VE-8-93ZONING ADJUSTOR
SPOKANE COUNTY, WASHINGTON
IN THE MATTER OF A VARIANCE FROM
FLANKING STREET YARD SETBACK
REQUIREMENT
FILE: VE-8-93
APPLICANT: SPOKANE SEED COMPANY
BY WESTERN MILLWRIGHTS
COMPANION FILE(S): CE-273-90;
BP-121-93 AND BUILDING PERMIT
RECORDS FOR E. 6015 ALKI
PARCEL NUMBER(S): 35133.1311
FINDINGS OF FACT,
CONCLUSIONS,
AND DECISION
APPLICATION DESCRIPTION: The applicant proposed to build two grainstorage bins
at the southeasterly comer of the parcel, with a flanking street yard setback of 2 feet from the
lot flanking street (Alki Road) property line; whereas, section 14.634.325.A.3 of the Zoning
Code of Spokane County requires that the minimum flanking street yard setback to be 35 feet.
Authority to consider such a request exists pursuant to section 14.404.080 of the Zoning Code
of Spokane County and Spokane County Board of County Commissioners resolution No. 89
0708, as may be amended.
PROJECT LOCATION: West Spokane Valley, at the northwest corner of the intersection
of Alki Avenue and Lake Road, one block east of Fancher Road, in SW 1/4 of Section 13,
Township 25N, Range 43 EWM; 6015 E. Alki Avenue.
OPPONENTS OF RECORD: NONE
PUBLIC HEARING AND DECISION: After consideration of all available information
on file, exhibits submitted a personal tour of the area, a review of other flanking street yard
variances in the area, and testimony received during the course of the public hearing held on
October 13, 1993, the Zoning Adjustor rendered a written decision on October 26, 1993 to
DENY the application as set forth in the file documents. A lesser Administrative
Exception is granted pursuant to section 14.506.020.9. of the Zoning Code of Spokane
County, to 20 feet from the Alki Avenue property line, as set forth below.
FINDINGS OF FACT
1. Testimony was taken under oath.
2. The proposal is exempt from the provisions of the Washington State Environmental
Policy Act, Chapter 43.21C RCW pursuant to WAC 197-11-800 (6) (b).
3 . The reasons for granting the variance, as set forth by the applicant, are as follows.
a. There is a need for more storage at the site and the site is built to the point
that no additional storage can be added within the 'footprint' provided by
the zoning regulations.
CASE NO. VE-8-93 SPOKANE COUNTY ZONING ADJUSTOR PAGE 2
b. Approving the variance and the additional storage would create less dust,
conserve energy (due to less handling of the material) and reduce the waste
associated with excessive handling of the product. Adding these two bins
increases the efficiency of operation and hence reduces the environmental
costs.
c. The variance is required for a continued and enhanced economic return from
the property through more efficient storage and handling of the peas and
lentils.
4. Numerous factors and circumstances were noted by the Zoning Adjustor as a result
of a site inspection and a discussion between the Zoning Adjustor and the applicant during the
hearing.
a. The applicant owns a sizeable parcel of land immediately to the south,
across Aiki. Although this site as storage may have its own complicating
factors with a franchise from the County Engineer's regarding air rights or
subsurface ground rights, storage is possible to the south with conveyance
under or above the roadway to the processing plant on the north side of
Alki.
b. In that discussion the applicant disclosed that it is their eventual intention to
bring the processing portion of their operation for peas or lentils across Alki
to the south and separate the storage and processing of peas and lentils onto
the two separate sites (one side of Alki for peas and the other for lentils).
c. An inspection of the area by the Zoning Adjustor disclosed numerous
instances in which new construction has occurred on the south side of Alki,
clearly adhering to the 35 foot setback for the buildings, with the front yard
areas for landscaping, storm water drainage disposal and parking areas. In
the general area there appears to be no instance of lawful single digit
dimension setbacks from the property lines, although there appears to be
numerous setbacks of approximately 20 feet. A color aerial photograph
looking northeasterly across the property depicts the general setbacks in the
area and substantiates that, at least along Alki, there would be no similar
setbacks rivaling the one sought by the applicant.
