plates supporting a primary roof surface that has only one (1) sloping plane (e.g., shed roof) may exceed the stated maximum if the average of wall plate heights is equal or less than the maximum wall plate height allowed. Staff Comment: Building coverage for proposed Lot 1 is approximately 10-percent. No buildings are proposed Lot 2. Impervious coverage for Lot 1 is approximately 34- percent. Lot 2 is currently unimproved with areas of compacted gravel and vegetation and approximate impervious surface percentage of 27-percent. The wall plate height for the existing library building is one story and approximately 13-feet. City of Renton Department of Community & Economic Development Administrative Report & Decision OLD HIGHLANDS LIBRARY SHORT PLAT LUA16-000960,SHPL-A Report Date: March 1, 2017 Page 6 of 10 Old Highlands Library Short Plant D__Old Highlands Library_170301_v1 N/A Maximum Number of Units per Building: In the R-14 zone, no more than 6 units per building are permitted. Staff Comment: Not applicable. No dwellings units are proposed.  Landscaping: The City’s landscape regulations (RMC 4-4-070) require a 10-foot landscape strip along all public street frontages. Additional minimum planting strip widths between the curb and sidewalk are established according to the street development standards of RMC 4-6-060. Street trees and, at a minimum, groundcover, are to be located in this area when present. Spacing standards shall be as stipulated by the Department of Community and Economic Development, provided there shall be a minimum of one street tree planted per address. Any additional undeveloped right-of-way areas shall be landscaped unless otherwise determined by the Administrator. Where there is insufficient right-of-way space or no public frontage, street trees are required in the front yard subject to approval of the Administrator. A minimum of two trees are to be located in the front yard prior to final inspection for the new Single Family Residence. Staff Comment: Lot 1 (former library) abuts NE 12th St and currently provides a 15-foot wide landscaping strip along the frontage. The landscaping contains 4 large and mature Western Red Cedar trees and shrubs. Currently there is no landscape strip within the ROW between the sidewalk and street. No improvements are proposed with the short plat and therefore no frontage improvements, including the street classification’s 8-foot planter strip, are being constructed with this application. Future improvements on Lot 1 that exceed construction cost thresholds would require the need for constructing the planter strip.  Tree Retention: The City’s adopted Tree Retention and Land Clearing Regulations require the retention of 20 percent of trees in a residential development. Significant trees shall be retained in the following priority order: Priority One: Landmark trees; significant trees that form a continuous canopy; significant trees on slopes greater than twenty percent (20%); Significant trees adjacent to critical areas and their associated buffers; and Significant trees over sixty feet (60') in height or greater than eighteen inches ( 18") caliper. Priority Two: Healthy tree groupings whose associated undergrowth can be preserved; other significant native evergreen or deciduous trees; and Other significant non- native trees. Priority Three: Alders and cottonwoods shall be retained when all other trees have been evaluated for retention and are not able to be retained, unless the alders and/ or cottonwoods are used as part of an approved enhancement project within a critical area or its buffer. A minimum tree density shall be maintained on each residentially zoned lot. Lots developed with detached single family dwelling units in the R-14 zone are exempt from the minimum tree density requirements. For multi-family development, the minimum tree density is four (4) significant trees for every five thousand (5,000) square feet. The tree density may consist of existing trees, replacement trees, trees required pursuant to RMC 4-4-070F1, Street Frontage Landscaping Required, or a combination. City of Renton Department of Community & Economic Development Administrative Report & Decision OLD HIGHLANDS LIBRARY SHORT PLAT LUA16-000960,SHPL-A Report Date: March 1, 2017 Page 7 of 10 Old Highlands Library Short Plant D__Old Highlands Library_170301_v1 Staff Comment: No trees will be removed with the proposed short plat. Compliance not yet demonstrated Parking: Parking regulations