PLNZAD2021-01200 - 1043 E North BonnevillePLNZAD2021-01200 Page 1 of 3
December 17, 2021
ADMINISTRATIVE INTERPRETATION
DECISION AND FINDINGS
PLNZAD2021-01200
REQUEST:
This is a request from Michael Lawlor of Brach Design (the applicant), representing the property
owner, for an Administrative Interpretation regarding the definition of “Building Connection” for
a proposed accessory dwelling unit (ADU) at approximately 1043 East North Bonneville Drive.
The proposed ADU would be attached to the existing primary residence by a structural roof
between the two buildings. The area underneath the proposed roof connection would be open,
like a porch or a breezeway. There would be no interior circulation space between the two
structures.
Specifically, the applicant has asked for clarity regarding the definition of a “Building Connection”
(found in section 21A.62.040 of the Salt Lake City Zoning Ordinance) to know what would be
required to consider the two buildings as a single structure.
DECISION:
The Zoning Administrator finds that the two connected buildings are considered a single structure
because they are connected “in a substantial manner,” and the structural roof connection
between the two buildings covers at least 50% of the connecting façades’ widths. “Internal
pedestrian circulation” is not required in this case. The proposed project would still need to
conform with all applicable standards in the Salt Lake City Zoning Regulations.
FINDINGS:
The zoning regulations define a “Building Connection” as the following (see section 21A.62.040):
Two (2) or more buildings which are connected in a substantial manner or by common
interior space including internal pedestrian circulation. Where two (2) buildings are
attached in this manner, they shall be considered a single building and shall be subject
to all yard requirements of a single building. Determination of building connection shall
be through the site plan review process.
The applicant would like the proposed ADU and the existing primary residence to be considered
a single building, as described in the above definition. To be considered a single building, the two
structures must meet the qualifying statement in the definition’s first sentence. This statement
separates two distinct qualifiers by the word “or.” This means that two buildings are considered
to be one structure when they are connected:
• In a substantial manner; OR
• By common interior space including internal pedestrian circulation.
The applicant’s question essentially boils down to whether the phrase “including internal
pedestrian circulation” applies to only connections “by common interior space” or also to
buildings “connected in a substantial manner.” Because there is not a comma separating “by
common interior space” and “including internal pedestrian circulation,” they should be
considered together as a single phrase that does not refer to anything listed before the conjunction
“or.” Buildings connected “in a substantial manner” (like the proposed structural roof) do not
require internal pedestrian circulation to be considered a single structure.
As stated in the request, the proposed ADU would be connected by a roof with no internal
circulation. The two buildings could be considered connected if it is determined that they are
connected in a “substantial manner,” as required by the definition for “Building Connection.” The
zoning regulations do not define “Substantial,” but, as required by section 21A.62.010, the
Merriam-Webster Dictionary has the following relevant definitions:
PLNZAD2021-01200 Page 2 of 3
• Firmly constructed; sturdy
• Significantly great
• Being largely, but not wholly that which is specified
Based on the above definition, a connection substantial in manner must be a) firmly constructed,
b) significant, and c) largely (but not necessarily wholly) connected. In this case, the Zoning
Administrator has interpreted it to mean that a connecting roof must cover the width of at least
50% of each structure’s walls that are to be connected. In the applicant’s proposal below, the roof
connecting the two buildings covers more than half the width of each buildings’ façades. If the
proposed connection covered less than half of either wall, it would not meet the definition of
“Substantial” and would not be considered a “Building Connection.”
Another relevant definition to consider is “Accessory Building or Structure,” the zoning
regulation’s definition is below:
A subordinate building or structure, located on the same lot with the main building,
occupied by or devoted to an accessory use. When an accessory building or structure is
attached to the main building in a substantial manner, as by a wall or roof, such
accessory building shall be considered part of the main building.
Accessory buildings “attached to the main building in a substantial manner, as by wall or roof”
are considered part of the main building. Because a roof will connect the two structures “in a
substantial manner” (as discussed earlier in this section), the ADU and the primary residence
would also be considered a single structure by the definition of “Accessory Building or Structure.”
If you have any questions regarding this interpretation, contact Aaron Barlow at 801-535-6182 or
email at aaron.barlow@slcgov.com.
PLNZAD2021-01200 Page 3 of 3
APPEAL PROCESS:
An applicant or any other person or entity adversely affected by a decision administering or
interpreting this Title may appeal to the Appeals Hearing Officer. Notice of appeal shall be filed
within ten (10) days of the administrative decision. The appeal shall be filed with the Planning
Division and specify the decision appealed and why the appellant claims the decision to be in
error. Applications for appeals are located on the Planning Division website at
https://www.slc.gov/planning/applications/ along with information about the applicable fee.
Appeals may be filed in person or by mail at:
In-Person:
Salt Lake City Corp
Planning Counter
451 S State Street, Room 215
Salt Lake City, UT
US Mail:
Salt Lake City Corp
Planning Counter
PO Box 145471
Salt Lake City, UT 84114-5417
NOTICE:
Please be advised that a determination finding a particular use to be a permitted or conditional
use shall not authorize the establishment of such use nor the development, construction,
reconstruction, alteration, or moving of any building or structure. It shall merely authorize the
preparation, filing, and processing of applications for any approvals and permits that may be
required by the codes and ordinances of the City including, but not limited to, a zoning certificate,
a building permit, and a certificate of occupancy, subdivision approval, and a site plan approval.
Aaron Barlow, AICP
Principal Planner
cc: Nick Norris, Planning Director
Joel Paterson, Zoning Administrator
Casey Stewart, Development Review Supervisor
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