HomeMy WebLinkAboutCJulien_CPA#23-M-01 be withdrawn (please forward to the Renton Planning Commissioners)_20230605CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless you know the content is safe.
From:Clint JulienTo:Margarette Bravo; Paul Hintz; Chip VincentSubject:CPA#23-M-01 be withdrawn (please forward to the Renton Planning Commissioners)Date:Monday, June 5, 2023 1:24:09 PM
(please forward to the Renton Planning Commissioners) I am Clint Julien, I live in Kennydale, at 1427 N 32nd St. I ask Amendment CPA#23-M-01 be withdrawn. Or, not approved and corrected for it's errors, with more communityinvolvement. This Amendment benefits the parcel owners to the tune of millions of dollars, while Kennydale residents haveobjected to having no traffic study presented and to having residential property rezoned to commercial. These issueswere taken up in 2017 in CPA#16-0809, and again in 2020 in CPA#19-M-04, both times rejected by the community.At this May's Kennydale Assoc. meeting for CPA #23-M-01, again concerns were voiced concerning communityinvolvement, traffic, school and Fire Station proximity, and losing residential property. At the end of CPA#19-M-04 Renton said they need to: engage in community meetings and public outreach to creategreater opportunity for public knowledge and understanding and prepare a transportation analysis. In May CPA#23-M-01 was presented to Kennydale residents, at the meeting it was noted the residents were not engaged in theprocess, only allowed to comment afterward. Also, no transportation analysis is or was done. Studies and Reports show the S curves and Kennydale Hill has the worst traffic in WA. In 2017 an Amendmentrezoning the Kennydale Apartments had to be withdrawn when a Traffic Study turned out bad. That Study has beendiscarded and previous outrage not remembered.
An example of what Renton is asking for is the property at 2900, it is a rental house with the driveway on Park, not
30th. CPA-#23-M-01 proposes to change this residential property to High Density and rezone it to CommercialNeighborhood.
The Amendment rezones this lot to CN and that does not meet the requirements of the Renton Comprehensive Plan,Policy L-16. The Planning Dept. downplay the effect of this Amendment as having little effect on Renton. It may have little effecton Renton but it will have a huge effect in Kennydale. It flies in the face of Renton City Council Resolution 2708, concerning Preservation Of Kennydale Neighborhoods FromDeterioration Due To Traffic.
Seattle Bread of Life Christian Church, located at the northwest corner of the N 30th St/Park Ave N intersection,
currently fills the park and ride parking lot every Sunday. I believe the owners lease to them and to the city? This
Church will lose it's parking and have to bus from Kennydale Elementary school if CPA #23-M-01 is passed. Has
Renton reached out to this large congregation for their input? Why instead of rezoning doesn't the owner sell the lot
to the new Church? When the owners had their Church in Kennydale would they have liked to have been in the new
Church's position?, over what amounts to greed.
Kennydale is depending on the City to do due diligence. Please do not rubber stamp this Amendment. Please shine alight on this Amendment and expose the fallacies. As Jesus did, on the cross, I trust in God, Thank you. -Clint Julien _______________________________________________________________________________HISTORYOctober 2, 2020 Charles Seil Renton Planning Commission Chair 1055 S Grady Way Renton, WA 98057 Subject: CPA #19-M-04: N 30th St Comprehensive Plan Amendment (CPA) and Rezone
Dear Chair Seil: The Community and Economic Development (CED) Department has determined that the subject 2020 Comprehensive Plan Amendment shouldbe extended into 2021 in order to more fully address community concerns. The Department believes there is still value and merit in advancingthe N 30th St CPA and Rezone; however, issues and concerns raised in the September 16, 2020 public hearing before the Planning Commissionshould be afforded additional time necessary to better inform the public and advance the proposal. Three (3) common items or concerns are as follows: How density range is calculated and how it pertains to potential growth. Why the CPAand rezone is proceeding in the context of the current pandemic. What are the transportation impacts. CED proposes the following actions be taken in the remainder of this year and 2021: engage in community meetings and public outreach tocreate greater opportunity for public knowledge and understanding, prepare a transportation analysis, separate the proposed CommercialNeighborhood (CN) code changes from the Comprehensive Plan Amendment map amendment and rezone request, and prepare graphics andmaterials to better inform the public regarding the scale, bulk and density of the proposal. Thank you for your consideration. Sincerely, Clark H. Close Interim Current Planning Manager ______________________________________________________________HistoryPlease withdraw Amendment CPA-M-04. Amendment CPA-M-04 violates the Comprehensive Plan Policy L-16, and has been presented, out of compliance with Chapter 365-196WAC, GROWTHMANAGEMENT ACT, PROCEDURAL CRITERIA FOR ADOPTING COMPREHENSIVE PLANS AND DEVELOPMENT REGULATIONS, and out of compliance withWAC 365-196-600, PUBLIC PARTICIPATION. This while the world is in a health Pandemic. The Renton Planning Staff made unsubstantiated claims in their Briefing. They did not show to Renton, the Planning Commission, or the community ofKennydale, worst case analysis. They did not provide what should be expected, Studies to substantiate their claims. To approve Amendment CPA-M-04 isbuying a pig in a poke, yet the Renton Planning Staff recommends approval. Policy L-16 ArgumentThe Renton Municipal Code implements the City’s policies adopted in the City’s Comprehensive Plan. The City's Comprehensive Plan clearly states in PolicyL-16, that Commercial Neighborhood Zone CN is required to front on a Minor arterial. To my knowledge, there are no exceptions to this for all existing CNzoned property in Renton. Despite this Policy, Amendment CPA-M-04 proposes to rezone, not one but three parcels that have no front on the Minorarterial of 30th St., to zone CN. The Staff's response to not fronting on 30th was, The two (2) parcels within the N 30th St Study Area that don’t immediately front a street classified as aPrincipal arterial, Minor arterial, or Collector are 1416 N 30th St (APN 3342103240) and 2900 Park Ave N (APN 3342103255). The purpose of includingthese parcels in the rezone was due to similar ownership purposes. In the case of 1416 N 30th St, the parcel is landlocked and access is from N 30th Stvia 1410 N 30th St (same owner). Concerning 2900 Park Ave N, the parcel is owned by the Kennydale United Methodist Church who also owns theabutting parcel on N 30th St (APN 3342103256). Abutting lots under common ownership with the same zoning allows for lot line adjustments, lotcombinations, or a more cohesive redevelopment project. I first contend "Similar ownership purposes", it is not in the Comprehensive Plan, or in the Renton Municipal Code. In RMC 4-2-050A. 'Permitted Land Uses Established', the CPA-M-04 purposed Land Use is P6, P for PERMITTED USES: Land uses allowed outright withina zone and 6 for Unclassified Uses, defined as follows:
6. Unclassified Uses: Upon inquiry by an applicant, an administrative interpretation shall be made by the Development Services Division Director to
determine if a proposed use not specifically listed is allowed utilizing the criteria in subsection C6a of this Section. Should interpretation be made that a
proposed, unlisted use not be allowed in a specific zoning district, the Director shall indicate which zones, if any, do permit the use. If the Development
Services Division Director’s interpretation indicates that an unlisted use is not consistent with the permitted, conditional or accessory uses in any district, or
if a party does not concur with the permit type applied to a use, appeal may be made pursuant to RMC 4-8-110. Interpretations made by the Development
Services Division Director shall be documented, and updates to Title 4, when consistent with the title format and level of detail, shall incorporate
“unclassified use” interpretations upon approval by the legislative authority.
