Editor:

The following letter was sent to Mayor Dave Earling & City Council Members Johnson, Nelson, Fraley-Monillas, Buckshnis, Teitzel, Mesaros and Tibbott

Subject: Properties Located within the Coastal High Hazard Areas and Coastal A Flood Zones

Proposed Amendments to:

19.00.025 International Building Code 1612.4.1 Lowest Flood Elevation

21.40.030 Height, Section D. Height Exceptions 1.

The Alliance of Citizens for Edmonds (ACE) discussed these two proposed changes, one of which, 21.40.030, was deleted by Council at its December 15, 2015, meeting, at our last regular meeting, and continued our discussions at a special meeting this week. In your upcoming reconsideration process, we ask that you consider the following suggested revisions and concerns:

1. We believe the height limit on properties located within the Coastal High Hazard Areas and Coastal A Flood Zones should continue to be bound by the existing height limits, which we understand are either thirty feet or thirty-five feet (Harbor Square), as measured using the existing four corners measured from ground level at the footprint of the building.

2. Whatever footage is established for the ground floor distance above the base flood elevation as identified from the applicable FEMA flood hazard map, currently stated to be two feet in the proposed amendments above, should be included in (i.e. not in addition to) the total building height controlled by the existing methodology.

3. We are concerned that the two feet included in the above amendment may not be adequate. This is based on observing the combined effects of high tide and wind seen during King Tides which approach the intermediate two foot rise anticipated in the next 100 years. This concern is apparently shared by the Senior Center planners, who we understand are planning to allow three feet to the first floor (i.e. a total of 15 feet) and are also voluntarily forfeiting one foot of building height. We also are aware that the Corps of Engineers provided guidance in 2015 to the City of Seattle that in 2090, at the end of the Senior Center Design life, the low, intermediate and high sea level rise may be 0.5 feet, 1.6 feet and 3.9 feet respectively. [1]

4. The City should evaluate how using the estimate of two feet in the amendments in light of the Corps of Engineer guidance above might affect the level of liability it could be exposed to if sea level rise exceeds two feet and should significant property damage / loss of life occur as a result.

We believe that the changes and concerns above, and the associated potential risks and liabilities, should be carefully and completely considered before finalizing the International Building Code and Height Exception amendments.  Existing building heights and view protection, which have been enacted with much thought and comment for the benefit of the entire community, should not be changed especially in so sensitive an area as the waterfront, simply in order to accommodate the potential hazards to the ground floor of the area in which the buildings are located.

Thank you for your consideration of our recommendations.

Respectfully,

The Alliance of Citizens for Edmonds (ACE)

[1] Letter from Jeff Parsons, Ph.D., P.E. of Herrera Environmental Consultants to Farrell Fleming, Executive Director of the Edmonds Senior Center dated November 25, 2015.