Showing posts with label point wells. Show all posts
Showing posts with label point wells. Show all posts

BSRE files appeal in Superior Court against Pt. Wells decision

Tuesday, November 6, 2018

Point Wells with a coal train in the foreground
Photo by Steven H. Robinson


BSRE, the developer whose application for a 3000+ unit development at Point Wells was recently denied by Snohomish County, has filed an appeal in King County Superior Court. The appeal alleges that the County misapplied the law, ignored evidence, and did not follow its own procedures when it denied the development application.

This is the third appeal of the original decision made by the County Hearing Examiner. BSRE first appealed for reconsideration by the Hearing Examiner, then to the County Council, and now to Superior Court.

Snohomish County identified 16 separate issues in finding the application in substantial conflict with the County code provisions and in each appeal BSRE has used the same arguments to try to refute all 16 issues.

Having failed to convince the Hearing Examiner and the County Council, it is unlikely (but still possible) that BSRE will be successful in court.

The tentative date for the hearing is April 1, 2019 in King County Superior Court before Judge Sue Parisien.

As with a Point Wells lawsuit in 2011, the appeal was filed in King County because Snohomish County is a party to the suit.

--Sno King Environmental Protection Coalition


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Snohomish council to affirm denial of BSRE application for Point Wells

Thursday, October 4, 2018

Point Wells
Photo by Steven H. Robinson
The Sno-King Environmental Protection Coalition, a volunteer group opposing the Point Wells development, has issued this statement after the Snohomish County Council's hearing of BSRE's appeal of the Hearing Examiner's denial of their project.

~~~~~~~

It's not quite over yet, but the long effort to block BSRE's attempt to build a small city at Point Wells took another positive step forward on Wednesday afternoon. After a few hours of public testimony and 15 minutes in executive session, Council members directed their staff to prepare a motion affirming the Hearing Examiner's decision denying BSRE's application.

The Council worked through a list of 16 issues under appeal and in a series of 4 - 0 votes requested each of the 16 issues be included in the motion to affirm the decision. The unanimous votes taken without discussion made it clear that the Council was not impressed by BSRE's arguments.

Council staff will create the final wording of the motion affirming the HE's decision. The motion is expected to come to a vote on Monday, October 8 at the regular Council meeting which starts at 10:30am.

RB and Woodway neighborhoods well represented

Local Point Wells expert Tom McCormick used his extensive knowledge of the issues to create 15 comment papers covering the most critical areas under appeal. Sno-King Coalition leaders Jerry Patterson and Tom Mailhot recruited a small army of RB and Woodway residents to travel to Everett to read the papers to the Council. In total there were 20 speakers against the appeal and only BSRE speaking in favor of the appeal.

A Snohomish County manager commented after the hearing that this was the most impressive public comment showing he had ever seen in his long career in government.

What's next?

While passage of the final motion seems all but assured, BSRE could still file an appeal in Superior Court. BSRE has only a few weeks to file the appeal so we will know soon if they decide to continue the appeal process.

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Snohomish County Council sets Oct 3 hearing date for Point Wells appeal

Wednesday, September 26, 2018

Point Wells today is an asphalt facility and oil-tank farm
Photo by Steven H. Robinson


The Snohomish County Council will hold a hearing on Wednesday, October 3, 2018 at 1:30pm in the Council Chambers on the 8th floor of the Robert J. Drewel Building, 3000 Rockefeller Ave. in Everett.

The Council will hear BSRE's appeal of the Hearing Examiner's re-affirmation of his denial of BSRE's development application for Point Wells. (See article BSRE appeals decision of Hearing Examiner)

BSRE will have 20 minutes to present their arguments, then the public will have three minutes each to make their comments.

If the Council upholds the Hearing Examiner's denial, the next level of appeal will be to Superior Court where only BSRE and the County can present arguments.

The Sno-King Environmental Coalition, a local group opposing the Point Wells development, plans to have residents there to offer comments, and point out the issues with the development.

They said, "We think it is important that our neighborhood be heard before the Council makes its decision. 
"We think the most likely outcome is that the Council will re-affirm the Hearing Examiner's decision, but that's not a guarantee."

Issues with the Point Wells development include height of the buildings, proximity to the high water mark, building in front of a landslide area, transportation and roads to and from the site. (See article Hearing Examiner rejects most of BSRE's motion to reconsider Point Wells project.)



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Sidewalk initiative, Point Wells update at September Richmond Beach Community Association meeting

Saturday, September 8, 2018

The finer points of two dramatic over-the-summer developments for Richmond Beach will be the topics at the September RBCA meeting.

A team from the City of Shoreline will explain what to expect now that 20th Avenue NW from Richmond Beach Road to the Saltwater Park has been put near the top of the priority list for sidewalk improvements.

In June, the City Council decided that, for all the scientific fairness applied to apportioning sidewalk repairs throughout the whole city, common sense told them that the heavily trammeled gateway to the city’s namesake attraction needed immediate attention.

Also in June, a judge in Snohomish County ruled that the developers of a proposed massive condominium complex at Point Wells were woefully deficient and egregiously tardy in their plans and permit applications, and the project was rejected.

In August, an appeal on several points of the judge’s ruling was largely rejected, but some question remains whether the developer, BSRE, can re-apply and under what rules. Local expert Tom McCormick will be on hand to explain and answer questions.

The meeting is open to all. It will be in the basement of the Richmond Beach Congregational Church, at the corner of Richmond Beach Road and 15th Avenue NW, at 7:30pm on Tuesday, September 11, 2018. Come a half hour early to mingle and enjoy refreshments.



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BSRE appeals decision of Hearing Examiner - Point Wells project still alive

Monday, August 27, 2018

Point Wells
Google Earth


This update is from the advocacy group Sno-King Environmental Protection Coalition, which opposes the proposed development at Point Wells


BSRE keeps it going - Files appeal with Snohomish County Council

As expected, BSRE hasn't taken "No" for the final answer. After having their development application denied by the Snohomish County Hearing Examiner (HE), then denied again when they asked the Hearing Examiner to reconsider the decision, BSRE has now taken the next step by filing an appeal with the County Council.

According to the Snohomish County Code, the appeal to the Council can only focus on issues already raised in the motion to reconsider the Hearing Examiner's decision. BSRE must argue that the HE came to a conclusion not supported by the record established in the hearing, made a mistake in applying the law, or that BSRE has new information which could not have been introduced at the hearing. The appeal will result in a public hearing where BSRE, the County, and the public will be able to make short presentations before the Council makes their decision. The date for the hearing has not yet been set.