a. Criteria for Unclassified Uses: In order to make a determination that an unclassified use is permitted, conditionally permitted or accessory, the
Development Services Division Director must find that the use is:
i. In keeping with the purpose and intent of the zone, and consistent with the Renton Comprehensive Plan policies; and
ii. Similar in nature to, and no more intense than, a specifically listed permitted, conditional or accessory use; and
iii. Consistent with subsection C4 of this Section, if determined to be permissible as an accessory use.
As far as "Similar ownership purposes", the Criteria for Unclassified Uses again stated, to be consistent with the Renton Comprehensive Plan, which CPA-M-04 does not do. So where did The Staff get "Similar ownership purposes"? Not relevant to P6 purposed in CPA-M-04, is use AC or Accessory Uses. It doesn't apply toCPA-M-04 but may be where Staff came up with "Similar ownership purposes". ACCESSORY USES states as follows: ACCESSORY USES: Uses customarily incidental and subordinate to the principal use and located upon the same lot occupied by the principal use or onan abutting/adjacent lot that is under the same ownership as the principal lot. Some accessory uses are specifically listed, particularly where a use is onlyallowed in an accessory form, whereas other accessory uses are determined by the Development Services Division on a case-by-case basis per RMC 4-2-050 C4 and C6, Accessory Use Interpretations and Unclassified Uses
In my argument above I showed 6 or (C6), the following is C4:
4. Accessory Use Interpretations: The Development Services Division Director may determine if an unclassified use or a classified use, even if not
specifically listed as accessory (AC), is permitted as an accessory use in a zone. Upon inquiry by an applicant, an administrative interpretation shall be
made by the Development Services Division Director to determine if a proposed use is allowed as an accessory use utilizing the rules of interpretation in
subsection C4a of this Section. If the applicant does not concur with the interpretation of whether a use is accessory or with the permit type applied to a
use, appeal may be made pursuant to RMC 4-8-110. Interpretations made by the Development Services Division Director shall be documented, and
updates to Title 4, when consistent with the title format and level of detail, shall incorporate “accessory use” interpretations upon approval by the
legislative authority.
a. Rules of Interpretation for Accessory Uses: To determine whether a use is permitted as accessory, the Development Services Division
Director shall utilize the following rules of interpretation:
i. If a use is allowed or conditionally allowed in a zone as a “permitted” use, accessory uses associated with the primary use that are determined
to be incidental, necessary and commonly found with the permitted use may be allowed with the same permit type as the primary use, unless
specifically stated otherwise.
ii. If a use is permitted or conditionally permitted as a primary use, subject to location restrictions, the listed use, even as an accessory use, is
also subject to the same location restrictions as the primary use, unless specifically stated otherwise. For example, if a use is restricted to a
location within the Employment Area (EA) land use designation, then the accessory form of the use is only permitted in the EA, unless
specifically stated otherwise.
iii. Required parking, required site utilities/facilities, and other development standards required in order to establish or operate a use on a site
according to the RMC are considered accessory.
To sum up Policy L-16, the Accessory Use sections of the Municipal Code are intended for an applicant, and subject to an Appeal. Accessory Use is notintended for Staff to get around the Comprehensive Plan Policies. Interpretations made by the Development Services Division Director shall bedocumented. Abutting/adjacent lots and same ownership does come up under Accessory Uses but it describes incidental and subordinate use. Nowhere is"Similar ownership" described. Rezoning should not make parcels 'non-compliance'. In the case of CPA-M-04, building commercial or Townhouses is notincidental. Same ownership of two parcels isn't consistent with Townhouses being bought and sold. Why rezone a water tower who's parcel does not fronton the Minor Arterial to CN in violation of the Comprehensive Plan. Why rezone a residential rental parcel, that does not front on a Minor Arterial, to CN,making it non-compliant, and in violation of the Comprehensive Plan. Why rezone the Apartment parcel that does not front on a Minor Arterial and who'sonly link to a Minor Arterial is a narrow easement, who's ownership with the Shell station parcel is not the same now, and not expected to be the samewith Townhouses, to CN, in violation of the Comprehensive Plan. There is no precedence to violate this Policy yet CPA-M-04 does it three times. Amendment 1. Argument
Amendment 1. purposes Development in the CN zone allows standalone attached dwellings in combination with office, retail and service uses.
