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SPOKANE COUNTY HEARING E R
RE Setback Vanance in the Urban ) FTNDINGS OF FACT,
Residenhal-22 (LTR-22) zone; ) CONCLUSIONS OF LAW,
Apphcant Irvin Water Distnct No 6) AND DECISION
File No VE-5-00 )
I, S Y OF PROPOSAL AND DECISION
Proposal: Apphcation for a structure height vanance, in the ex.istuig Urban Residennal-22
(UR-22) zone, to allow construchon of a pubhc utlhty standpipe reservoir for water storage at a
maxunum height of SS feet
Decision: Approval, subject to cond.itions
The Heanng Examiner has reviewed the apphcation for a vanance permit and the
evidence of record, and hereby adopts the following findings of fact, conclusions of law and
decision:
1. BACKGROUND/FINDINGS OF FACT
A. GeneralInformation:
Applicant/Site Owner: Irvui Water Distnct No 6, 11907 East Trent Avenue, Spokane, WA
99206
Location: Generally located less than 300 feet east of the northerly ternunus of Cherry
Street, approximately 800 feet east of State Route No 27 (Pines Road), in the NW '/4 of Secnon
10, Townslup 25 North, Range 44 EWM, Spokane County, Waslungton
Legal Description: The subject property, and the easement for access and pipehnes to the site,
are descnbed on the attachment to the vanance application subnvtted on 3-20-001n File No
VE-5-00
Parcel Number: County Assessor tax parcel no 45102.9046
Zoning: Urban Residenhal-22 (CTR-22) The site is also located inside the Aquifer
Sensitive Area (ASA) Overlay zone and the Public Transit Benefit Area designated by the
Zonuig Code
Comprehensive Plan: Urban category The site is also located mside the ASA, the Pnonty
Sewer Service Area and the Urban Impact Area designated by the Plan
HE Findings, Conclusions and Decision VE-5-00 Page 1
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Critical Areas: County Cntical Areas maps designate Urban Natural Open Space throughout
the site. Such maps also designate erodible soils on the site Some slopes on the site exceed 30%
- IUGA: The site is located inside the mtenm urban growth area boundanes desigaated y the
County pursuant to the State Growth Management Act
Environmental Review: The vanance proposal is exempt from SEPA review, pursuant to
WAC 197-11-800 (2)(e)
Site Description: The subject property is 16,553 square feet in size, rectangular in shape and
consists of a solid rock outcrop The site is the highest pomt m the area A low, relatively flat
saddle bisects the nuddle of the site from north to south Several large pine trees are located on
the property The site is undeveloped, and currently accessible only by foot. An access and unhty
easement extends northerly from the proposed reservoir site for some distance, contuiues
northwesterly for some distance, and then extends due west all the way to SR-27.
Surrounding Conditions: SR-27 west of the site is a 4-lane state highway unproved wnth
curb and sidewalk ui the vicuuty, and connects to Interstate 90 to the south. Mirabeau Parkway
to the north and east is designated by the County as a 3-lane artenal, wlule Indiana Avenue to the
south is designated as a Muior Artenal Mirabeau Parkway provides a new route from SR-27 to
the Spokane Valley mall, located south of Indiana Avenue, between Evergreen Road extended
and Sullivan Road. Cherry Street, wluch cul•de-sacs a few hundred feet west of the subject
property, extends southerly to Mansfield Road Mansfield Road extends westerly to SR 27
The site is bordered on the north and west by a 15-acre parcel zoned UR-22, which is
unproved with apartments to the west and is undeveloped to the north A school distnct
admirustration building on land zoned UR-22 is found northwest of the site, north of Grace
Street. The land lyuig south of the site is zoned UR-22 and developed wnth apartments. The
densrty of the multi-family housing in the area is approximately 16 dwefling units per acre The
nearest single-fanuly residences are generally found northwest of the site, west of SR-27
The land 1}nng east of the site is zoned Rural Residennal-10 (RR-10), is owned by the
Washington State Deparbment of Natural Resources, is in a conservancy status as a natural area,
and consists of a ponderosa pine woodland with large rock outcroppings Such land is
undeveloped, except for a cyclone fence with barbed wire that runs from north to south in the
vicinity. Some Light Industnal (I-20 zorung has recently been approved along the south and
west sides of Mirabeau Parkway in the area, as part of the undeveloped Mitabeau Commercial
and Industnal Park project See Heanrig Examiner decision dated 8-17-99 in Planning File No
ZE-37-96
The area surroundmg the site is illustrated as Urban Natural Open Space on the County
Cntical Areas maps wluch designate pnonty vvildlife habitat
Project Descriptioa: The application requests a vanance in the existulg UR-22 zone to allow
a steel standpipe reservou (tank) for water storage to be installed at a maximum height of 85 feet,
whereas the UR-22 zone allows a maximum structure height of only 50 feet The site plan of
record submitted on March 20, 2000 illustrates development of the proposed reservolr in the
approxunate middle of the site, and shows requued landscaping along the site penmeter The
HE Findings, Conclusions and Decision VE-5-00 Page 2
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site plan illustrates a transmission maui extending northwesterly from the reservoir, vnth an
access and utilrty easement extending from the site northwesterly all the way to SR-27 The
reservou would contain approximately 875,000 gallons of water At the public hearuig, the
apphcant testified that the reservou would need to be located approximately 20 feet further to the
east on the site, vvrthin the relatively flat saddle area, to provide a more stable foundation.