What is "without prejudice"?

The Hearing Examiner had the choice of denying the application either "with prejudice" or "without prejudice". An application denied with prejudice is dead, and the developer must wait a year before submitting another similar application. A denial without prejudice allows the developer to submit a similar application without the one year wait period. The HE's ruling on reconsideration clarified that he denied BSRE's application without prejudice, giving BSRE a path to fix the issues found by the HE and quickly submit a new development plan.

One of the more interesting questions raised by BSRE is whether the HE's ruling that the application was denied without prejudice also grants BSRE the right to retain all their vested Urban Center development rights.

The HE seemed to rule against that right when he said the provision in the 2011 version of the County Code that preserved vesting was no longer in effect because it had been removed in a 2013 update to the Code. The County is almost certain to use this argument before the Council.

BSRE is arguing that they were vested to that provision of the 2011 code so it doesn't matter that it was later removed - their vesting preserves their right to use the 2011 version of the code.

This sounds like an issue that will eventually end up in court before we get a final decision.

Why do we care about "without prejudice"?

If BSRE wins this argument and is able to submit a new application using their vested development rights, then we will be right back where we were a year ago with a large development being proposed for a piece of land that does not have the access needed to support the number of vehicle trips the development will generate, and no process for the City of Shoreline to control what happens with the development.

If BSRE loses this argument, they can still submit a new application, but that application would have to follow the County's Urban Village development rules which give the City much more control over what can be developed.

It's much better for our neighborhood if the City has more control over the development since we have a much better chance of working cooperatively with our own City Council to come to good decisions than we do in talking to the Snohomish County Council.


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Hearing examiner rejects most of BSRE's Motion to Reconsider Point Wells project

Thursday, August 9, 2018

Point Wells 2018 holds oil storage tanks

The following is a report from the Sno-King Environmental Protection Coalition, an advocacy group opposed to the proposed BSRE development at Point Wells


The Snohomish County Hearing Examiner has issued a ruling on BSRE’s motion to reconsider his June 29, 2018 ruling that denied their application for a 3,000 unit development at Point Wells. The ruling on reconsideration was issued on August 3, 2018.

The ruling on reconsideration rejects most of BSRE’s objections and leaves the application dead pending any further appeals or other actions by BSRE.

Findings on Residential Setbacks

The Hearing Examiner originally ruled that SCC 30.34A.040(2)(a) limited the height of proposed buildings in the Upper Village area (the area east of the railroad tracks) because they were too close to neighboring residential zones in Woodway. BSRE argued that this section of the code only mentions specific Snohomish County residential zones, not the Woodway zones cited by the HE, so it can’t be used to limit building heights in that area of the property.

On reconsideration, the HE stated that the clear intent of the code was to limit the height of buildings near any residential zones no matter what jurisdiction controlled those zones. He found BSRE’s argument would lead to “absurd results that contradict the otherwise clear intent of the code”, and upheld his original ruling.

Findings on the Ordinary High Water Mark

The Hearing Examiner originally ruled that BSRE placed several of its proposed buildings within 150 feet of the Ordinary High Water Mark (OHWM) when no development is allowed in that buffer zone. BSRE argued that they found out about the need to identify the OHWM only recently when the County pointed out it was missing from their plans.

On reconsideration, the HE stated the code requirement to use the OHWM was unambiguous and has been in the code since 2007, that it was BSRE’s responsibility to understand the requirements for a design that meets County code, and upheld his original ruling.

Findings on the 90 Foot Height Limit and High Capacity Transit

The normal height limit for the development is 90 feet, but the developer is allowed to build up to 180 feet if the site is near a high capacity transit route or station and the developer can document that the additional height is necessary or desirable. While BSRE’s plans showed 21 buildings over the 90 foot limit, the Hearing Examiner originally ruled that BSRE had not submitted any documentation showing the extra height was either necessary or desirable. BSRE argued that since the County had not asked for such documentation, the HE could not base a ruling on it.

On reconsideration, the HE stated that it is the HE’s job to determine code compliance and the HE cannot just ignore non-compliance whether or not the County previously mentioned the issue to the developer. The application does not show the taller buildings are necessary or desirable, that is in conflict with County code, so the HE upheld his original ruling.

Findings on Landslide Hazard Area

Snohomish County Code section 30.62B.340 states that no buildings are allowed in a landslide hazard area unless it can be shown there is no alternate location for the buildings, and the developer can prove they will be able to complete geotechnical modifications that will make the buildings just as safe as if they were located outside the area. The Hearing Examiner originally ruled that BSRE had not fulfilled either of these conditions. BSRE argued that their project architect had since reviewed the site plan again and concluded that there was no other location for the buildings that was as good as the proposed location.

On reconsideration, the HE stated that it was too late for BSRE to submit more documentation because the application had expired on June 30, 2018, so the HE upheld his original ruling.

Findings on Request for Further Extension

The Hearing Examiner originally ruled that he would not grant BSRE any further extensions because BSRE has not been diligent over the last five years in resolving issues raised by the County. BSRE argued that they were led to believe that the County would grant them another extension, and that all the work they had accomplished in the last 3 months proved they would work diligently to complete the application if they were granted more time.

On reconsideration, the HE stated that he did not have authority to grant an extension unless he remanded the application back to the County for further processing. Since the HE denied application instead of remanding it, the HE could not grant an extension. The HE also stated that even if he had remanded the application, he would not have granted an extension because BSRE had not been diligent in trying to complete the application over the last five years. The HE upheld his original ruling.

What’s Next

The Hearing Examiner originally ruled that if BSRE did not like the ruling on the motion, they could appeal to Superior Court. BSRE cited sections of the County Code they claim allowed them to appeal to the County Council before going to court.

On reconsideration, the HE agreed with BSRE and changed the decision to indicate that the first level of appeal was the County Council, with a deadline of August 17, 2018 for filing an appeal. Any appeal to the Council must be limited to issues previously raised in the motion to reconsider.

At BSRE's prompting, the HE also clarified that his original ruling was to deny the application "without prejudice". Under the 2011 version of Snohomish County Code in effect when the application was submitted, denial without prejudice gave BSRE the right to reactivate the application while keeping the old vested development rules. The right to reactivate was removed in 2013 and we believe the HE indicated that BSRE must follow the current code in this area. We've asked the County to explain their position on this question but have not yet received an answer.