According to the Comprehensive Plan Policy 16, Expanded CN zoning should only be where there is opportunity to provide small limited-scale commercialopportunity to the immediately surrounding residential community that would not result in an increase in scale or intensity, which would alter thecharacter of the nearby residential neighborhood. CPA-M-04 violates this. There is no "minimum" size for the commercial, Townhouses can increasedisproportionate to commercial. Take the following examples.
A simple example, Take a one acre parcel, currently with a three story building having commercial on the first floor and two apartmentson each of the 2nd and 3rd floors. Impose the new Amendment. A 3 story, standalone Townhouse(s) totaling 16 more units could bebuilt, without adding any new commercial establishment. 20 units total, that is a 5 times increase,(Concern has been expressed about a coffee stand out front (for the commercial), with 20 Townhouses behind. Clark Close said there isno "minimum" size for the commercial.) A scary example, if one considers the existing Shell Station as the one commercial establishment and uses the concept of "Similarownership purposes" to link the property acreage calculation of the Shell Station and the current Apartment property, (.67+.50 acres),under the new Amendment the owners could tear down the existing apartment building and build standalone Townhouse(s) totaling 23units, without adding any new commercial property.
Amendment 2a. Argument
2a. Amend RMC 4-2-060.C, Zoning Use Table – Uses Allowed in Zoning Designations – Residential, as follows:
Sometime before CPA-M-04, even without Townhouses or attached dwellings being allowed it the CN zone per RMC 4-2-080.A.6 Zoning Use Tables, theBenson, Cedar River, Talbot, or Valley Community Planning Areas. saw it coming and protected their zoning areas by adding a "not permitted" Condition.They did this unusual act in belief Townhomes are inappropriate for the CN zone!
The split zoned and P6 zoned parcels are the community's buffer to development. My property is behind the Apartment (APN 3342103240). For me andothers in similar positions with CPA-M-04 we will have 35" high Townhouses feet from our yards, with three story high balconies overlooking our yards.Nobody would want that, Please do not let that happen.
____________________________________________________________________________________________________________________________HISTORY
__________________________________________________________________________________________________________________________HISTORY(please forward to the Renton Planning Commissioners) Comments on CPA #23-M-01 1) Lot 2 is a residential lot on a residential street. On Lot 2 is a single family home. Many Kennydale residents including me wish to safeguard Kennydale'sresidential zoned property from commercial development. This was evident in the failure of the previous two Comprehensive Plan Amendments. Lot 2 isNon-Compliant with CN period. Lots 1 and 2 have the same owner. I understand this owner is requesting the CPA change, not to develop the properties but to sell the properties todeveloper(s). There is no development proposal or assurance the Lots will be developed together. This owner previously owned a third Lot, where theChurch is, and sold it in a separate transaction. Lot 2 could be rezoned and then also sold in a separate transaction, making it even more Non-Compliantwith CN.The Renton Municipal Code implements the City's policies adopted in the City's Comprehensive Plan. The City's Comprehensive Plan clearly states inPolicy L-16, that Commercial Neighborhood Zone CN is required to front on a Minor arterial. To my knowledge there are no exceptions to this for allexisting CN zoned property in Renton. Despite this Policy, Amendment CPA #23-M-01 proposes to rezone Lot 2, that has no front on the Minor arterial of30th St., to zone CN. 2) Staff withdrew two previous Comprehensive Plan Amendments due to community outrage, and failed Traffic Studies. This CPA does not require aTraffic Study or address the results of the Previous Traffic Studies. This is of major importance. 3) Misc. Errors Please correct the "General Description" to specify Lot 1 is adjacent to the southeast intersection of N 30th St and Park Ave., Lot 2 is adjacent to Park AveN., and Lot 3 is adjacent to . N 30th St.______________________________________________________________________________HISTORY
(please forward to the Renton Planning Commissioners)Hi to the new Renton Planning Commissioners, the following contains history concerned in the CPA 19-M-04 request.CPA 19-M-04: N 30th Street” Rezone is the same as CPA #16-0809, both propose to rezone the same property from R-6 residential to CN commercial,and change the Land Use designation from Medium Density to High Density. If the rezone is approved, future development will comply with thedevelopment standards in place for the CN zone under the Renton Municipal Code.CPA #16-0809 was before the Renton Planning Commission for two years. Many Residents told the Commission their many concerns. The PlanningCommission asked the developer to address these concerns and asked them to talk with the Kennydale Neighborhood Association.Chip Vincent presented the purposed rezone three times to the Kennydale Association. The first two times it caused a general uproar and disapproval aswitnessed by all including Mayor Denis Law. The Renton Planning Commission asked for a traffic study, which came back very bad. I have a letter dated4/27/18 from Mr. Richards, at the time President of the Kennydale Neighborhood Association, stating Chip Vincent reported to him there must be a bettercase for the rezone to continue. At the third Association meeting in Oct 2018 Chip Vincent announced the Rezoning request had been withdrawn to muchapplause. Follow-upThe traffic study results were not a surprise, a quick search of the web shows traffic at this location to be the worst in the State.Reference; The Renton Reporter 1/11/2013 'Renton Police Keep Watch On Traffic Congestion At Kennydale Elementary'.Reference; City of Renton, WA Resolution No. 2708 'A Resolution Of The City Of Renton, WA Concerning Preservation Of North Renton And KennydaleNeighborhoods From Deterioration Due To Traffic'.AlsoThe Renton Comprehensive Plan states that CN zoned lands need to front on a street classified as a Principal arterial, Minor arterial, or Collector. The site
area for the rezone is located one parcel away from the Minor arterial N. 30th Street. The following pictures show the actual access of the site area to N.30th Street. The access to N. 30th Street is through this easement which was never meant for commercial traffic, and does not meet the criteria to berezoned. ____________________________________________________________________________________________________________HISTORY
General Description