B. ProceduralInformation,:
Applicable Zoning Regulations: Chapters 14 404 and 14 622 of Spokane County Zoning Code
Hearing Date and Location: May 31, 2000, Spokane County Pubhc Works Biulding,
Lower Level, Commissioners Assembly Room, 1026 West Broadway, Spokane, WA
Site Visit: May 29, 2000
Notices: Mailed May 10, 2000
Comphance: The legal requirements for pubhc notice have been met
Hearing Procedure: Pursuant to County Resolurion Nos. 96-0171 and 96-0294
Testimony:
James Richardson Nlichael Morse
Division of Current PlaYUUng Inc•
1026 West Broadway 7147 North Flemming
Spokane, WA 99260 Spokane, WA 99208
Items Noticed: Spokane County Generalized Comprehensive Plan, County Zorung Code,
County Code, County Cntical Areas C?rdinance, County Guideluies for Stormwater
Management, County Artenal Road Plan maps, and County Cntical Areas maps Final land use
decisions referenced in Staff Report
County Resolunon Nos 98-0201 (amending Guidehnes for Stormwater Management),
97-0874 (revising mtenm regulations for County NGAs), 97-0321 (adophng mtenm regulahons
for County IUGAs), 97-0134 (establislung County IUGA boundanes), 96-0294 (Hearmg
Exammer Rules of Procedure), 96-0171 (Heanng Exammer Ordinance), and 95-0498 (adopting
Guidelines for Stormwater Management), and 85-0900 (adophng Zonuig Code, and Program to
Implement Zonuig Code)
Procedural Matter: After the public heanng, the Exammer received a copy of a geo-hazard
evaluation dated 6-6-00 subrrutted by MSCE, Inc , consultmg engineers for the applicant Since
the project had no opposirion, and a geo-hazard evaluatton was requued for the project, the
Exammer has reopened the record to include such evaluation in the record
In drafting this decision , the Exammer also discovered that the site is illustrated as Urban
Natural Open Space on the County Cntical Areas maps wluch designate pnonty wildlife habitat