This is a critical question: if the County agrees with our position, then BSRE's only option if they want to proceed with development is to submit a new application using current development rules which give the City of Shoreline and the Town of Woodway much more control over the size of the development. We will let you know when we get that answer.


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BSRE appeals decision against them for Point Wells development

Sunday, July 29, 2018

Point Wells 2017
Photo by Steven H. Robinson


Sno-King Environmental Protection Coalition, the advocacy group opposing the Point Wells development, has released the following report and commentary:

Pt. Wells Developer Asks for Reconsideration

BSRE, the developer who had plans for a 3,000 unit development at Point Wells, has decided not to accept the recent decision by the Snohomish County Hearing Examiner to deny the application. The developer has filed a motion asking the Hearing Examiner (HE) to reconsider his decision, the first step in what may be further legal action to overturn the denial.

The motion lists what BSRE claims are multiple instances where the HE incorrectly interpreted the law or made findings not supported by the facts introduced in the public hearing. The motion also includes new evidence that BSRE claims the HE should consider because it was not available at the time of the public hearing in May, and includes changes to the application in response to issues identified in the hearing.

Findings on Residential Setbacks

The Hearing Examiner cited provision 30.34A.040(2)(a) of the County Code to rule that proposed buildings in the Upper Village area (the area east of the railroad tracks) must be severely limited in height because they were too close to neighboring residential zones in Woodway. BSRE argues that this section of the code only mentions specific Snohomish County residential zones, not the Woodway zones cited by the HE, so it can’t be used to limit building heights in that area of the property.

Findings on the Ordinary High Water Mark

The Hearing Examiner found that BSRE placed several of its proposed buildings within 150 feet of the Ordinary High Water Mark (OHWM) when no development is allowed in that buffer zone. The HE further found that BSRE was derelict in not identifying the OHWM earlier in the application process. BSRE argues that they found out about the need to identify the OHWM only recently and immediately moved to identify the mark and revise their plans. The motion includes revised plans that now identify the OHWM and remove all buildings in the 150 foot buffer area and claims that this late submission should be considered by the HE.

Unexplained is why the County had to point out the missing OHWM when BSRE at any time in the last seven years could have read the County Code provision that clearly states the OHWM must be used to establish the 150 foot buffer area.

Findings on the 90 Foot Height Limit and High Capacity Transit

The normal height limit for the development is 90 feet, but the developer is allowed to build up to 180 feet if the site is near a high capacity transit route or station. While the application claimed the site was near a high capacity transit route and included more than 20 buildings that were over the 90 foot limit, the Hearing Examiner ruled that BSRE had not done enough work with Sound Transit or Burlington Northern Railroad to ensure that any high capacity transit would actually serve the site, and thus all buildings must meet the 90 foot height limit.

BSRE argues that County Code section 30.34A.040(1) does not require actual service, just proximity, so the fact that the Sound Transit trains travel across the site is enough to qualify for the added height.

BSRE also argues that a mention of a possible Richmond Beach station in the appendix to a 2005 Sound Transit environmental statement and a single 2010 letter from Sound Transit shows that they have been diligent in pursuing a Sound Transit stop at Point Wells.

Unexplained is why, when Sound Transit has since proposed 2 additions to the system (ST2 and ST3) that take system planning beyond 2040, neither included any mention of a potential Richmond Beach station.

Finally, BSRE claims that they will establish a water taxi service between Point Wells and Edmonds to fulfill the need for high capacity transit. Unexplained is why BSRE has not provided any documentation showing they have contacted the Port of Edmonds to confirm the taxi would be allowed to dock.

Point Wells 2017
Photo by Steven H. Robinson


Findings on Landslide Hazard Area

Snohomish County Code section 30.62B.340 states that no buildings are allowed in a landslide hazard area unless it can be shown there is no alternate location for the buildings, and the developer can prove they will be able to complete geotechnical modifications that will make the buildings just as safe as if they were located outside the area. The Hearing Examiner ruled that BSRE had not fulfilled either of these conditions.

BSRE argues that their project architect reviewed the site plan again to confirm there is no other possible location for the Upper Village buildings. The architect concluded that there was no other location for the buildings that was as good as the proposed location. Unexplained is why saying that this is the best location proves there is no alternate (though possibly less desirable) location.

BSRE also includes a revised geotechnical report that purports to show the buildings will be just as safe as if they were placed outside the hazard zone, and claims this information could not have been provided to the HE during the May public hearing. Unexplained is why this information could be produced in the two weeks following the original ruling, but not in the seven years the application was in process prior to the hearing.

Findings on Request for Further Extension

The Hearing Examiner ruled that he would not grant BSRE any further extensions because BSRE has not been diligent over the last 8 years in resolving issues raised by the County. Denying any further extension allowed the application to expire on June 30, 2018. BSRE argues that they were led to believe that the County would grant them another extension, and that all the work they had accomplished in the last 3 months proved they would work diligently to complete the application if they were granted more time. Unexplained is why BSRE submitted very little work in the 5 years before January 2018 but was able to accomplish so much in the last 3 months leading up to the May hearing.

What’s Next

The Hearing Examiner must reply to the motion. His ruling could accept some or all of BSRE’s arguments and his ruling on the motion to reconsider could range from upholding the original denial to reversing his position and granting BSRE an extension.

The Hearing Examiner states that if BSRE does not like the ruling on the motion, they can appeal to Superior Court. BSRE cites sections of the County Code they claim allow them to appeal to the County Council before going to court. It’s unclear at this point who is right. Stay tuned.



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Evan Smith: Point Wells proposal denied because of inadequate second road, other deficiencies

Sunday, July 1, 2018

Richmond Beach Drive in Shoreline is the only road
in to Point Wells
Photo by Diane K. Hettrick
By Evan Smith

A Snohomish County hearing examiner has ruled against a developer's proposal to build a 3,100-unit condominium project on an industrial site at Point Wells because he found the developer's proposal for a second road to be inadequate.

He also found other inadequacies in the proposal for the development along Puget Sound in Woodway and unincorporated areas of Snohomish County near Woodway. It is currently used as a marine fuels depot and an asphalt plant.

Snohomish County Hearing Examiner Peter Camp denied the developer’s request for an extension of the expiration date of its urban center development applications and granted the county planners’ request to deny the developer’s application without an environmental impact statement because the application violates county code.