The applicant seeks a rezone of approximately 2.65-acres of the N 30th St Study Area from a land use designation Residential Medium Density (RMD) to Residential High Density
(RHD) and a zoning change from Residential-6 (R-6) to Commercial Neighborhood (CN) in the Kennydale Community Planning Area. The N 30th St Study Area, as shown in the vicinity
maps (Exhibits 1 and 2), is approximately 7.41 acres and consists of 12 parcels located between Park Ave N and I-405 on N 30th St Of t. (3 of the 12 do not front on N 30th St., 1416,
1406, and 2900. As required for CN by Policy L-16: , officials should be the first to comply with their own regulations)he 12 parcels in the N 30th St Study Area, five (5) are
proposed for rezone. Of the five (5) parcels proposed to be rezoned, three (3) are currently split zoned as R-6 and CN. Exhibit 3 and Exhibit 4 show the current and proposed land use
designations, while Exhibit 5 and Exhibit 6 show the current and proposed zoning.(from these Exhibits one cannot distinguish the 12 parcels so cannot tell what is being proposed
for individual parcels. Please show a parcel map such as I include at the end of this doc.) Staff recommends approval of this rezone proposal with a change in land use to RHD
with CN zoning, subject to the following code amendments: 1) update the purpose of the CN zone by allowing standalone attached dwelling units(this is specifically not permitted in
the CN Zone within the Benson, Cedar River, Talbot, or Valley Community Planning Areas, why now in Kennydale?) in combination with office, retail and service uses (RMC 4-2-
020.K); 2a) permit attached dwellings – townhouses (again, this is specifically not permitted in the CN Zone within the Benson, Cedar River, Talbot, or Valley Community Planning
Areas, why now in Kennydale?) in the CN zone as an allowed use in the Zoning Use Table (RMC 4-2-060.C), subject to revised condition #6 (RMC 4-2-080.A.6), 2b) revise Use
Condition No. 6 to encourage activation of the street edge by locating commercial and retail activities at the front of the site and standalone residential building(s) closest to the
abutting residential zone. The standalone residential would only be allowed if part of a horizontal mixed use development; 3) (again, this is specifically not permitted in the CN Zone
within the Benson, Cedar River, Talbot, or Valley Community Planning Areas, why now in Kennydale?) require new multi-family dwelling units in the CN zone to be subject to
residential design and open space standards (RMC 4-2-115.B.1); and 4) the maximum number of attached dwelling units would be equivalent to the Residential Multi-Family (RMF)
zone at 20 dwelling units per acre rather than four (4) dwelling units per structure (RMC 4-2-120A(this is up to a 5 times increase!!! And affects all existing CN zoned property in
Renton, including within the Benson, Cedar River, Talbot, or Valley Community Planning Areas, and they have not been invited to the Planning Meetings,why not?).
List of Exhibits (for the N 30th St Study Area)
Exhibit 1: Vicinity Map
Exhibit 2: Aerial Vicinity Map
Exhibit 3: Current Comprehensive Plan Land Use Designation Map
Exhibit 4: Proposed Comprehensive Plan Land Use Designation Map
Exhibit 5: Current Zoning Map
Exhibit 6: Proposed Zoning Map
Exhibit 7: Critical Area Areas Map
Exhibit 8: Arterial Streets Map
Background
Five (5) of the R-6 parcels (whole or partial) proposed for rezone are currently used for a single family dwelling, park-and-ride parking lot (Kennydale Park and Ride), vacant land, eight
unit apartment building, and the Kennydale Reservoir (water tower). Since attached residential units are not currently allowed in the R-6 zone, the apartment structure is a non-
conforming use. (This is appropriate as intended, because 1416 does not front on N 30th St., as required for CN by Policy L-16:. For this parcel Chip Vincent commentedDeveloper can re-evaluate what they can do with the existing zoning) The Kennydale Reservoir (LUA17-000633) received conditional use permit and site plan review approval on
December 7, 2017. (Rezoning serves no purpose for the Reservoir. It is Public Property not subject to private property regulations. That said changing to RHD is inappropriate , I
expect no high density population to be living there. Also, changing to CN is wrong as 1406 does not front on N 30th St., as is required for CN by Policy L-16:. Also what is the
commercial use?) If the rezone proposal is approved, the property owners could continue the existing commercial uses along N 30th St,(This is also true if not approved?) allow for
more mixed-use development opportunities, or permit standalone attached residential where abutting a residential zone (again, this is specifically not permitted in the CN Zone
within the Benson, Cedar River, Talbot, or Valley Community Planning Areas, why now in Kennydale?) based on the recommended code amendments to the CN zone. See Staff
Recommendation at the end of this staff report for recommended code changes to support the rezone. The proposal is a non-project action, and no associated development is
proposed.(So why is this being fast tracked during a Pandemic, when a Principle, the United Methodist Church is in Quarantine, and with public descent?)
The N 30th St Study Area parcels are adjacent to or abutting .(The Policy requirement is to front on N 30th St., not to be adjacent or abutting to another CN zoned parcel. 1416,
1406, and 2900 are not in compliance as required for CN by Policy L-16: , officials should be the first to comply with their own regulations) commercial neighborhood zoned
parcels and residentially zoned properties, as shown in Exhibit 5. To the north and south of the site is RMD land use designation with R-6 zoning. To the west is RMD and RHD with
Residential-8 (R-8) and Residential (R-10) zones. To the east, across I-405 right-of-way at Exit 6, is RMD and RHD with R-8 and CN zoning.
The Residential Medium Density (RMD) land use designation, as identified in the City of Renton Comprehensive Plan, is intended for areas that can support compact urban
development with access to urban services, transit, and infrastructure. RMD land uses are suitable for larger lot development, infill, and developing single-family residences at urban
densities. Alternatively, the implementation policies for Residential High Density (RHD) are intended for land uses to create conditions appropriate for a variety of housing unit types
or where there is existing multifamily development. RHD land uses may provide goods and services on a small-scale to surrounding residential neighborhoods. RHD unit types are
designed to support cost-efficient housing, facilitate infill development, have close access to transit service, and efficiently use urban services and infrastructure. Land designated
RHD is where projects would be compatible with existing uses and where infrastructure is adequate to handle impacts from higher density uses.(Studies do not support this in this
location, Reference CPA #16-0809).
