Spring Grove Project: Letter to Planning Director on Fire Access and Code Compliance

Subject: Spring Grove Project – Request for Clarification Regarding Fire Access, Hose Reach, Flag Lot, and Small-Lot Standards

Leza,

I am writing to request clarification regarding the City's processing and approval of the Spring Grove subdivision, particularly with respect to the City's application of several objective provisions of the Municipal Code and applicable fire-safety standards.

I previously raised these issues during the City's consideration of the project, including the attached comment regarding the project's flag-lot configuration. Given the City's subsequent approval of the project, I would appreciate clarification as to how the applicable standards were ultimately interpreted and applied.

1. Two-Fire-Access-Road Requirement

The approved Spring Grove project contains 41 residential units. The City's Municipal Code, including SHMC §15.36.100(D), establishes a requirement for two emergency access roads for residential developments exceeding 30 units.

Accordingly, I would like to understand:

Why was the two-fire-access-road requirement not applied to the Spring Grove project?
What provision of the Municipal Code permits a 41-unit residential development to be served by a single emergency access road?
Did the City determine that §15.36.100(D) did not apply to Spring Grove? If so, who made that determination, when was it made, and what was the specific code basis?
Was an exception, waiver, or alternative standard applied? If so, what provision authorizes it?
What was the Fire Department/Fire Marshal's determination regarding the applicability of the two-access-road requirement?

I am particularly interested in understanding how the City reconciled the project's 41-unit configuration with a code provision establishing a 30-unit threshold for requiring redundant emergency access.

2. 150-Foot Hose-Reach Requirement and the Effect of Hose Length on Firefighting Performance

There is a separate issue concerning the City's application of the 150-foot hose-reach requirement.

My understanding is that the City's review acknowledged that the project does not comply with the objective 150-foot hose-reach standard. During the City's consideration of the project, the Fire Chief explained that the Fire Department carries 200-foot hoses.

That response raises an important distinction. The question presented by the code is not simply whether the Fire Department possesses hoses that are physically longer than 150 feet. The applicable safety standard establishes an objective 150-foot measurement by which the adequacy of the firefighting equipment to perform its intended function — to deliver the required water flow and pressure necessary to suppress and/or extinguish an actual fire — is to be evaluated.

The distinction is important because hose length directly affects friction loss and available nozzle pressure. The technical information attached to this correspondence explains that friction loss increases with hose length. As an example, for a 1.75-inch hose flowing 150 GPM, the cited calculations show approximately 52 PSI of friction loss at 150 feet versus approximately 70 PSI at 200 feet — an additional 18 PSI loss resulting from the additional 50 feet of hose.

That additional pressure loss can affect nozzle performance, stream reach, and overall firefighting effectiveness. Plainly, and more importantly from an objective safety standpoint, a 200-foot hose is not necessarily equivalent in performance to a 150-foot hose. The additional length introduces additional friction loss and can reduce the pressure available at the nozzle unless compensating pump pressure is supplied. This appears to be precisely why objective hose-reach standards are established: to provide a consistent and measurable safety standard under actual firefighting conditions, rather than relying simply upon the physical reach of the longest hose wielded by the Fire Department.

Those standards also protect the firefighters who must deploy and operate the hose under emergency conditions, as well as the residents and property the Fire Department is responsible for protecting.

Accordingly, I would appreciate clarification on the following:

Did the City determine that the Spring Grove project complies with the 150-foot hose-reach requirement?
If so, how was that determination made?
If the project does not comply with the 150-foot requirement, what provision authorizes the City to approve the project notwithstanding that non-compliance?
Did the City formally grant an exception, modification, or alternative means of compliance? If so, under what specific code provision?
Where is that determination documented in the administrative record?
How does the City's reliance on the availability of 200-foot hoses reconcile with an objective standard that requires the determination to be made using a 150-foot hose-reach measurement?
Did the City perform any analysis of the additional friction loss and resulting effect on available nozzle pressure associated with using 200 feet of hose rather than the 150 feet specified by the applicable standard?
If such an analysis was performed, where is it contained in the administrative record?

Most importantly, I would appreciate the City's identification of the specific code authority that permits the objective 150-foot standard to be replaced or satisfied by the availability of 200-foot hoses.

3. Flag-Lot Determination and Access Limitation

The question of whether the Spring Grove subdivision constitutes a flag lot was expressly raised during the January 2025 Planning Commission proceedings. The Planning Commission Chair stated, "It's a flag lot... walks like a flag lot... talks like a flag lot," and the applicant acknowledged this characterization.

The City's flag-lot standards in SHMC §17.24.060 contain several provisions that appear directly relevant to the Spring Grove configuration, including:

§17.24.060(B)(1), establishing requirements for the narrow strip or panhandle portion connecting the lot to a public or private street;
§17.24.060(B)(2), which expressly states: "A panhandle may provide access to two lots."
§17.24.060(B)(3), which provides that the panhandle portion connecting the lot to a public or private street "shall be excluded when determining the compliance with minimum lot width and lot size standards."

Given these provisions, I would appreciate clarification on the following:

How did the City determine that the Spring Grove access configuration complies with SHMC §17.24.060(B)(2), which provides that "A panhandle may provide access to two lots"? Specifically:

How many of the 41 residential lots are accessed through the same panhandle/access strip?
Does the City interpret §17.24.060(B)(2) as permitting a single panhandle to provide access to more than two lots?
If so, what provision of the Municipal Code supports that interpretation?
If the City determined that §17.24.060(B)(2) does not apply to the Spring Grove configuration, what is the basis for that determination?
Was this issue specifically evaluated by Planning staff, the City Attorney, or the Fire Department?
Where is that analysis documented in the administrative record?