County planners had given the developers three deadline extensions over seven years before asking the examiner earlier this year to turn down the project.

Camp cited inadequacies in the developer’s proposal to build a second road into and out of the area.

A county planner said Friday that the developer's proposal for a road over a hill in Woodway didn't adequately address issues related to road construction down the muddy hillside.

The only current access to Point Wells is by a two-lane road that crosses the Snohomish - King county line from the Richmond Beach area of Shoreline, Richmond Beach Drive.

The principal planner for the project, Paul MacCready, also said that the inadequacy of the developer’s proposal for a second road was just one of several reasons why planners had recommended denial of the developer’s proposal.

MacCready cited these other reasons for denial:
  • Failure to address impacts on Woodway and Shoreline.
  • Failure to protect one of the buildings from possible mudslides from a nearby hillside.
  • A lack of plans to protect nearby wetlands.
  • A lack of access to transit.
  • A lack of adequate parking in the developer's plans.
  • Failure to show the correct number of condominium units.
  • Failure to address impacts on Woodway and Shoreline.
In another setback for developer BSRE Point Wells, the examiner denied an attempt to double allowable building heights to 180 feet. That affects almost half of the 46 proposed buildings, which exceed 90 feet.

The developer now can ask the hearing examiner to reconsider the ruling or appeal the ruling to the Snohomish County Superior Court.

Evan Smith can be reached at schsmith@frontier.com.



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Point Wells development application denied by Snohomish County Hearing Examiner

Friday, June 29, 2018

Point Wells
from Google Earth
The Snohomish County Hearing Examiner has denied BSRE Point Wells LLC's (BSRE) request for an extension of the expiration date of its urban center development applications.

The hearing examiner has also granted the Snohomish County Planning and Development Services Department's request to deny BSRE's applications without an environmental impact statement because the applications are in substantial conflict with the county code.

Full hearing examiner decision

The Sno-King Coalition reviews the possible next steps:

"BSRE can appeal the decision to the County Council and through the Courts, but they will have to prove that the Hearing Examiner made an error in reviewing the facts of the case; that will be a difficult standard to meet.

"BSRE could also submit a new application for a somewhat smaller Urban Village development, but that would require an agreement with both Shoreline and Woodway on how traffic and other impacts would be handled. That agreement would be required before the application could be submitted, which gives both Shoreline and Woodway more control over the size of the development."



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Update from Point Wells Hearing

Friday, June 15, 2018

Current view of Point Wells
Woodway is at the top of the hill
Photo by Steven H. Robinson

Report from the Sno-King Environmental Protection Coalition

Below is a summary of the public testimony portion of the open hearing on the Point Wells development application that came to an end on May 24, 2018 after 4 days of testimony from experts called by both BSRE and the County. To access key documents produced for the hearing, please go to the following link on the Sno-King Coalition web page.

What were the issues?

In a staff recommendation document dated April 17, 2018, the County identified 8 major areas where they claimed the application did not meet code requirements. Based on these conflicts and a June 30, 2018 application deadline, the County recommended denial of the application.

Since that date, BSRE has submitted numerous new plans and reports in an attempt to satisfy the County’s concerns. After a time-limited quick review of most of the new plans and reports, the County released a supplemental recommendation on May 9th that said the County was no longer contesting 3 of the original 8 areas, but that the 5 remaining areas were still in substantial conflict with the code and that the County was still recommending denial of the application.

The hearing was to determine whether the application should be denied, or sent back to the County for continued work on the Draft Environmental Impact Statement.

What happened at the hearing?

The hearing began on May 16th with opening statements by BSRE and the County followed by an opportunity for public comment. Tom McCormick, Susan Chang, Jerry Patterson, Tom Petersen, Denis Casper, and Tom Mailhot were among the neighborhood residents who made the trip up to Everett to comment. The City of Shoreline also sent a large contingent to comment (and encourage the denial of the application), including City Manager Debbie Tarry and City Attorney Margaret King. The City offered a powerful case for denial and reflected many of the positions taken by our community members.

Starting on May 21st the hearing moved to the expert testimony phase with the County’s experts explaining why the County believed the application was substantially in conflict with various portions of the County code, while BSRE’s experts argued that the application either already did or soon would comply with all County code provisions.

Each side specifically addressed each of the 5 remaining areas. We’ll go through the 5 areas and summarize each side’s main arguments.

1. Second Access Road

BSRE’s latest design for the second road shows the road exiting the east side of the Point Wells property and proceeding up the hillside to Woodway along a narrow easement owned by BSRE. The County’s supplemental recommendation letter said the latest design requires BSRE to purchase property along the route because the design is wider than the narrow easement and that the route requires grading on some of the neighboring parcels not owned by BSRE. BSRE has not submitted any documentation showing they have rights to purchase or grade any of the affected property; the County requires that documentation before they can consider the road to be feasible, and without a feasible second road the application is in substantial conflict with County code.

BSRE argued that the County’s demands for further documentation were overly broad since most of the road travelled over property located in Woodway, so Woodway, not the County, would be the permitting agency for the road.

2. Building height

The County found 2 issues with building heights in the proposed project. First the buildings in the Upper Village (the area east of the train tracks) must be limited in height because they are adjacent to areas that Woodway has zoned for single family residences, and second the project includes more than 20 buildings over 90 feet in height but the project lacks access to high capacity transit which is required to build higher than 90 feet.

BSRE argued that the Upper Village was at the bottom of a 220 foot bluff so the towers would not be visible to anyone. (Note: the bluff at that point is about 50 feet high before it flattens out and in fact the proposed second road runs over the upper portion of the “bluff”).

On the question of buildings over 90 feet in height, BSRE argued that the project plans include a train station and that they have a letter from Sound Transit saying that ST is willing to allow a commuter rail station at Point Wells if BSRE finances the station, and this commitment should be sufficient to meet the requirement of access to transit to allow buildings over 90 feet. (Note: BSRE would actually need permission from Burlington Northern (not Sound Transit to build and operate a station at Point Wells.

3. Parking

The County’s supplemental recommendation letter cited a parking shortage of 546 spaces as the substantial conflict in this area. In testimony at the hearing, it became clear the discrepancy was because BSRE had labeled the units as “Senior Housing” while what they really meant was “Retirement Housing”. The difference is that “Senior Housing requires a minimum of 1 parking stall per unit while “Retirement Housing” requires a minimum of .5 parking stalls per unit. The County agreed that if the units were regarded as “Retirement Housing” then the parking shortage no longer existed.