require that a minimum of two parking spaces be provided for each detached dwelling. Parking regulations require that a minimum and maximum of 1.6 spaces be provided per 3 bedroom or large dwelling unit; 1.4 spaces per 2 bedroom dwelling unit; and 1.0 space per 1 bedroom or studio dwelling unit. Driveway cuts are required to be a minimum of 5 feet from property lines and new driveways may be a maximum of 16 feet in width at the property line. Maximum driveway slopes shall not exceed fifteen percent (15%); provided, that driveways exceeding eight percent (8%) shall provide slotted drains at the lower end with positive drainage discharge to restrict runoff from entering the garage/residence or crossing any public sidewalk. Staff Comment: The former library (Lot 1) contains 26 parking spaces. No new use has been proposed for the site. Any future use in the existing building will be required to demonstrate compliance with the parking requirements. Driveway cuts for Lot 1 are set back 8-feet on the west driveway and 12-feet on the east driveway. Lot 2 will be continue to be used as an alley for abutting property owners with no parking requirements N/A Fences and Retaining Walls: In any residential district, the maximum height of any fence, hedge or retaining wall shall be seventy two inches (72"). Except in the front yard and side yard along a street setback where the fence shall not exceed forty eight inches (48") in height. There shall be a minimum three-foot (3') landscaped setback at the base of retaining walls abutting public rights-of-way. Staff Comment: Not applicable. No fences or retaining walls are proposed. 16. Critical Areas: Project sites which contain critical areas are required to comply with the Critical Areas Regulations (RMC 4-3-050). The site is within a Wellhead Protection Area Zone 2. No improvements are proposed with the short plat application. Any future construction on the site will be required to comply with the Critical Areas regulations. 17. Compliance with Subdivision Regulations: RMC 4-7 Provides review criteria for the subdivisions. The proposal is consistent with the following subdivision regulations: Compliance Subdivision Regulations and Analysis  Access: Each lot must have access to a public street or road. Access may be by a shared driveway per the requirements of the street standards. The maximum width of single loaded garage driveways shall not exceed nine feet (9') and double loaded garage driveways shall not exceed sixteen feet (16'). Staff Comment: Access to the site will remain unchanged. There are currently two 14-foot wide driveways serving the former library site (Lot 1). Access to the alley (Lot 2) remains in its current location on Harrington Ave NE. and approximately 16-feet wide at the intersection. N/A Blocks: Blocks shall be deep enough to allow two tiers of lots. Staff Comment: No blocks are proposed. City of Renton Department of Community & Economic Development Administrative Report & Decision OLD HIGHLANDS LIBRARY SHORT PLAT LUA16-000960,SHPL-A Report Date: March 1, 2017 Page 8 of 10 Old Highlands Library Short Plant D__Old Highlands Library_170301_v1  Lots: The size, shape, orientation, and arrangement of the proposed lots comply with the requirements of the Subdivision Regulations and the Development Standards of the R- 14 zone and allow for reasonable infill of developable land. All of the proposed lots meet the requirements for minimum lot size, depth, and width. Staff Comment: As discussed under FOF 14 both lots meet the minimum lot dimensional requirements for the R-14 zone. Lot 1 is not rectangular; however it is a large lot with 168 linear feet of frontage along the street and an average lot width of 215-feet. Adequate developable area of the lot is demonstrated by the existing 6,160sf foot building and 26- space surface parking lot. Lot 2 does not resemble a typical lot shape or orientation as it has and will in the future function as an alley for abutting residential properties.  