More simply, if §17.24.060(B)(2) establishes that a panhandle "may provide access to two lots," what is the City's code-based authority for an access configuration serving more than two residential lots?

There is also a separate issue concerning the formal classification of the property as a flag lot. The attached material reflects that the issue was expressly raised during the City's review, yet no formal flag-lot determination appears in the record.

If the City did make such a determination, please identify:

Who made the determination;
When it was made;
Where it is documented; and
What analysis was performed under §17.24.060, including the required exclusion of the panhandle when calculating minimum lot width and lot area.

If no formal determination was made, why was the project permitted to proceed to approval without resolving this threshold zoning classification issue?

4. Application of the Small-Lot Development Standards

I would also appreciate clarification regarding the City's application of the small-lot development standards to Spring Grove.

The project materials describe 41 individual townhouse lots, together with a common lot and a riparian lot, resulting in 43 created lots in total.

This raises an important question regarding both the City's characterization of the subdivision and the application of the development standards to the individual lots being created.

Did the City apply the HDR development standards to each of the newly created townhouse lots, and if so, how were the applicable setbacks and other dimensional requirements calculated for each lot?

In particular:

Which provision of the Municipal Code establishes the applicable small-lot standards for this project?
Which of the 41 townhouse lots were determined to qualify as "small lots"?
Were the required front, street-side, interior-side, and rear setbacks applied to each individual townhouse lot?
Were those setbacks measured from the boundaries of each individual created lot?
If the standards were not applied to each individual lot, what specific code provision permits them to be applied differently?
Where in the approved plans or staff report is this analysis documented?

The City's development standards appear to establish specific dimensional requirements for HDR development, including separate standards applicable to small-lot development. I would therefore appreciate identification of the specific code provisions, exceptions, adjustments, or other authority relied upon by the City in finding the project compliant.

5. The City's Overall Determination of Compliance

Finally, I would appreciate clarification as to how the City reconciled these various requirements in reaching its determination that the project complied with the Municipal Code.

In particular, I would like to understand how the City reconciled:

1. 41 residential units with the 30-unit threshold for requiring two emergency access roads;
2. The City's non-application of the 150-foot hose-reach requirement;
3. Reliance upon the availability of 200-foot hoses in place of the objective 150-foot measurement;
4. The apparent flag-lot configuration with the requirements of SHMC §17.24.060;
5. The provision stating that "A panhandle may provide access to two lots" with the project's access configuration;
6. The mandatory exclusion of the panhandle when calculating minimum lot width and lot area; and
7. The application of the HDR small-lot development standards, including required setbacks, to the 41 individual townhouse lots.

These are not questions about subjective design preferences or discretionary planning judgment. They concern the application of specific, objective provisions of the City's Municipal Code and fire-safety standards.

I am therefore requesting identification of the specific code provisions, determinations, findings, exceptions, and analyses upon which the City relied in concluding that the approved Spring Grove project complies with these standards.

Given that these issues were raised during the public review process, I would appreciate a response identifying where these determinations can be found in the administrative record. Happy to discuss. Call, text, or email with any questions.

Thank you,

Daniel Hale

Attachment: Flag Lot Determination and Required Code Application

The administrative record reflects that the issue of whether the Spring Grove subdivision constitutes a flag lot was explicitly raised before City staff, the City Attorney, contract planners, and the applicant during the January 2025 Planning Commission hearing.

At that hearing, Planning Commission Chair John Ponte stated "It's a flag lot...walks like a flag lot...talks like a flag lot," and the applicant, City Ventures, expressly acknowledged "...correct." These statements are not incidental — they establish that the issue was recognized by both decision makers and the applicant as a threshold classification question requiring formal determination.

That determination is legally consequential. Municipal Code §17.24.060 provides that, for flag lots, the "panhandle portion of the lot connecting with a public or private street... shall be excluded when determining compliance with minimum lot width and lot size standards." Accordingly, whether the project complies with dimensional standards cannot be evaluated unless and until the City first determines whether the parcel is a flag lot within the meaning of the code.

No such determination appears in the record.

Instead, at the February 10, 2026 City Council meeting, the Fire Department stated that the project "meets minimum lot width dimensional requirements." That conclusion is procedurally and substantively deficient for two independent reasons:

First, the Fire Department does not have the authority or expertise to interpret and apply zoning classifications under Title 17. The determination of whether a parcel constitutes a flag lot is a land use classification issue properly made by Planning staff, with legal interpretation as necessary from the City Attorney.

Second, and more fundamentally, the conclusion fails to apply the required analytical sequence. If the parcel is a flag lot, as acknowledged in the record, then §17.24.060 mandates exclusion of the access strip from any calculation of lot width and area. A conclusion of compliance that does not first perform this required classification and exclusion is unsupported and invalid.

This omission is not merely technical. The flag lot standard exists to address precisely the type of constrained, "bottleneck" configurations that can create safety risks for residents and emergency responders. This purpose aligns directly with the policy embodied in Municipal Fire Code §15.36.100(D), which requires redundant access for developments exceeding specified unit thresholds. Both provisions are grounded in the same public safety concern: avoiding single-access configurations that may impede adequate emergency response.

Here, the City was explicitly directed during the January 2025 Planning Commission proceedings to evaluate and resolve the flag lot issue. Staff indicated that this analysis would be undertaken. However, no formal determination or supporting analysis has been produced.

Absent an explicit finding on whether the parcel is a flag lot — and absent application of the mandatory exclusion required by §17.24.060 — any conclusion that the project complies with minimum lot width and lot size standards lacks a valid analytical and legal foundation.

For these reasons, the City must make a clear, supported determination regarding flag lot classification and demonstrate compliance with the code as written before any finding of consistency or determination of applicable codes can be sustained.