There was no discussion about whether building over 1,000 retirement units with only 500 parking spaces really made any sense or how that might impact our neighborhood when overflow parking occurs on our streets.

4. shoreline regulations

The County had several complaints about development along the shoreline:
  • BSRE’s plans show commercial use of the pier, but the pier is located in a Conservancy Environment which does not allow commercial uses.
  • The County believed the pedestrian promenade shown on the plan would also act as a flood control measure, which is not allowed without the approval of a code variance.
  • No development is allowed within 200 feet of the Ordinary High Water Mark, but some buildings in the plans are within this zone.
  • The County claimed the application did not sufficiently address Shoreline Master Plan Regulations, especially regarding the proposed reconstruction of the pier.

BSRE claimed that the colored illustrations used in the some of the presentations that show commercial uses on the pier should not be treated as actual plans to have commercial uses on the pier. BSRE also claimed that their recent submittals resolved all the other shoreline issues, and if they didn’t, BSRE was committed to providing any information that was determined to be missing.

5. Critical areas

BSRE’s design shows the lower portion of the second access road and most of the buildings in the Upper Village (the area east of the tracks) are located in a landslide hazard area. This is not allowed without the grant of a variance. BSRE submitted a variance three weeks before the hearing date, but the County’s experts testified that the variance application did not meet the requirements for granting a variance, specifically, that the variance application must show there is no other place on the property where the road or buildings could be located.

On further questioning, the County’s expert admitted a variance would probably be granted for the second access road since the route shown on the plan is probably the only realistic option, but he stated again that BSRE had not proven the buildings shown in the landslide hazard area could not be placed somewhere else on the property.

BSRE’s experts argued that they didn’t like any of the other plans they considered for placing the building in other areas of the property, so they had to go in the landslide area. (Note: their argument wasn’t that the buildings couldn’t be located elsewhere, just that BSRE preferred them to be in the landslide area.)

In expert testimony the County tried to establish that the material in the Habitat Management Plan concerning potential impacts to specific marine mammals was missing while BSRE replied by pointing to some sections containing general impacts to all marine mammals.

Summary

In summary, the County’s argument was that the application as it stands today is either incomplete, inconsistent, or just in conflict with County code provisions and it cannot be fixed by the June 30, 2018 deadline, so it should be denied; BSRE’s argument was that the application as it stands today is not perfect, but it is so much better than it was a year ago and if they are just given a little more time they promise to fix all the remaining problems at some future point.

The Hearing Examiner estimated it might take until mid to late June before his decision was ready.



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Point Wells update

Saturday, June 2, 2018

Drawing from BSRE Project Narrative 

By Tom McCormick

A seven-day hearing was held at Snohomish County from May 16-24.

The County asked the Hearing Examiner to deny BSRE’s application to develop Point Wells as an Urban Center. BSRE proposes to build over 3,000 residential units and 125,000 square feet of office and retail. Both the County and BSRE presented witness testimony, and introduced many exhibits available here.

Like a trial, witnesses were cross-examined by the opposite side. Friday (June 1) was the deadline for the County and BSRE and others to submit their Post-Hearing briefs and other materials to the Hearing Examiner.

The Hearing Examiner will consider whether to deny BSRE’s 7-year-old application because of alleged substantial conflicts with the County’s Code, and/or whether to grant BSRE extra time to fix the problems with its application (its application is due to expire on June 30).

The County alleges five areas of substantial conflict with County code: 
  1. conflict with the Code's 90-foot maximum building height (nearly half of the proposed buildings are taller than 90 feet); 
  2. conflict with an even lower height limit in the Code for five buildings near adjacent residential properties; 
  3. Code conflicts and compliance failures for the second access road including landslide hazard concerns; 
  4. Code conflicts and compliance failures regarding the shoreline master management program; and 
  5. Code conflicts and compliance failures regarding critical areas regulations including landslide and other geological hazards.

Perhaps the biggest single issue is whether the maximum building height is 90 feet or 180 feet. County Code says the maximum building height is 90 feet, but there’s an exception that allows a building height increase up to an additional 90 feet when the project is “located near a high capacity transit route or station.”

Project opponents discovered the "high capacity transit" phrase in 2015, and brought it to the County’s attention. The County promptly told BSRE what opponents were saying, but BSRE stood firm, not altering its original 2011 application in which nearly half of the buildings were taller than 90 feet. When BSRE submitted revised application materials in 2017 and in 2018, nearly half of buildings were still taller than 90 feet.

BSRE contends that it is allowed to build towers as tall as 180 feet because Point Wells is bifurcated by the Sound Transit commuter rail line; thus, it says, Point Wells is located "near a high capacity transit route or station," thereby satisfying the Code requirement for an additional 90 feet.

Opponents disagree. And so too does the County, the City of Shoreline and the Town of Woodway. The opposition argues that mere proximity to a rail line without a stop is meaningless — access is required where people can board the train. Opponents argue that BSRE fails to qualify for an additional 90 feet because there isn’t a station at Point Wells now, nor is one planned with any degree of certainty (requires Sound Transit and BNSF approvals, which might be impossible to get).

This is a critical issue for BSRE. Twenty-one of its proposed buildings are taller than 90 feet, some as tall as 180 feet. If the Hearing Examiner agrees that the height limit is 90 feet, he could deny BSRE’s application due to this single, substantial Code conflict. Alternatively, if the Hearing Examiner decides to give BSRE extra time to fix the problems with its application, he could, as a condition to granting the extra time, require BSRE to reduce the height of its buildings to 90 feet. If that happens, BSRE could lose up to 1,200 of its 3,000 planned residential units.

The Hearing Examiner is expected to issue his written decision by the end of June. Stay tuned.

If you want to read more about the 90-foot issue, three documents authored by opponents can be accessed at this link.

Here you can access the Post-Hearing filings by the County, BSRE, and the City of Shoreline. Their filings discuss the 90-foot issue, plus many other issues.



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Snohomish County Hearing Examiner posts exhibits for Point Wells hearing

Friday, May 11, 2018

Architect's drawing of proposed Point Wells development


The Snohomish County Hearing Examiner has posted all of the exhibits for the Point Wells hearing scheduled to begin May 16.