Exhibits 2, 7 and 8 show the mapped built environment, street classification, proximity to I-405 on- and off-ramps, and locations of potential critical areas on the projected rezone
site and vicinity. Future development on these parcels is appropriate for the area, (yes, and as Chip Vincent pointed out can be developed with existing zoning. due in part to
these factors, and an RHD land use designation is recommended.
Review Criteria
RMC 4-9-020.F Review Criteria or the Comprehensive Plan Adoption and Amendment Process lists three (3) review criteria for Comprehensive Plan Amendments. The three (3)
criteria are as follows:
1. All Comprehensive Plan amendments will be evaluated on their merits based upon the following:
a. The effect upon the rate of growth, development, and conversion of land as envisioned in the Comprehensive Plan; (NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
b. The effect upon the City’s capacity to provide adequate public facilities;(NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
c. The effect upon the rate of population and employment growth;
(NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
d. Whether Comprehensive Plan objectives are being met as specified or remain valid and desirable;
e. The effect upon general land values and housing costs;
(NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
f. Whether capital improvements or expenditures, including transportation, are being made or completed as expected; (NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
g. Whether the initiated amendment conforms to the requirements of the GMA, is internally consistent with the Comprehensive Plan, and is consistent with the County-wide
Planning Policies for King County;
h. The effect upon critical areas and natural resource lands;
i. Consistency with locational criteria in the Comprehensive Plan and application requirements established in this section; (NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
j. Consistency with the policies set forth in the Comprehensive Plan;
k. The effect upon other considerations as deemed necessary by the Department.
(NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
2. All applications must meet at least one of the following criteria:
a. The request supports the vision embodied in the Comprehensive Plan; or
b. The request supports the adopted business plan goals established by the City Council; or
c. The request eliminates conflicts with existing elements or policies; or
d. The request amends the Comprehensive Plan to accommodate new policy directives of the City Council.
3. Proposals that include a concurrent rezone proposal shall also comply with the decision criteria for a change of zone classification in RMC 4-9-180.
Analysis
Criteria 1
Criteria 1 of the Comprehensive Plan Review Criteria has been met. Parts a-h are addressed in the impact analysis below. The Department of Community and Economic Development
has not identified any additional considerations as noted in part k. The proposal has met application requirements as noted in part i and j. Part i and j require consistency with the
locational criteria and policies in the Comprehensive Plan. Comprehensive Plan Policy L-16 describes the locational criteria for the RHD land use designation and the CN zone within it:
(NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
(3 of the 12 parcels do not front on N 30th St., 1416, 1406, and 2900. As required for CN by Policy L-16: , officials should be the first to comply with their own
regulations)
Policy L-16: Residential High Density – Designate land for Residential High Density (RHD) where access, topography, and adjacent land uses create conditions appropriate for a
variety of housing unit types, or where there is existing multifamily development. RHD unit types are designed to incorporate features from both single family and multifamily
developments, support cost-efficient housing, facilitate infill development, have close access to transit service, and efficiently use urban services and infrastructure. Land designated
RHD is where projects will be compatible with existing uses and where infrastructure is adequate to handle impacts from higher density uses. The study area is less compatible with its
current RMD designation and more compatible with the proposed RHD designation. (VERY NOT TRUE),
3 of the 12 parcels do not front on N 30th St., 1416, 1406, and 2900 as required for CN by
Policy L-16:
2900
This property is a rental house with the driveway on Park, not 30th. HOW DOES THIS RESIDENTAL PROPERTY QUALIFY FOR RHD CN? SEE PICTURE
1416 The predecessor to CPA 19-M-04, CPA #16-0809 was before the Renton Planning Commission for two years. Renton Planning Commission asked for answers to the many
questions brought up by the public. As far as I know the Commissioners or the public never received answers, including the final results of a traffic study the Commission
requested. I thank the previous Planning Commission, Chip Vincent and the Community Development Dept. for their previous support to Kennydale residents which resulted in
rejecting the zoning change
1416 is located one parcel away from the Minor arterial N. 30th Street. The following pictures show the actual access of the site area to N. 30th Street. The access to N. 30th
Street is through this easement which was never meant for commercial traffic, and does not meet the criteria to be rezoned.
1406 Rezoning serves no purpose for the Reservoir. It is Public Property not subject to private property regulations. That said changing to RHD is inappropriate, I expect no
high density population to be living there. Also, changing to CN is wrong as 1406 does not front on N 30th St., as is required for CN by Policy L-16:. Also what is the commercial
use?
The study area is currently split zoned as R-6 and CN and is being proposed to be amended to all CN zoning.
· Commercial Neighborhood Zone – Zone lands Commercial Neighborhood (CN) that provide goods and services on a small-scale to a surrounding residential neighborhood
and that front on a street classified as a Principal arterial, Minor arterial, . (So you don’t miss it, this is one Policy being ignored, 3 of the 12 parcels do not front on
N 30th St., 1416, 1406, and 2900 as required for CN by Policy L-16: , officials should be the first to comply with their own regulations) or Collector. Expanded
CN zoning should only be where there is opportunity to provide small limited-scale commercial opportunity to the immediately surrounding residential community that would
not result in an increase in scale or intensity, which would alter the character of the nearby residential neighborhood. The CN zone implements the Residential High Density
land use designation.