Streets: The proposed street system shall extend and create connections between existing streets per the Street Standards outlined in RMC 4-6-060 Street Standards. Staff Comment: No street improvements are proposed with the short plat application. Lot 1 is abutting NE 12th Street. Frontage improvements would be required for future improvements to Lot 1 should the construction costs exceed the current exemption level. Lot 2 is currently unimproved and functions as an alley for the abutting properties. The proposed Sunset Area Street Classification (Exhibit 3) identifies Lot 2 as NE 16th Alley and Jefferson Alley NE. The Sunset Area Community Planned Action EIS (Exhibit 4) provides a concept for Lot 2 as a possible candidate for the Green Connection Low-Impact Development stormwater program with an alley/woonerf. Improvements to the alley would likely be constructed as part of a capital improvement plan and/or incrementally with abutting residential development.  Relationship to Existing Uses: The proposed project is compatible with existing surrounding uses. Staff Comment: The proposed short plat would not change the existing nature of the subject property and remains compatible with surrounding uses. Any future use of the former library building will be required to meet current zoning use and development regulations. The alley (Lot 2) provides the preferred vehicle access for the R-14 zoning designation. 18. Availability and Impact on Public Services: Compliance Availability and Impact on Public Services Analysis  Police and Fire: Police and Fire Prevention staff indicates that sufficient resources exist to furnish services to the proposed short plat. No fire impact fees are required at this time. Impact fees may be required for future improvements on the site. N/A Schools: No dwelling units are proposed and therefore no impacts to the Renton School District are anticipated. N/A Parks: No dwelling units are proposed and therefore a Parks Impact Fee is not required.  Storm Water: An adequate drainage system shall be provided for the proper drainage of all surface water. Staff Comment: No improvements are proposed with the short plat application and therefore no drainage system improvements are required at this time. Future improvements may require upgrades to the existing drainage infrastructure. ReportDate:March1,2017Page9of10nowaterimprovementsarerequiredatthistime.Futureimprovementsmayrequireupgradestotheexistingwaterinfrastructure.SanitarySewer:Noimprovementsareproposedwiththeshortp/atapplicationand“thereforenosanitarysewerimprovementsarerequiredatthistime.Futureimprovementsmayrequireupgradestotheexistingsanitarysewerinfrastructure.I.CONCLUSIONS:1.ThesubjectsiteislocatedintheHighDensity(HD)ComprehensivePlandesignationandcomplieswiththegoalsandpoliciesestablishedwiththisdesignation,seeFOE14.2.ThesubjectsiteislocatedintheResidential-14(R-14)zoningdesignationandcomplieswiththezoninganddevelopmentstandardsestablishedwiththisdesignationprovidedtheapplicantcomplieswithCityCode,seeFOE15.3.TheproposedshortplatcomplieswiththeCriticalAreasRegulationsprovidedtheapplicantcomplieswithCityCode,seeFOE16.4.TheproposedshortplatcomplieswiththesubdivisionregulationsasestablishedbyCityCodeandstatelaw,seeFOF17.5.TheproposedshortplatcomplieswiththestreetstandardsasestablishedbyCityCode,seeFOE17.6.Thereareadequatepublicservicesandfacilitiestoaccommodatetheproposedshortplat,seeFOE18.J.DECISION:ITheOldHighlandsLibraryShortPlat,EileNo.LUA16-000960,SHPL-AasdepictedinExhibit2,isapproved.DATEOFDECISIONONLANDUSEACTION:SIGNATURE:Applicant:CityofRentonMichaelKirk10555.GradyWayRenton,WA98057Applicant:NorthwestSelectRealEstateServicesCassandraHaavistoP0Box489MapleValley,WA98038TRANSMuTEDthis;stdayofMarch,2017tothePartiesofRecord:PaulRusso1217JeffersonAveRenton,WA98056Frederick&CherieCrothamel72175E29thSt.MercerIsland,WA98040CityofRentonDepartmentofCommunity&EconomicDevelopmentOLDHIGHLANDSLIBRARYSHORTPLATAdministrativeReport&DecisionLUAI6-000960,SHPL-A)JenniferHenning,PlanningDirecrTRANSMITTEDthis;stdayofMarch,2017totheOwner/Applicant/Contact:t(tfTDateOldHighlandsLibraryShortPlantAdminReportOldHighlandsLibrary City of Renton Department of Community & Economic Development Administrative Report & Decision OLD HIGHLANDS LIBRARY SHORT PLAT LUA16-000960,SHPL-A Report Date: March 1, 2017 Page 10 of 10 Old Highlands Library Short Plant D__Old Highlands Library_170301_v1 TRANSMITTED this 1st day of March, 2017 to the following: Chip Vincent, CED Administrator Brianne Bannwarth, Development Engineering Manager Lillian Watson, Property Services Vanessa Dolbee, Current Planning Manager Fire Marshal K. 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 March 14, 2017. 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 administrative short plat decision will expire two (2) years from the date of decision. A single one (1) year extension may be requested pursuant to RMC 4-7-070.M. 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.