Point Wells Exhibits for Hearing Examiner

Snohomish County Hearing Examiner

May 17 and 18 are the dates for public comments on BSRE's application for the Urban Center development at Point Wells. The comment times are part of a public hearing that is the final step before the Hearing Examiner makes his ruling to either deny the application or allow continued work on the application and the draft environmental impact statement.

The hearing and public comments will take place at the Snohomish County campus in the Robert J. Drewel Building (Admin-East Bldg) in Room 2 on the 1st floor (Stillaguamish Room), located at 3000 Rockefeller Avenue in Everett.

  • BSRE will make its presentation on Wednesday, May 16th, from 2pm to 5pm. 
  • Snohomish County will present its recommendation to deny the application on Thursday, May 17th, from 9am to noon.

Public comment times:
  • Public comment periods start on Thursday, May 17th from 1:30pm and extend until at least 7pm. The County has committed to keeping the hearing open beyond 7pm to allow anyone arriving before 7pm to offer their comments.
  • The second comment period will start on Friday, May 18th at 9am. The County has not committed to a specific length of time for this period so it is advising the public to arrive at 9am if they want to be assured of an opportunity to speak.

Point Wells is a proposed development on a 61 acre point of land in Snohomish county which is at the base of a steep hillside in Woodway and accessed only by a narrow road in Shoreline. The development would feature over 3,000 residential units in buildings as tall as 180 feet, and more than 125,000 square feet of office, retail, and commercial space.




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Public comment on Point Wells scheduled for May 17 and 18

Saturday, May 5, 2018

Photo courtesy City of Shoreline
The advocacy group Save Richmond Beach has expanded into Snohomish county and become the 501(c)3 Sno-King Coalition group.

Tom Mailhot, of Save Richmond Beach, said "This group is a combination of leaders from both SRB and Richmond Beach Advocates (RBA). 
The old SRB and RBA groups will no longer be sending out newsletters; future newsletters will come from Sno-King Coalition."

The Sno-King Coalition has announced that the public hearing and chance for public comment on Point Wells is scheduled for May 17 and 18, 2018.

Per their newsletter:

"Snohomish County has announced May 17 and 18 as the dates for public comments on BSRE's application for the Urban Center development at Point Wells. The comment times are part of a public hearing that is the final step before the Hearing Examiner makes his ruling to either deny the application or allow continued work on the application and the draft environmental impact statement.

"The hearing and public comments will take place at the Snohomish County campus in the Robert J. Drewel Building (Admin-East Bldg) in Room 2 on the 1st floor (Stillaguamish Room), located at 3000 Rockefeller Avenue in Everett.

"The hearing will begin with BSRE making its presentation on Wednesday, May 16th, starting at 2pm and ending at 5pm. The County will present its recommendation to deny the application on Thursday, May 17th, starting at 9am and ending at noon.

"There will be two opportunities for you to offer your own comments on the project. The first public comment period will start on Thursday, May 17th at 1:30pm and extend until at least 7pm. The County has committed to keeping the hearing open beyond 7pm to allow anyone arriving before 7pm to offer their comments.

"The second comment period will start on Friday, May 18th at 9am. The County has not committed to a specific length of time for this period so it is advising the public to arrive at 9am if they want to be assured of an opportunity to speak."


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Snohomish County Planning dept recommends denial of permit for Point Wells development

Friday, April 20, 2018

2011 BSRE Urban Center concept


From Tom McCormick

Snohomish County’s Department of Planning and Development Services has sent its 93-page Staff Recommendation to the hearing examiner, recommending denial of BSRE’s applications to develop Point Wells as an urban center. Here is an excerpt from page 2 of the Staff Recommendation:

"Recommendation: Denial for the following reasons:
  • Failure to Document Feasibility and Code Compliance of Second Access Road;
  • Failure to Provide Acceptable Traffic Report and Assumptions, Resulting in Noncompliance with Concurrency Requirements and Failure to Mitigate Traffic Impacts;
  • Failure to Provide Appropriate Building Setbacks for Tall Buildings from Lower Density Zones and Failure to Document Evidence for Access to High Capacity Transit for Building Heights Over 90 Feet;
  • Failure to Satisfy Access to Public Transportation and Transit Compatibility;
  • Failure to Furnish Information on Contamination Necessary to Determine Approvability of Drainage Proposal and Compliance with Critical Areas Regulations;
  • Failure to Provide Adequate Parking;
  • Failure to Address Shoreline Management Regulations;
  • Failure to Comply with Code Provisions Regarding Critical Areas, Including Geologically Hazardous Areas, Wetlands and Fish and Wildlife Habitat Conservation Areas, and Critical Aquifer Recharge Areas.”
The 93-page Staff Recommendation can be accessed here.

According to the hearing examiner's scheduling order, the hearing is scheduled to begin May 16, and continue through May 31. Public comments can be made on May 17 (starting 1:30pm), and on May 18 (starting 9am). The hearing examiner’s scheduling order can be accessed here

4-21-2018 Corrected image caption

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Point Wells application likely to be denied - hear update at RBCA's Tuesday meeting

Wednesday, April 4, 2018

Richmond Beach Community Association's 
April Community Meeting
Topic: Point Wells
Tuesday, April 10, 7:00pm - meet and greet; 7:30pm - meeting
Richmond Beach Congregational Church, 1512 NW 195th Street, Shoreline

The April 10 public meeting of the Richmond Beach Community Association will be an update on the Point Wells development project. Snohomish County and the developer, BSRE, have been working on the development application for more than seven years, and the long application approval process looks like it is finally coming to a critical point in May.

In January, the county notified BSRE by letter that the county is likely to recommend the application be denied. We’ll review what has happened since that letter, the next steps we know about and tell you about upcoming opportunities for you to get involved again by sending the county your thoughts about the development.

While it will be welcome news for the neighborhood if the county does recommend the application be denied, it is almost certainly not the end of the story, so we’ll also take a look at what may follow over the next few years.

There’s been a lot going on since our last update, so don’t miss this chance to find out the latest.

The meeting is in the lower level of the Richmond Beach Congregational Church, at the corner of Richmond Beach Road and 15th Avenue NW. Doors open at 7:00 p.m. for refreshments and a meet and greet, with the program starting at 7:30pm.



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Point Wells Project heading for a showdown

Wednesday, January 31, 2018

Point Wells
Google Map
By Tom McCormick

Barring unforeseen circumstances, the fate of the Point Wells project will soon be determined by Snohomish County’s hearing examiner.