This proposal meets the locational criteria of the RHD designation and CN zoning. (VERY NOT TRUE, see above), Designation of this entire study area to RHD land use eliminates the
issue of attached dwelling units at 1416 N 30th St being a non-conforming use. (This is not an issue, it is appropriate as intended, because 1416 does not front on N 30th St., as
required for CN by Policy L-16:. For this parcel Chip Vincent commented Developer can re-evaluate what they can do with the existing zoning) It provides a small opportunity for
commercial and residential infill development on four (4) parcels (please identify which parcels) within the study area. The study area for the proposal is located along N 30th St or
is located one parcel away from N 30th St. It is anticipated that through common ownership or proximity to N 30th St, the study area is
intended to be developed jointly with commercial uses required along the street. .(This is double talk, the Policy requirement is to front on N 30th St., not
to be adjacent or abutting to another CN zoned parcel, not to be in proximity, anticipated or intended. Where does common ownership apply when parcels are being bought
and sold separately? The 1416 and 1410 properties have similar ownership not common as they are owned by different LLCs. 1410, the Shell Station has developmental
restrictions on its Title from the Shell Co., Are there any restrictions on the Park and Ride property Title? 2900 the rental house behind the Park and Ride may well be sold on
its own with the moves the Church is making. In short, 1416, 1406, and 2900 are not in compliance as required for CN by Policy L-16: , officials should be the first to comply withtheir own regulations) The portion (this is an admission that some do not) of the study area that fronts N 30th St is classified as a Minor Arterial (Exhibit 8).
The proposed use of the properties provide a limited scale expansion of commercial, mixed-use, and standalone attached residential (again, this is specifically not permitted in the
CN Zone within the Benson, Cedar River, Talbot, or Valley Community Planning Areas, why now in Kennydale?) opportunities where abutting residential zones, but it is not
expected to significantly increase the scale or intensity of development in this area. (NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC, also your counter statement below ‘thepossibility for expansion when I-405 expands’.) The overall purpose of the CN would remain the same, to provide for small-scale convenience retail/commercial areas offering
incidental retail and service needs for the surrounding area while maintaining compatibility with the scale and character of the neighborhood. This designation is the smallest and
least intensive of the City’s commercial zones.
The current zoning and parcel areas have the potential to expand or redevelop and thereby the potential to expand commercial and residential uses on a few of the properties within
the study area. However, the existing properties already contain commercial or residential development with either a convenience store and gas station, fire station (public not
commercial), water tower (public not commercial), office building, retail store, service building, park-and-ride, or a single family home (non conforming in CN). Currently, new
development in the CN zone is limited to 35 feet in height and four (4) residential units per structure. However, staff is recommending adjusting the maximum net residential density
allowed within the CN zone to 20 dwelling units per net acre (du/ac). Two- to three-story development and 20 du/ac is generally compatible with the adjacent development. For
example, there is a three-story triplex and a three-story duplex located on the southwest corner of N 30th St and Park Ave N that are around 35 feet in height and 20 du/ac.
The study area is appropriate for a RHD designation due to the abutting RHD designation, constraint of the abutting parcels, and general lack of sensitive areas in the area. Within the
vicinity of the site are other developments that are compatible with the increases in commercial potential, density level and height being proposed.
All new structures, conversion of vacant land, conversion of a residential use to a nonresidential use, exterior modification, alterations, enlargements, and/or restoration of
nonconforming structures in the CN zone would be subject to Urban Design District ‘D’ Regulations. The purpose of the urban design regulations under RMC 4-3-100 were
established in accordance with and to implement policies established in the Land Use Element of the Comprehensive Plan. These standards are divided into seven (7) areas: a) site
design and building location; b) parking and vehicular access; c) pedestrian environment; d) recreation areas and common open space; e) building architectural design; f) signage; and
g) lighting. In addition, residential design and open space standards under RMC 4-2-115 would apply to standalone attached residential units following the recommended code
amendments to the CN zone. The purpose of residential design and open space standards is to implement policies established in the Land Use Element of the Comprehensive Plan,
enhance quality of life by encouraging new residential development to produce beautiful neighborhoods of well-designed homes, and to mitigate adverse impacts (NO STUDIES
HAVE BEEN PROVIDED TO THE PUBLIC) of density for the neighborhood and the surrounding community.
Criteria 2
This proposal fulfills two of the measures in criteria 2: it supports the vision embodied in the Comprehensive Plan and supports the adopted business plan goals established by City
Council. As a result, it meets criteria 2. (It conflicts with the City Council Resolution; City of Renton, WA Resolution No. 2708 'A Resolution Of The City Of Renton, WA Concerning
Preservation Of North Renton And Kennydale Neighborhoods From Deterioration Due To Traffic'.)
Renton’s Business Plan vision is summarized in the tagline “(t)he center of opportunity in the Puget Sound Region where families and businesses thrive.” One of the characteristics of a
thriving city is the development of neighborhood nodes that will “…reduce transportation impacts (NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC) within the City by allowing
residents to work and shop close to where they live, as well as, provide alternatives to single-occupant vehicle trips.” Two land use goals support this vision:
One of the characteristics of a thriving city is the development of neighborhood nodes that will “…reduce transportation impacts (NO STUDIES HAVE BEEN PROVIDED TO THE
PUBLIC) within the City by allowing residents to work and shop close to where they live, as well as, provide alternatives to single-occupant vehicle trips.”[1] Two land use goals support
this vision:
· Goal L-K: Provide an energetic business environment for commercial activity providing a range of service, office, commercial, and mixed-use residential uses that enhance the
City’s employment and tax base along arterial streets and in Centers.
· Goal L-L: Transform concentrations of linear form commercial areas into multi-use neighborhood centers characterized by enhanced site planning, efficient parking design,
coordinated access for all modes of transportation, pedestrian linkages from adjacent uses and nearby neighborhoods, and boulevard treatment.
The proposal meets the above Land Use goals. (NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC) With the proposed rezone, the environment within the N 30th St Study Area will
help to broaden the commercial and residential uses beyond its current formation. A larger area of consistent zoning will improve the potential range of service offered to the
neighborhood, providing a greater opportunity for local residents to obtain goods and potentially reduce trips. CN zoning requires landscaping and pedestrian connections that will
help to implement these goals. (It conflicts with the City Council Resolution; City of Renton, WA Resolution No. 2708 'A Resolution Of The City Of Renton, WA Concerning
Preservation Of North Renton And Kennydale Neighborhoods From Deterioration Due To Traffic'.)