The present site of the proposed storage bins contains a shop building and
fenced outdoor storage area for various materials related to the entire
processing storage at the Alki site. A review of building permits after the
public hearing (by the Zoning Adjustor) disclosed information generally as
follows. The site on the north side of Alld has been the subject of many
building permits over the years. The file for E. 6015 Alki is extensive. Of
particular interest is the slow but steady expansion of the site, including
both the processing operation and additional storage bins. Slowly but
surely the number of storage bins and buildings added has consumed nearly
all of the lawfully buildable site east and southeast of the processing plant.
The shop structure is an exception to the storage bin phenomena. The
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CASE NO. VE-8-93 SPOKANE COUNTY ZONING ADJUSTOR PAGE 3
building permit for the main portion of the storage building was issued on
June 5, 1972 (permit J3370) and the site plan showed a 35 foot setback for
the 40 foot by 24 foot building. Most site plans on building permits
subsequent to that continue to re -verify a 32 to 35 foot setback from Alki.
On October 26, 1978, a 24 foot by 30 foot addition (building permit
M1427) was granted to this same shop building. The site plan for M1427
indicated the existing shop (building permit J3370) as being 45 feet from the
south property line at Alki. A detailed site plan associated with a 1980
building permit (80B-1456) shows the shop building constructed only about
25 feet from the Alki property line. This same building permit also indicates
a storage yard fence (not lawfully authorized) approximately 3 feet from the
Alki property line. The shop building, which is proposed to be replaced by
the two storage bins appears not to have been built as per the submitted site
plans which then recognized Alki as the front yard for the site, wherein a 35
foot setback was required by the former Spokane County Zoning
Ordinance.
d. With the establishment of the Zoning Code of Spokane County on January
1, 1991, Alki became the flanking street yard and Fancher and Lake Roads
became front yards. The setbacks for both Alki, Fancher and Lake are now
35 feet under the Zoning Code.
e. Spokane County Engineer's Office has recommended a'site distance,
braking and stopping analysis' be submitted as part of the application for
review prior to any approval (reference: October 11, 1993 memorandum
from the Spokane County Division of Engineering and Roads, Office of the
Spokane County Engineer). The expressed concem of the engineers is that
the location of the proposed bins (at 2 feet from the Alki property line) may
well provide a view blockage inconsistent with the public health, safety and
general welfare of the traveling public on Alki. They suggested the
recommended study would quantify any problem and would recommend
mitigating measures.
f. Subsection 14.506.020.9. of the Spokane County Zoning Code addresses a
possible allowable Administrative Exception to a flanking street yard
setback. The criteria for granting an administrative exception for a flanking
street yard setback is substantially less prescriptive than granting a variance
under section 14.404.080 of the Zoning Code (variance). In a
memorandum of November 12, 1991, the Planning Director established
general criteria for granting Administrative Exceptions. Number 8 of that
memorandum addressed an example and stated 2 criteria for granting the
flanking street yard setback administrative exception. These provisions
would allow the granting of an administrative exception for a 20 foot
setback from Alki (as opposed to the required 35 foot setback). The criteria
set forth by the Planning Director, specifically "...inability to expand
existing structure, add garage, etc...." is applicable to the subject
application. Additionally, the granting of such an administrative exception
should not, by the Planning Director criteria, create a burden for adjoining
property owners.
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CASE NO. VE-8-93 SPOKANE COUNTY ZONING ADJUSTOR PAGE 4
g. The Zoning Adjustor introduced various previous flanking street variance
decisions in the near vicinity. The various case numbers were read into the
record, along with a summary of the decisions. Generally, the decisions
where either denial or the granting of a variance to approximately one half of
the standard. In only one or two instances were variances granted
approaching the degree requested by the applicant. In several instances the
previous Zoning Adjustors specifically described that the problem
necessitating an application for a variance: would apply to almost any
property owner or proposal; is or is not related to the personal situation of
the applicants; is either related or is not related to unique circumstances at
the property and; is or is not related to the general condition of the
surrounding or adjacent properties.
h. The two sites which the applicants own are both flat and of common
rectilinear shape, encumbered by no special circumstances related to the
land; except that the north property is 'built out.'