Seven years ago, BSRE submitted applications to Snohomish County to develop Point Wells as an Urban Center, proposing 3,081 residential units in buildings as tall as 180 feet, and more than 125,000 square feet of office, retail, and commercial space. The project would add thousands of average daily trips to City roads, causing significant traffic congestion.

Facing a June 30, 2018, application expiration date, BSRE recently asked Snohomish County's department of Planning and Development Services (PDS) for more time. On January 24, PDS said no, telling BSRE that the project's application expiration date remains June 30.

Parts of BSRE's submitted application materials fail to comply with the County's Development Code, according to a 389-page Review Completion Letter that PDS sent BSRE last year (October 6, 2017). Because of the compliance failures, it seems that PDS is in the process of invoking a rarely used option — County Code 30.61.220 (Denial without EIS) — to send the Point Wells project to the County’s hearing examiner with a recommendation to deny the project without the preparation of an Environmental Impact Statement (EIS). As stated in a January 19 letter from PDS to BSRE’s attorney:

"Since BSRE submitted its application materials seven years ago, PDS has worked cooperatively and in good faith with BSRE in the application submittal and review process, and will continue to do so. However, BSRE has failed to address multiple County Code compliance issues with its application materials despite PDS repeatedly identifying Code compliance concerns and requesting BSRE submit materials resolving these issues. BSRE has allowed years to pass without addressing Code compliance issues with its application, which is well documented in PDS’s Review Completion Letters dated April 12, 2013, and October 6, 2017. PDS has repeatedly and consistently communicated in writing to BSRE regarding the upcoming application expiration deadline and potential outcomes if BSRE did not provide adequate application submittals to address Code compliance issues and the information needed to continue environmental review."

A hearing date has not been announced yet, but it seems likely that it would be in May, giving the hearing examiner time to issue a written decision before the June 30 application expiration date. (It is possible that BSRE could go to court to challenge PDS’s January 24 refusal to extend the project's June 30 application expiration date. If that happens, the hearing could be postponed until BSRE's challenge is resolved.)

While we wait for a hearing date to be announced, three other things are in progress.

First, to comply with County Code, PDS needs to present the project to the County’s volunteer Design Review Board in a public proceeding. Expect the Design Review Board meeting to be in March or April, a month or two before the project goes to the hearing examiner. The Design Review Board is an advisory body to PDS and applicants applying for approval of an Urban Center development. Duties include: reviewing proposed site plans and project design features to ensure fair and consistent application of the County Code’s design standards; providing written recommendations to PDS and the applicant on potential modifications regarding the project, such as scale, density, design, building mass and proposed uses of the project; and synthesizing community input on design concerns. The Design Review Board proceeding will be an awkward hoop to jump through, considering that PDS will apparently be recommending denial of the project.

Second, PDS is preparing its staff report to the hearing examiner, and compiling the many exhibits that will accompany it. As discussed above, PDS will apparently be recommending denial of the project without the preparation of an Environmental Impact Statement because parts of BSRE's application materials allegedly fail to comply with the County’s Development Code. Expect PDS to deliver its staff report to the hearing examiner at least a few weeks before the hearing begins — far enough in advance of the hearing so that the hearing examiner has adequate time to read and digest everything.

Third, BSRE and its consultants are presumably working on revisions to BSRE's application materials. BSRE told PDS that by April 30 it would submit supplemental application materials responsive to the County’s October 6, 2017, lengthy Review Completion Letter. It seems likely that at about the same time that BSRE sends its supplemental application materials to PDS, PDS will be sending its staff report to the hearing examiner. As PDS told BSRE in its January 19 letter: "While [the supplemental application] materials ... may not be included in the PDS recommendation [to the hearing examiner] due to the timing of BSRE’s proposed resubmittal, it does not preclude BSRE from submitting application materials that may be considered by the hearing examiner in making a determination whether the applications satisfy the County Code requirements to a degree necessary to continue environmental review.”

If a hearing takes place in May as expected, and the hearing examiner agrees with some or all of PDS’s expected recommendation to deny approval of the project on account of alleged failures to comply with the County’s Development Code, then the hearing examiner could deny the project outright (BSRE could appeal the denial). Alternatively, the hearing examiner could deny the project on a tentative basis, giving BSRE one more chance to revise its application materials to bring them into compliance with County Code. The hearing examiner would probably set a deadline, and if BSRE doesn’t meet it, or if BSRE’s revisions are insufficient to comply with County Code, then the hearing examiner could deny the project outright (BSRE could appeal the denial).

If the hearing examiner determines that BSRE’s revised application materials sufficiently correct all deficiencies and comply with County Code, then the hearing examiner could direct PDS to resume its review and processing of BSRE’s applications, and direct that preparation of a draft EIS for the project be resumed.

What might BSRE do if the hearing examiner denies BSRE's applications to develop Point Wells as an Urban Center, and the denial is upheld on appeal? Stay tuned for a future article addressing this question.


Tom McCormick is working with of a coalition of Shoreline residents and organizations opposing the proposed Point Wells development.



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CORRECTION: Richmond Beach Road and Richmond Beach Drive

Tuesday, October 24, 2017

CORRECTION: On the op-ed published yesterday, (Op-Ed: Where do City Council candidates stand on Point Wells?) editorial staff added a photo of Richmond Beach Drive with a photo caption that actually referred to Richmond Beach Road.

The caption (now corrected) incorrectly stated that Richmond Beach Drive would have 22,000 daily trips. The caption should have said that Richmond Beach Drive would have 11,500 trips.

Richmond Beach Road will have 22,000 daily trips.

Here is the corrected article.



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Op-Ed: Where do City Council candidates stand on Point Wells?

Sunday, October 22, 2017

Richmond Beach Drive would have 11,500 daily trips
Photo by Diane Hettrick
Tom McCormick is working with of a coalition of Shoreline residents and organizations opposing the proposed Point Wells development

By Tom McCormick

The Point Wells project in Snohomish County is expected to generate 11,000 or more average daily trips traveling on City of Shoreline roads.

(The City’s 2013 agreement with the developer (BSRE) assumes for study purposes that the Point Wells project will generate up to 11,587 average daily trips.)

The only road to Point Wells is Richmond Beach Drive, a two-lane road with just 500 average daily trips today. Richmond Beach Road would be used too; its current traffic volume would double to nearly 22,000 average daily trips.