A condition of approval has been added to address this matter
HE Findings, Conclusions and Decision VE-5-00 Page 3
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III. LAND USE ANALYSIS
FINDINGS OF FACT & CONCLUSIONS OF LAW
1 Because of sroecial circumstances apphcable to the property, includmg steeu slones.
elevarion and the water needs of the area, stnct applicanon of the maximum 50-foot structure
heieht reauired bv Zorung Code 14 622 335 in the Urban Residential-22 ([JR-22) zone creates
nrachcal difficulties and deunves the property of nghts and pnvileges enjoyed bv other
nro»erhes in the vicinitv and zoned UR-22 The granhng of the vanance will not be detnmental
to the vublic welfare, nor iniunous to the property or improvements in the vicuuty and UR-22
zone The factors set forth in Zomng Code 14 404 082 (2) are substantiated, and grantint of the
vanance will not violate anv of the factors set forth in Zoning Code 14 404 082 (3) T'he
mimmum reauuements of RCW 36 70 810 have been established
The apphcant requests a vanance to allow an 85-tall water standpipe reservoir to be uistalled
on the site, while the UR-22 zone allows a maximum structure height of only 50 feet
The srte is designated in the Urban category of the Comprehensive Plan The Urban
category is intended to provide the opportunity for a"citylike" envuonment, including a vanety
of land uses served by a lugh level of pubhc facihties and sernces It is pnmanly a residential
category of single-family, two-fanuly, multifamily and condomuuum buildings, along with
neighborhood commercial, light mdustnal, pubhc and recreational facihties. A residenhal
density (net) of one (1) to 17 dwelling wuts per acre is reconunended
The Urban category states that the more intensive uses such as hght industrial and
neighborhood commercial should be located near the heavily traveled streets, with the less
intensive uses such as residential isolated from the noise and traffic Major commercial, heavy
industnal, agncultural and miiung uses are not considered compatible within areas of the county
designated Urban Comprehensive Plan, Section 1
The Urban category includes, wnthout limitaUon, the follownng relevant pohcies•
Objectzve 1 1 a Promote fill-in wtthrn establzshed development areas and
exjsting outlying communihes where utclihes, arterlals, schools and
com»:untty faciltties have already been estabhshed
Decision Guideline 1 1 1 Urban development will be approved rn areas
having adequate power supplies, water, sanitary and storm sewers,
streets, and school and f re servcces, provcded that such development
meets the intent of other Objechves and Deci.szon Guidelcnes of this
sectioti
Dectsron C'ntideline 112 Base net density for sangle famrly dwelling
areas and for mulhfamily dwellcng areas may be tncreased throicgh bonus
densities, zero lot lines or similar methods when meetrng the fill-in
crtterra
Decision Guideline 114 A variety of densities and resrdennal uses
shocrld be avazlable to provide a freedom of choice to live in Urban areas
HE Finduigs, Conclusions and Decision VE-5-00 Page 4
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y
with varying densittes, combinattons, or mrx of uses (see detailed Urban
deftnrtions)
Objecnve 12. b Ensure adequate open space, recreational facilihes and
parks for residennad development
Decision Gutdelme 12 2 The need for recreatron and open space created
by residennal developments should be met and be in conformance wtth
ordinances, plans, and polictes pnor to residential development approval
Decision Gurdeline 1 31 Proposed Urban developments should be
designed to benefit from, accommodate and complement the
environmental condttions and environmental features
Decision Guideline 13 Z The destgn or adoption of a proposal shall
consider the retention and maintenance of idenhfied "unique
environmental features "
Decision Gutdelrne 13 3 All Urban development proposals should
requtre public saratary and storm sewer systems or intenm sewer systems
to protect water qualaty
Decision Guideline 13 4 Activihes should be guided by policres outlined
within the State Shorelines Management Act and the Spokane County
Shorelrne Program
Decision C'ruideline 1.41 Development shall not occur on lands rdenhfied
as betng tn a 100 year f lood plain or crs havrng a history of f looding,
unless the developer constructs rriechanrsms
a) accepted by the~'inancing instrtution and by the Counry Engineers
as capable of protechng life and property from flood damage, and
b) whrch do not increase or change water flows whtch may damage
other property
Dectsron Guideline 14 3 Urban development proposals and their deszgn
shall consider the retentton and maintenance of afj`'ected fragile wildl fe
areas and/or unrque environmental areas identified by the County
Ob,Jecttve 15 a New residentral or multiple family should be buffered
from extsttng adjacent land uses where adverse effects may develop
Decision Guideline 15 1 Bufferrng and/or landscaping will be used to
mitigate the daf~`'erences between proposed developments and extsnng uses
Deczsron Guideline 15 4 Sidewalk facilihes wrll be required along
arterials connecttng resjdential areas wrth community facrhties and/or
commercial areas