The City of Renton Business Plan states that Renton should “(r)ecruit and retain businesses to ensure a dynamic, diversified employment base,” under its economic vitality and
strategically position goal for the future. Goal ED-B states a similar goal in the Comprehensive Plan Economic Development Element. The proposed rezone presents an opportunity to
retain and expand business in the Kennydale neighborhood node. Without the rezone, the possibility for expansion and a more cohesive development of the area would be lost when
I-405 expands. Neighborhood retail businesses contributes to Renton’s diversified economic base to ensure the long-term economic health of Renton and its residents. (It conflicts
with the City Council Resolution; City of Renton, WA Resolution No. 2708 'A Resolution Of The City Of Renton, WA Concerning Preservation Of North Renton And Kennydale
Neighborhoods From Deterioration Due To Traffic'.)
Criteria 3
As a rezone proposal, criteria 3 requires compliance with RMC 4-9-180.F.1 Criteria for Rezones Requiring a Comprehensive Plan Amendment:
The following findings shall be made:
The proposed amendment meets the review criteria in RMC 4-9-020; and
a. Is consistent with the policies set forth in the Comprehensive Plan; and
b. At least one of the following circumstances applies:
i. The property subject to rezone was not specifically considered at the time of the last area land use analysis and area zoning; or
ii. Since the most recent land use analysis or the area zoning of the subject property, authorized public improvements, permitted private development or other
circumstances affecting the subject property have undergone significant and material change.
Criteria 2, at RMC 4-9-020.F.2, demonstrates that the proposal is consistent with policies set forth in the Comprehensive Plan. In regards to the second test, this property was not
specifically considered at the time of the last area land use analysis or zoning, which was completed for the Comprehensive Plan update in 2015. The predecessor to CPA 19-M-04,
CPA #16-0809 was before the Renton Planning Commission for two years. Renton Planning Commission asked for answers to the many questions brought up by the public. As
far as I know the Commissioners or the public never received answers, including the final results of a traffic study the Commission requested. I thank the previous Planning
Commission, Chip Vincent and the Community Development Dept. for their previous support to Kennydale residents which resulted in rejecting the zoning change Thus, the
proposal meets the findings in RMC 4-9-180 for rezones, thereby meeting the criteria 3 in RMC 4-9-020.
Impact Analysis (NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
Effect on rate of growth, development, and conversion of land as envisioned in the Plan
The proposal has the potential to have a small effect on the amount of buildable lands within the City with a slight increase in intensity of commercial and multi-family uses. The
conversion of residential land to commercial and/or residential uses is envisioned in the Comprehensive Plan. Urban design regulations, specifically District ‘D’, would apply to the
rezoned parcels. Applicable development activity would be more consistent as the urban design regulations that implement policies established in the Land Use Element of the
Comprehensive Plan.
(NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
Effect on the City’s capacity to provide adequate public facilities
This proposal has no effect on the City’s capacity to provide adequate public facilities. Existing development is already served or has the ability to be served by utilities and emergency
services due to the level of existing development around the study area.
Effect on the rate of population and employment growth
Projected population and employment from this proposal is too small to have any significant effect on Renton’s growth. It could result in additional housing units (approximately 1 to
28 units) and additional commercial space (estimated between 6,000 and 13,500 square feet). The scale of increase is anticipated in Renton’s growth and employment estimates.(NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
Whether Plan objectives are being met as specified or remain valid and desirable
Renton’s Comprehensive Plan anticipates infill development on vacant and underutilized land in established neighborhoods. In addition, Renton’s Comprehensive Plan anticipates the
conversion of strip commercial development into multi-use environment and the enhancement of neighborhood commercial nodes and development of new multifamily and mixed-
use in the high residential designations. This proposal furthers those plan objectives, as noted in the analysis above.
(NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
Effect on general land values or housing costs
In general, this project should not have a significant effect on land values or housing costs. The ability to expand and operate a commercial business or attached residential housing
on the proposed rezone study area will increase the value of that property. Increasing the availability of goods in the Kennydale neighborhood commercial node could produce a
slight increase in land values over time for properties in the vicinity.
(NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
Whether capital improvements or expenditures are being made or completed as expected
This impact is not applicable.(NO STUDIES HAVE BEEN PROVIDED TO THE PUBLIC)
Consistency with GMA and Countywide Planning Policies
The proposal is consistent with GMA and the Countywide Planning Policies. Both documents support the expansion of urban levels of service within urban areas. GMA has several
goals that are supported with this proposal including reduction of sprawl, concentration of urban growth, and economic development. Similarly, the Countywide Planning Policies
support business development and the concentration of development in policy EC-7, which supports the retention and expansion of small businesses. It also supports the
development of neighborhood centers and nodes under policy DP-38.
Effect on critical areas and natural resource lands
The proposed rezone is located within a wellhead protection zone and there are limited areas of steep slopes mapped there. Any future development within the study area will be
required to comply with critical area regulations and development standards in place for the CN zone under the Renton Municipal Code.
Staff Recommendation
Staff finds that the proposed Comprehensive Plan Amendment and Rezone is consistent with the Comprehensive Plan and with the criteria for amendment in the Renton Municipal
Code. Staff recommends approval of this amendment for the reclassification of land use designation to Residential High Density (RHD) and rezoning to Commercial Neighborhood
(CN), subject to the following code amendments:
1. Amend RMC 4-2-020K, Commercial Neighborhood Zone, as follows:
K. COMMERCIAL NEIGHBORHOOD ZONE (CN):
The purpose of the Commercial Neighborhood Zone (CN) is to provide for small-scale convenience retail/commercial areas offering incidental retail and service needs for the
surrounding area. Development in the CN zone allows standalone attached dwellings in combination with office, retail and service uses. Uses serving a larger area may be appropriate
if they also serve the residents of the immediate area and are compatible with the scale and character of the neighborhood. This designation is the smallest and least intensive of the
City’s commercial zones.