The City and BSRE are on a collision course. Projected Point Wells traffic will exceed three City-adopted limits and contribute to traffic congestion throughout Shoreline:

  • City Limit 1: Traffic on Richmond Beach Drive is not to exceed 4,000 average daily trips (see the Point Wells Subarea Plan). NOTE: In 2011, BSRE filed a petition with the Growth Management Hearings Board challenging the City’s 4,000 average daily trip limit. The City and BSRE have mutually agreed on 27 separate occasions to extend (delay) the proceedings, apparently hoping that they can reach a settlement — BSRE would probably want a trip limit near 11,000 average daily trips.
  • City Limit 2: Traffic volume on arterials like Richmond Beach Road is not to exceed 90% of the road’s maximum capacity (this 0.90 V/C standard is in the City’s development code). NOTE: After Richmond Beach Road becomes three lanes next year, it will have a spare capacity at the top of the hill (west of 8th Ave NW) of about 4,000 - 5,500 average daily trips. More traffic than this would exceed the City’s 0.90 V/C standard. The spare capacity east of 8th Ave NW will be even less — perhaps 1,000 or so average daily trips. In contrast, the Point Wells project is expected to generate 11,000 or more average daily trips.
  • City Limit 3: Wait times at intersections with stoplights are not to exceed 55 seconds under the level of service “D” standard in the City’s development code. NOTE: After Richmond Beach Road becomes three lanes, one’s average wait time for eastbound morning traffic at the stoplight at the top of the hill (8th Ave NW) would jump to 187 seconds with Point Wells — a delay of more than three minutes! (Source: August 2016 Traffic Analysis done for BSRE, page 35)

How does BSRE propose that things be fixed (mitigated) so that it can shoehorn 11,000 or more average daily trips onto City roads without violating the City’s traffic limits? On page 88 of the Traffic Analysis, under the heading, ”Richmond Beach Road Rechannelization Impacts and Mitigation”, it proposes fixing some intersections, and getting the City to do the following three things (the Traffic Analysis does not address Richmond Beach Drive’s 4,000 average daily trip limit):

  • BSRE Mitigation 1: Allow traffic volumes to exceed 90% of maximum capacity. COMMENT: Mitigation typically involves improving one’s roads to increase capacity or, for example, downsizing a proposed development to decrease the amount of traffic that is generated. In contrast, BSRE’s idea is to convince the City Council to revise its rules to let traffic volumes exceed 90% of maximum capacity — that’s not mitigation, that’s congestion.
  • BSRE Mitigation 2: Undo the rechannelization of the segment of Richmond Beach Road west of 8th Ave NW, reverting back to four lanes. COMMENT: If, with current traffic volumes, the City Council deemed it wise to convert Richmond Beach Road from four lanes to three lanes for safety reasons, then one would expect that it would refuse to go back to four lanes when traffic doubles due to Point Wells. Reverting to four lanes would make Richmond Beach Road far more accident prone and less safe than before.
  • BSRE Mitigation 3: Widen to five lanes the segment of Richmond Beach Road between 3rd Ave NW and 8th Ave NW. COMMENT: It is not possible to build five lanes within the City’s 60-foot right-of-way, with sidewalks, bike lanes, and amenity zones. If the City keeps its promise not to condemn private property to widen Richmond Beach Road, then a five-lane road is not viable unless BSRE could acquire sufficient property or easements all along Richmond Beach Road to widen it.

What will the City Council do when pressed by BSRE? Will the City Council stand firmly behind its three traffic limits, reject BSRE’s three mitigation ideas as being contrary to City limits and policy, and fight in court if necessary?

Snohomish County, the permitting agency, has said informally that they intend to honor the City’s level of service “D” standard and perhaps the City’s 0.90 V/C standard, but will they?

Will the City Council fight any efforts by Snohomish County to let BSRE build a project that generates far more traffic than our roads can handle as determined by the City’s three traffic limits? It is well known that the City wants to annex Point Wells thereby deriving a new source of revenue (see the Point Wells Subarea Plan).

Will the City Council let our roads be congested in exchange for BSRE’s promise to let the City annex Point Wells?

Who we vote for in this year’s City Council election may affect what happens with Point Wells. 

To the candidates: Do you pledge to stand firmly behind the City’s three traffic limits, reject BSRE’s three mitigation ideas, and fight to ensure that Point Wells does not generate more traffic than our roads can comfortably handle?



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HeraldNet: Plan for 3,080 waterfront condos still lacking, county says

Tuesday, October 10, 2017

2012 architect rendition of Point Wells


According to an article in the HeraldNet, BSRE's plans for the Point Wells development has not addressed Snohomish county's concerns about the site.

A developer needs to address lingering questions about plans to build 3,080 waterfront condos at Point Wells, including parking, landslide hazards and cleaning up industrial contamination, Snohomish County staff said Friday.
Blue Square Real Estate has until Jan. 8 to supply missing information, according to a letter from county planners. The deadline is intended to give county staff time to review the information before BSRE’s permit applications are set to expire in mid-2018

Read the article here.


BSRE is proposing to build clusters of mid-rise buildings on a beach in unincorporated Snohomish county on the border of Shoreline and Woodway. Currently the only road into the site is two lane Richmond Beach Drive in Shoreline.



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Point Wells, LLC development in Woodway: Woodway Pointe

Monday, October 2, 2017

The property is directly above the big Point Wells project.
A secondary road exits east at the end of the development.
A potential emergency access snakes down the hill.
Point Wells, LLC has submitted a proposal to the Town of Woodway to develop Woodway Pointe, a 36 lot subdivision plat located on the property identified in the town’s Comprehensive Plan as the Upper Bluff. The subdivision would be accessed from 238th St. SW. 

The property was recently annexed into the Town of Woodway. The Notice of Application submitted in July includes the proposal and required environmental documents. Based on the information provided in the SEPA Checklist, the town determined that potential environmental impacts warrant preparation of a complete Environmental Impact Statement (EIS). Among the environmental concerns identified requiring further study are earth/geologic, wetlands/streams, and aesthetic/views.

In early September the town issued a Determination of Significance and Request for Comments on the Scope of an Environmental Impact Statement in September. The 21-day comment period concludes on October 9th. The date and time of the Scoping meeting is yet to be determined.

All documents associated with the annexation and development proposal are available for review at the Woodway Town Hall. Comments may be submitted to the Town Clerk, Heidi Napolino as such: Heidi@townofwoodway.com or Heidi Napolino, Town Clerk, 23920 113th Place W, Woodway, WA

--Robin McClelland



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