The Division of Engineering and Roads' request for a study needs to be
kept foremost in the minds of any appeal body considering the appeal of this
decision.
5. Where the problem complained of is common to land in the area or throughout the
community, the proper solution is legislative rezoning, rather than piecemeal administrative
exemption. The alleged problem or hardship must relate to the land. Community needs or
personal hardships do not qualify as legitimate grounds for issuing a variance. (Zoning and
Land Use Controls, Rohan, § 43.02 [4][b][i]).
6. Section 14.404.082 of the Zoning Code addresses the requirements for granting a
variance. Subsection 1 of the above section is as follows:
1. Any variance from the terms of the Zoning Code shall be subject to such conditions
as will (a) ensure that the adjustment shall not constitute a grant of special privilege
inconsistent with the limitations upon other properties in the vicinity and similar
zone classification in which the property is situated, (b) ensure that the intent and
purpose of the Zoning Code is maintained with regard to location, site design,
appearance, landscaping and other features of the proposal, and (c) protect the
environment, public interest and general welfare, and that the following
circumstances are found to apply:
a. Because of special circumstances applicable to the property, including size,
shape, topography, location or surroundings, the strict application of the
Zoning Code creates practical difficulties and is found to deprive the property
of rights and privileges enjoyed by other properties in the vicinity and similar
zone classification; and
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CASE NO. VE-8-93 SPOKANE COUNTY ZONING ADJUSTOR PAGE 5
b. That the granting of the variance will neither be materially detrimental to the
public welfare nor injurious to the property or improvements in the vicinity
and zone in which the property is located. (emphasis added)
Subsection 4 of the above section defines several key terms, one of the most important of
which is 14.404.082.4.e wherein 'practical difficulties' are established as one or more of any
number of differences and privileges characteristic of a property due to a combination of special
circumstances and standards of the Code: provided, that a practical difficulty shall not solely
be a parcel alleged to be too small for a given use if the subject property can be put to any
number of similar or alternative uses conforming to the standard. (emphasis added)
CONCLUSIONS
1. Special circumstances (Zoning Code, § 14.404.082.1.a. and § 14.404.082.4.b.)
are not found to exist such that the application of the zone creates a practical difficulty (Zoning
Code, § 14.404.082.4.e.i.).
2. The property is not deprived of rights and privileges enjoyed by other properties in
the vicinity and similar zone classifications (Zoning Code, § 14.404.082.4.a., c. and d.).
Reasons for granting a variance must be reasons pertaining to the property itself which prevent
full use of the property to the extent other properties in the vicinity and under the same zoning
can be used. RCW 36.70.810(2)(a).
3. Strict application of the 35 foot setback on Alld arguably can create an unreasonable
burden in light of the purpose to be served by the Zoning Code. The purpose of setbacks is to,
among other things, create a uniform visual relief in a zone along the street side environment.
It is also for the purpose of creating visual corridors for the purposes of safety of the traveling
public with respect to ingress and egress from private properties onto the public thoroughfare.
A setback of 2 feet places a major visual obstruction to the point where the public safety is
jeopardized (reference comments from the Spokane County Engineers Division of Engineering
and Roads memorandum). However, application of the previous flanking street standard
(Zoning Code, § 14.506.020.9.) achieves the purpose and intent of the Zoning Code for visual
relief and protection of the health, safety and general welfare of the public. For the proposal,
although it is not to the degree to which the applicant seeks relief, the 20 foot setback provision
as provided in the Administrative Exception portion of the Zoning Code (§ 14.506.020.9) is
grantable since it addresses an expansion/intensification issue and does not adversely affect
adjacent property.