Decision Guideline 15 S Paved streeis and street lights should be
required in Urban density development
Objective 15 e When a neighborhood experiences pressure for change zn
character, such change shall be permctted upon appropriate revtew
HE Findings, Conclusions and Decision VE-5-00 Page 5
Objecttve 1.5 8 When determrning whether a proposal will change the
exishng land use character of an area, factors to consider may include •
a) the structure height of the proposal in relation to structure herght of
nearby structures, and
b) whether new structures wzll have a posahve or negattve impact upon
the neighborhood s archztechrral character
Deciston GuTdeline 1 61 Before land use proposals are approved they
should
a) conform to plans, policies and regulations of County water, sewer,
storm sewer,
b) uttlity and spectal service districts,
c) conform to County transportanon plans and polictes, and
d) tdentify and take steps to resolve signaficant adverse impacts upon
existing utilittes, (i e water, santtary and storm sewers, uhlity,
avarlable and future energy resources), and traffic systems
The Cnrical Areas secnon of the Comprehensive Plan contauis poucies for pnonty vv~ldhfe
habitat, geologically hazazdous areas, wetlands and environmentally sensitive areas These
pohcies are implemented pnmanly through the County Cnhcal Areas Ordinance, codified in
chapter 11.20 of the County Code
Secnons 22-24 of the Comprehensive Plan encourage the review authonty to consider the
unpact of development on existuig water and sewer facihties, and generally require that the use
of such facilities be in accordance wrth adopted policies and plans for uhlities, such as the
Coordinated Water System Plan and the Comprehensive Wastewater Management Plan. The
Coordinated Water System Plan indicates that the site is served by the apphcant, Irvin Water
Distnct No 6
The site is currently zoned Urban Residential-22 (UR-22), a zone wluch specifically
implements the Urban category of the Comprehensive Plan Zoning Code 14 622.100, sets forth
the purpose and intent of the UR-22 zone, as follows.
The pacrpose of the UR-22 zone is to set standards for the orderly
development of residential property in a manner that provrdes a desirable
livtng envtronment that cs compattble with surrounding land uses and
assicres the protection of property values It is cntended that this zone be
used to add to the variety of housing types and densittes, and as an
implementation tool for the Cornprehensrve Plan Urban Category General
characteristics of these areas include paved roads, publtc sewer and water,
accessibility to schools and Itbrartes, and a full hne of picblic services
cncltrdzng manned fire protection and publrc transit accessibtlity Offices
are perniitted in the UR-22 zone rn order to provide some of the service
needs generated by high-rntensity land uses The highest density residefitial
zone, UR-22 is tntended primarily for multiple family dwellings and is
usually located adjacent to major or secondary arterials It is used as a
transrtron between low or medium density multiple family uses and intensive
commercial or low intensity rndustnal uses and to provrde for higher density
housing in locations close to employment, shopping and major
HE Findinjs, Conclusions and Decision VE-5-00 Page 6
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transportation where movements of people can be handled effieiently and
with least overall adverse impact
A"public uhhty local distnbuhon system", which is defined by the Zoni.ng Code to
include, wrthout lunitarion, any building, structure or device which transfers duectly to the
public water provided by a pubhc utility, and all other necessary facilities, eqwpment and
structures necessary for conducting a local distnbution of water by such uhlity, is a permitted use
in the UR-22 zone See Zomng Code 14 300 100 (defuuhons), and Zomng Code Chapter
14 605 Such use must still comply with the development standards of the UR-22 zone Zomng
Code 14 622.335 unposes a maxunum structure and bwlding height of 50 feet in the UR 22
zone If the water standpipe reservoir conshtutes a"pubuc uhlity local distnbution system",
then a height vanance is needed by the apphcant
Zomng Code 14 300.100 provides a separate definition for a"pubhc utahty transmission
facihty". The defuunon vvith regard to water facihties is sunilar to that for a"pubhc utlhty local
distnbution facilrty", except that the utility service is transferred indtrectly to the pubhc, instead
of directly. Such definition specifically includes substahons, swrtclung stahons and
"reservoirs" A"pubuc unhty transmission facihty" is a pernutted use in the UR-22 zone,
subject to certain special development standards, uicluding a showing that the use is comparible
wnth surrounduig propemes See Zomng Code 14.622 210 (B)(1). The maximum permissible
height for such facilrty in the UR-22 zone is 125 feet, meatung that the apphcant would not need
a vanance for the project The other general development standards of the UR-22 feet, other than
maximum height, as well as the special development standards for such use, would still have to
be complied with.
It is not at all clear to the Examiner wluch defuution set forth above best fits the project.