2a. Amend RMC 4-2-060.C, Zoning Use Table – Uses Allowed in Zoning Designations – Residential, as follows:
Uses:COMMERCIAL ZONING DESIGNATIONS
CN CV CA CD CO COR UC
C. RESIDENTIAL
Detached dwelling
Attached dwellings – Flats P6 P6 P6 P6 P16 P6 P6
Attached dwellings – Garden
style apartments
P6
Attached dwellings –
Townhouses
P6 P6 P6
Attached dwellings – Carriage
houses
P6 P6
Manufactured Homes
Manufactured homes
(the above change affects all of Renton CN zones, except Benson, Cedar River, Talbot, or Valley Community Planning Areas. Proper notification has not happened.)
2b. Amend RMC 4-2-080.A.6, Conditions Associated with Zoning Use Tables, as follows:
RMC 4-2-080 CONDITIONS ASSOCIATED WITH ZONING USE TABLES:
A. SUBJECT TO THE FOLLOWING CONDITIONS:
6. Specified residential use(s) are not allowed within one thousand feet (1,000') of the centerline of Renton Municipal Airport runway. (*)Attached dwellings are not permitted in the
CA or CN Zone within the Benson, Cedar River, Talbot, or Valley Community Planning Areas. (this is specifically not permitted in the CN Zone within the Benson, Cedar River, Talbot,
or Valley Community Planning Areas, why now in Kennydale?)
Where not prohibited, attached dwelling units are permitted subject to the following conditions and standards in addition to RMC 4-4-150, Residential Mixed-Use Development
Standards:
a. Standalone Residential – Where Allowed: Standalone residential buildings are permitted:
i. In the CD Zone outside of the Downtown Business District, provided residential amenity space and/or lobby space is provided on the ground floor along the street frontage;
ii. In the CV Zone where not abutting NE Sunset Blvd. east of Harrington Avenue NE;
iii. In the CA Zone where abutting a residential zone if at least one vertical mixed building is constructed along the street frontage(s) with a minimum of two (2) residential
stories above commercial, the standalone residential building(s) are sited closest to the abutting residential zone and, if townhouses, limited to three (3) stories;
iv. In the UC Zone along streets not designated as pedestrian-oriented streets through the Master Site Plan process; and
v. In the COR Zone as determined through the Master Site Plan process.
vi. In the CN Zone where abutting a residential zone, the standalone residential building(s) are sited closest to the abutting residential zone and not fronting along an arterial
street. Additionally, standalone residential building(s) are only allowed as part of a horizontal mixed use development. (this is specifically not permitted in the CN Zone
within the Benson, Cedar River, Talbot, or Valley Community Planning Areas, why now in Kennydale?)
Where standalone residential buildings are not allowed, dwelling units shall be integrated into a vertically mixed use building with ground floor commercial. (this is what is
permitted in the CN Zone within the Benson, Cedar River, Talbot, or Valley Community Planning Areas, why not in Kennydale?)
b. Commercial Uses: Commercial uses in residential mixed-use developments are limited to retail sales, on-site services, eating and drinking establishments, taverns, daycares,
preschools, indoor recreational facilities, pet daycares, craft distilleries/small wineries/micro-breweries with tasting rooms, general offices not located on the ground floor, and
similar uses as determined by the Administrator.
Uses normal and incidental to a building including, but not limited to, interior entrance areas, elevators, waiting/lobby areas, mechanical rooms, mail areas,
garbage/recycling/compost storage areas, vehicle parking areas, and areas/facilities for the exclusive use of the residents are not considered commercial uses.
c. Timing of Development: A building permit shall not be issued for any standalone residential building(s) prior to the issuance of a building permit for any required standalone
commercial or vertically mixed use building(s) and no certificate of occupancy shall be issued for any standalone residential building(s) prior to the issuance of a certificate of
occupancy for any required standalone commercial or vertically mixed use building(s).
3. Amend RMC 4-2-115.B.1, Residential Design and Open Space Standards – Applicability, as follows:
B. APPLICABILITY:
1. This Section shall apply to all new primary and attached dwelling units in the following zones: Resource Conservation (RC), Residential-1 (R-1), Residential-4 (R-4), Residential-6 (R-6),
Residential-8 (R-8), Residential-10 (R-10), and Residential-14 (R-14), and unit lot subdivisions within the RMF zone, and Commercial Neighborhood (CN). (this change affects all of
Renton CN zones, Benson, Cedar River, Talbot, or Valley Community Planning Areas have not been included, invited, or notified, as well as the rest of Renton) The standards of
the Site Design subsection are required to be addressed at the time of subdivision application. The standards of the Residential Design subsection are required to be addressed at the
time of application for building permits. The standards of Residential Design are required to be addressed for the building for which the building permit is being issued.
2. Additions and/or expansions to detached or attached dwellings that are valued at fifty thousand dollars ($50,000.00) or more, or at fifty percent (50%) or greater of the most recent
assessment or appraisal shall require that the entire dwelling or structure comply with the standards of the Residential Design subsection.
3. When new dwelling units are created in the Residential Ten Dwelling Units per Acre (R-10) and Residential Fourteen Dwelling Units per Acre (R-14) zones, any existing dwelling units
included in the development shall comply with the standards of this Section.
4. Amend RMC 4-2-120A, Development Standards for Commercial Zoning Designations (CN, CV, CA, & UC), as follows:
CN - Maximum Net Residential Density: 4 dwelling units per structure20 dwelling units per net acre.(this change affects all of Renton CN zones, Benson, Cedar River, Talbot, or Valley Community Planning Areas have not been included, invited, or notified, as well as the rest of
Renton)
I added my parcel map below
[1] Renton Comprehensive Plan Vision, p. 2.