4. A broader public or communion need or interest will not be served by granting the
variance. Granting the variance requested by the applicant, will, as described above, place the
traveling public and those private parties entering the public right-of-way from the Alki
property line, at some degree of risk. Furthermore, the applicant company, and to a lesser
extent some consumers of peas or lentils, are the benefactors of the variance, if granted.
Evidence of hardship or difficulty that will support a variance must relate to the land itself and
not to the owner -applicant (St. Clair v. Skagit County, 43 Wn App. 122, 126, 1986).
VE-8-93
CASE NO. VE-8-93 SPOKANE COUNTY ZONING ADJUSTOR PAGE 6
5. Granting the variance to 2 feet from the property will establishes a precedent which
will adversely affect the zoning concept for the area and the County as a whole. The qualifying
criteria for a variance is not met by the proposal and to grant the variance opens all industrial
properties in the county to serious consideration of a similar degree of relief. Granting relief to
20 feet from the property line is an application of the Administrative Exception of Chapter
14.506 of the Zoning Code, which has a considerably lower threshold for granting than does
the criteria for variances established in the Zoning Code.
6. The variance should not be granted substantially based upon the lack of reasonable
economic return (Zoning Code, § 14.404.082.3.c.).
7. If the application for variance were to be granted, the Zoning Adjustor or Board of
Adjustment would have no basis for denying subsequent variance applications by other owners
under similar circumstances. With no special circumstances at the site, this would amount to a
defacto text amendment to the Code; an authority neither Hearing Body possesses.
8. The applicant has not presented a convincing case that a broader public or
community need or interests would be served by granting the variance, as opposed to denying
the application.
9. Rohan, in Zoning and Land Use Controls, § 43.02 [5], states that over the years a
number of factors have been considered by courts with respect to granting variances. These
include: (1) whether strict compliance with the terms of the ordinance will preclude a permitted
use from being pursued; (2) whether the land will yield a reasonable return; (3) the degree to
which the applicant seeks to vary from the ordinance; (4) the degree of harm which will be
imposed on the surrounding area if the variance is granted; (5) whether some other method can
be pursued to avoid the need for the variance; (6) whether the difficulty is self imposed; and (7)
whether the interest of justice and the general welfare will be served. Rohan continues that no
factor alone controls and all must be considered. It is a balancing act of the competing interest
between the landowner and the community, as expressed through the zoning document.
As the Zoning Adjustor considered all the facts, testimony, relevant case law and
instructive usefulness of Rohan's Zoning and Land Use Controls, it is concluded that the
balancing test of competing interest lies with he variance request as being: (1) primarily to the
benefit of the applicant; and (2) generally to the detriment of the local area and the community,
as a precedent which would destroy the purpose and intent of the concept of building setbacks
set forward in the Zoning Code adopted by the Board of County Commissioners.
10. The proper legal requirements for advertising of the hearing before the Zoning
Adjustor of Spokane County have been met.
DECISION
From the foregoing Findings and Conclusions, the Zoning Adjustor DENIES the
applicant's proposal as generally set forth in the file documents and instead APPROVES an
Administrative Exception to 20 feet from Alld Avenue.
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CASE NO. VE-8-93 SPOKANE COUNTY ZONING ADJUSTOR PAGE 7
CONDITIONS OF APPROVAL
I. GENERAL
1. The following conditions shall apply to the applicant, owner and successors in
interest and shall run with the land.
2. Failure to comply with any of the conditions of approval contained in this decision,
except as may be relieved by the Zoning Adjustor, shall constitute a violation of the Zoning
Code for Spokane County and be subject to such enforcement as is appropriate.
3 . The Zoning Adjustor may administratively make minor adjustments to site plans or
the conditions of approval as may be judged by the Zoning Adjustor to be within the context of
the original decision.
II. PLANNING DEPARTMENT
1. Although, grain storage bins are the intended land use, other structures may be
reviewed and approved by the Zoning Adjustor.