Water from the reservou would appear to duectly serve the pubhc, however, the defininon of
"public utility transrrvssion facility" specifically includes a"reservoir" Since the apphcant has
not contested the apphcability of the maximum height lunitation of 50 feet in the UR-22, the
Exanuner has analyzed the project as if it was a"pubhc uhhty distnbuhon facilrty". Smce the
project proposes a height of 85 feet, a height vanance is required The Division of Planiung is
strongly encouraged to consult with the Civil Division of the County Prosecutor's office for an
interpretarion of the Zomng Code wrth regard to sumlar projects in the future, to ensure that a
height vanance is not being needlessly required
The proposed water pipe would be installed pursuant to the applicant's water system plan
recently approved by the Washington State Department of Social and Health Services, wluch
necessrtates that the water pipe be placed at an elevation such as the srte provides. The site
represents the best of the alternative sites avallable to the apphcant See teshmony of Michael
Morse The rocky nature of the site and its steep rock outcroppings precludes most development,
including residential and commercial uses, allowed in the UR-22 zone.
County Cntical Areas maps designate the site within a geologically hazardous area due to
the presence of erodible soils The soil type on the site, SuE, is listed as presenting a severe
threat of water erosion in Appendix H of the Cnncal Areas Ordulance The srte also contains
some extremely steep slopes, well in excess of 30% A geo-hazazd evaluatton should have been
submitted to the Division of Plaruung before the public heanng, but was erroneously found not to
be necessary by County staff
HE Fmdings, Conclusions and Decision VE-5-00 Page 7
After the public hearing, a geo-hazard evaluation was subnutted by a qualified engineer
retauied by the applicant. The evaluation has been admitted into the record by the Examiner.
See letter dated June 6, 2000 from MSCE, Inc. to James Richardson. The geo-hazard evaluation
indicates that the erodible soils of concern exist primanly along the route of the reservoir
transnussion maui and access route The evaluation is comprehensive and appears to adequately
identify and evaluate the geo-hazards presented by development of both the site and the
associated access and unlity easement, and recommend nutigating measures. The Examiner has
added a cond.inon of approval requinng that such mitigatuig measures, and any addihonal geo-
hazard mitigahon plan required before site development, be followed
County Cntical Areas maps designating pnonty vvildhfe habitat designate the site and
surrounding area wnthin Urban Natural Open Space The Staff Report fails to note tZus, and the
Exammer discovered such designation after the public heanng upon reviewing the applicable
map The Exammer cannot sunply overlook this requirement The County Cnhcal Areas
Ordmance in such uistances reqiures the County Division of Planning to contact the Washuigton
State Department of Fish and Wildlife (WDFV), to help deternune if a habitat management plan
is needed
Considenng the relatively low unpact of the project, the location of the site outside the
fenced conservancy area owned by the Washington State Depardment of Natural Resources to the
east, and the Examiner's expenence with WDFW's typical recommendations for minor
developments proposed in Urban Natural Open Space, the chances are extremely lugh that the
Washington Department of Fish and Wildhfe (WDFV) would not request preparation of a
habitat management plan for the proposal The Exammer has therefore added a condition of
approval requinug Division of Planiung staff to contact the WDFW and make a detemunation as
to whether a habitat management plan is requued if so, the applicant is required to comply with
the recommendahons of such agency
The Staff Report otherwise provides a logical and sufficient analysis of the consistency of
the project with the vanance cntena contained in the County Zomng Code, which analysis the
Exammer hereby uicorporates hereui and adopts by reference as findings of fact and conclusions
of law. This also sansfies the sunilar vanance cntena contained m RCW 36.70 810
As conditioned, the apphcation will be reasonably compatible with neighboruig land uses,
complies with apphcable development regulations and generally conforms with the
Comprehensive Plan and the purpose and intent of the UR-22 zone
IV. DECISION
Based on the Findings of Fact and Conclusions of Law stated above, the application for a
vanance from the requirement of the UR-22 zone that structures be hnuted to a maxunum height
of 50 feet, to allow development of a public utility standpipe reservou for water storage at a
maxunum height of 85 feet, is hereby approved, subject to the conditions listed below Any
conditions of such agencies which have been added or sigruficantly revised by the Heanng
Exammer are itahcized
HE Findings, Conclusions and Decision VE-5-00 Page 8
,
.
Failure to comply wrth the condirions of this approval may result in suspension or
revocation of the vanance by the Heanng Examuier.
SPOKANE COUNTY DIVISION OF PLANNING
1. All condrtions unposed by the Hearing Exanuner shall be bindmg on the "Appucant",
wluch term shall include the owner(s) and developer(s) of the property, and theu heirs, assigas
and successors
2. The proposal shall comply wnth the Urban Residenhal-22 (LTR-22) zone, the Aquifer
Sensitave Area Overlay zone, and other appltcable provisrons of the Spokane County Zorang
Code, as amended
3. The apphcant shall develop the subject property in substanhal accordance with the site
plan of record submitted to the Division of Planntng on March 20, 2000, provided, that the
standpipe reservoir may be moved approximately 20 feet east on the site as proposed at the publzc
heanng Minor vanations, to be approved by the Duector of the Division of Planiung/designee,
shall only be allowed to meet development regulations and condihons of approval Any other
modificahon must be subrrutted by wntten apphcation to the Division and approved by the
Heanng Examiner after a public hearuig.
4. This proposal is withn the Aquifer Sensirive Area, therefore any unpervious surfaces
(access roads, out buildings, etc. ) created will need to comply wrth the Gtudeluies for
Stormwater Management Erosion and sediment control will also need to be addressed if any
County permits relating to site disturbmg activities are reqwred, (i e a construction and/or
graduig permrt)
5 Due to its elevated location and the proposed 85 foot height, the landscape screening
required under Section 14 806 of the Zorung Code and as shown on the site plan of record would
have very httle practical effect Further, landscape plantings on the rock outcrop and associated
steep slopes may be unpractical The reservou site contauis a number of large pine trees wluch
have managed to estabhsh themselves on the rock outcrop and should be retained wherever
feasible Pnor to construction, the applicant shall subirut to the Division of Planning a tree
retention plan wluch approximately locates the trees to be removed or retained A review of that
plan will determine whether or not supplemental plantings anll be necessary to satisfy the
landscaping requirement under Section 14 806 of the Zorung Code
6 County Crittcal Areas maps designate the site within Urban Natural Open Space, a praortty
wildltfe habitat Divrston of Planning staff shall promptly contact the Washington State
Department of Fcsh and Wildlife to determine whether a habitat management plan needs to be
prepared if so, the appltcant shall have such plan prepared by a qualified biologrst and
submatted to the Divi.ston for review and approval The applicant shall comply with the
recommendations in the habitat management plan, if approved
7 County Crrtical Areas maps desrgnate the site as having erodtble soils and steep slopes
For any szte development, the applicant shall comply with the recommendations of the geo-
hazard evaluation prepared for the proJect by MSCE, Inc, dated June 6, 2000, as accepted by
HE Findings, Conclusions and Decision VE-5-00 Page 9
/
the Dtvtston of Planning, and any subsequent geo-hazard mingatron plan required to be
prepared by the Dtvtston. %
8 The apphcant shall comply wrth the County Crnccal Areas Ordinance, as amended
DATED this 21 st day of June, 2000
SPOK;ANE OUNTY HEARING E R
~
1Vhchael C. Dempsey, V~BA #82
NOTICE OF FINAL DECISION AND NOTICE OF RIGHT TO APPEAL
Pursuant to Spokane County Resolution No 96-0171, the decision of the Heanng Examiner
on an apphcation for a vanance is final and conclusive unless wrthin twenty-one (21) calendar days
from the issuance of the Exanuner's decision, a party with standing files a land use peuhon m
supenor court pursuant to chapter 36.70C RCW. Pursuant to chapter 36 70C RCW, the date of
issuance of the Hearing Examiner's decision is three (3) days after it is mailed.
Tlus Decision was mauled by Cemfied Mail to the Applicant on June 21, 2000. The date of
issuance of the Hearing Examiner's decision is therefore June 26, 2000, counting to the next
business day when the last day for mailing falls on a weekend or holiday THE LAST DAY FOR
APPEAL OF THIS DECISION TO SUPERIOR COURT BY LAND USE PETITION IS
JULY 17. 2000.
The complete record in this matter, including tlus decision, is on file dunug the appeal penod
wrth the Office of the Heanng Examiner, T'hird Floor, Public Works Building, 1026 West
Broadway Avenue, Spokane, Washington, 99260-0245 The file may be inspected Monday - Fnday
of each week, except holidays, between the hours of 8 00 a m. and 4 00 p m. Copies of the
documents in the record will be made available at the cost set by Spokane County
HE Findings, Conclusions and Decision VE-5-00 Page 10