2. Prior to development of the property under the authority of this decision, the
applicant shall submit a site plan for approval by the Zoning Adjustor. The site plan shall
accurately indicate the Alki Avenue property line, existing physical features, and overlay the
outline of the grain storage bins. The approval of this site plan by the Zoning Adjustor does
not supersede or take the place of any site plan requirements required through the building
permit process and associated with complying with the underlying standards of the I-3 zone for
new construction.
3. In the event this variance denial and approval of a subsequent administrative
exception approval is overturned by the Board of Adjustment or a court of competent
jurisdiction, it is highly recommended that the requested engineering study be undertaken if the
storage bins or other construction is to be closer than 20 feet to the Alki Avenue property line.
III. DEPARTMENT OF BUILDINGS
1. The applicant shall contact the Department of Buildings at the earliest possible stage
of design/development in order to be informed of code requirements administered/enforced as
authorized by the State Building Code Act. Design/development concerns include: Fire
Apparatus Access Roads; Fire Hydrant/Flow; Approved Water Systems: Building
Accessibility; Construction Type; Occupancy Classification; Exiting; Exterior Wall Protection;
and Energy Code Regulations.
None is needed.
IV. DIVISION OF UTILITIES
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CASE NO. VE-8-93 SPOKANE COUNTY ZONING ADJUSTOR PAGE 8
V. HEALTH DISTRICT
None is needed.
VI. DIVISION OF ENGINEERING AND ROADS
1. In the event a variance or other deviation is granted to closer than 20 feet to the Alld
Avenue property line the following should apply:
The County Engineer has reviewed this proposal and requests that a site distance,
braking and stopping analysis be submitted as part of the application for review
prior to approval being granted for the project. This analysis shall be as
prescribed in A POLICY on GEOMETRIC DESIGN of HIGHWAYS and
STREETS, prepared by the AMERICAN ASSOCIATION OF STATE
HIGHWAY AND TRANSPORTATION OFFICIALS. In addition, that no
decision be rendered in favor of the variance application until such time as a
review of the analysis has occurred and the County Engineer has forwarded his
comments and recommendations to the Zoning Adjustor.
NOTICE: PENDING COMPLETION OF ALL CONDITIONS OF APPROVAL WHICH
NEED TO BE COMPLE 1 ED PRIOR TO PERMIT ISSUANCE, PERMITS MAY BE
RELEASED PRIOR TO THE LAPSE OF THE 1EN (10)-DAY APPEAL PERIOD.
HOWEVER, THE COUNTY HAS NO LIABILITY FOR EXPENSES AND
INCONVENIENCE INCURRED BY THE APPLICANT IF THE PROWL APPROVAL IS
OVERTURNED OR ALTERED UPON APPEAL.
DATED this Rath- day of October, 1993.
2
G. MOSHER, AICP
ing Adjustor
ounty, Washington
PILED:
1) Applicant (Certified/Return Receipt Mail)
2) Opponents of Record
3) Spokane Division of Engineering and Roads
4) Spokane County Health District
5) Spokane County Division of Utilities
6) Spokane County Department of Buildings
7) Planning Department File BP-121-93
8) Planning Department Cross-reference File and/or Electronic File
VE-S-93
CASE NO. VE-8-93 SPOKANE COUNTY ZONING ADJUSTOR PAGE 9
NOTE: ONLY THE APPLICANT OR AN OPPONENT OF RECORD MAY N1LE AN
APPEAL WITHIN 1 EN (10) CALENDAR DAYS OF THE ABOVE DA It OF SIGNING.
APPEAL MUST BE ACCOMPANIED BY A $200.00 FEE. APPEALS MAY BE FILED AT
THE SPOKANE COUNTY PLANNING DEPARTMENT, PUBLIC WORKS BUILDING,
1026 W. BROADWAY, SPOKANE, WA 99260 (Section 14.412.042 of the Zoning Code for
Spokane County).
VE-8-93