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HomeMy WebLinkAboutC_Hanbey Public Comment_230418 .docxAlex: This e-mail is in response to a meeting we had the week of April 5th. Thank you for asking for feedback on the applicant’s SEPA document submittal. As you will see from the length of the document this is taking some time to prepare, and I’m sending about 2/3s of the feedback now, and plan to send the rest this week. In this message you’ll see two items from the meeting and at last one new item. The two items are: 1) additional signage on proposed development property, and 2) feedback on developer’s SEPA document. The new item has to do with the on-hold letter with a very specific concern about this. This communication covers item 1 and most of item 2. When the rest of item 2 is sent there will be some comments about an on-hold letter sent to the developer on September 8. For easier reading, comments in italics are specific to answers in the applicant’s SEPA document. See below about less than acceptable answers, which seem would require the applicant to revise and resubmit answers, if not the entire SEPA document. ADDITIONAL SIGNAGE Additional Signage: at the meeting I understood the intent to add another sign on the property at N Logan Avenue between N 3rd Street and N 4th Street. Based on the traffic pattern (one way streets on both 3rd and 4th Streets), could the additional sign be placed on the N 4th Street of the property? SEPA ENVIRONMENTAL CHECKLIST In the State WAC (197-11-960) the applicant is required to answer questions ‘accurately and carefully…’ and the use of ‘not applicable’ or ‘does not apply’ can be used only if there is an explanation or why the answer is unknown. The above being said, the applicant’s answers in the SEPA Environmental Checklist is inadequate. The document has the ‘feel’ of a hastily put together document, either filled out at the last minute, or answered with little forethought or answered with little effort made. There are questions unanswered, incomplete answers, errors in responses, etc. I believe the city is within its authority to reject applications if documents are not complete, or inaccurate, such as with the SEPA Environmental Checklist. BACKGROUND 11) Give brief, complete description of proposal… In the answer the applicant states “Apartments are slated to be 60% standard and 40% senior accommodations (2/28/2022). However, a document from the applicant in conjunction with an electronic neighborhood meeting as part of public notice requirements the applicant states “25% of the units will be allocated for senior housing”. And now, from what was mentioned at the meeting, 0% of the units are allocated or senior housing. How can the description in the SEPA Environmental Checklist show that nearly ½ of the proposed units are for seniors, and then somehow things change to 0%? Shouldn’t the applicant have to revise the answer, or provide an explanation, either of which should be ‘accurate and careful’? ENVIRONMENTAL ELEMENTS Earth 1 a), 1 b), 1 c) no answer for these questions. Doesn’t the applicant have to provide an answer, even if it is “no” or “n/a”? If n/a, the applicant is required to explain why “n/a” 1 d) Are the surface indications or history of unstable soils in the immediate vicinity? The answer includes, in part, “… stable to depths greater than 20’” What if the depth is greater than 20 feet? Wouldn’t the parking, presumably two levels, go deeper than twenty feet? 1 e) Describe the purpose, type, total area, and approximately quantities and total affected area of any filling, excavation, and grading proposed. Indicate source of fill. How does the removal of fill affect water run off? The property, currently vacant, has some higher spots and lower spots, with vegetation throughout. Presumably, the ground absorbs a significant amount of water when it rains, or possibly groundwater from the adjacent properties to the east. How would water flow to the east from the proposed development? What about groundwater from adjacent areas, presumably impeded by the depth of the parking structure at the bottom of the property? 1 g) About what percent of the site will be covered by impervious surface? Answer provided is 62.68%; however, this can’t be right. To say the remaining 37.32% is no impervious surface is an overstatement. Surely the site is mostly paved with entrances or exits, areas for garbage bins, and emergency access, etc. Shouldn’t the applicant have to provide an accurate answer? Earth What type of emissions to the air would result from the proposal during constructions, operation, and maintenance when the project is completed? Answer is provided about the construction phase. What about the operation and maintenance? The answer is not complete, and if “n/a” is the answer, then the applicant needs to explain why the answer is “n/a” per the instructions. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally describe. Answer given is “None known.” This is a poor answer, with little to no thought given. However, as Logan Avenue is a main North/South road, It seems obvious vehicle emissions will affect the property. In addition, the proximity of the property to the Renton Municipal airport would have an impact from airplane exhaust during takeoffs and landings. Also, the Boeing plant nearby does noise testing, revving up airplane engines, and this produces exhaust. It seems this answer is incomplete, and should revised. Proposed measures to reduce or control emissions or other impacts to air, if any: Answer refers to construction—what about emissions during operation and maintenance? Presumably there are air intakes/vents, etc, and any mechanical, heating, cooling or other systems would result in emissions. 3) Water a) Surface Water: 1) Is there any surface water body on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds, wetlands). If yes, describe type and provide names. If appropriate, state what stream or river it flows into. It may be there is vegetation that indicates surface water—such as moss and plants that grow in water-saturated soil. This is because of the undulation of the ground on the property. It is difficult to describe the way the property varies in height, which is due in part to the length of the location from North to South. A visual inspection of the property provides insight. On the edges are the points, even with the sidewalks to the west and east. Approximately 10 feet from these edges the land elevates about 2 feet. More importantly, there are two high areas, akin to swales, on the south and along the east side of the property. These swales or embankments are 10-20 feet wide and run close to the entire southern boundary of the property, and most of the east side of the property. Both swales are about 7-10 feet above the sidewalk level. These swales move water in certain directions, and at the ends or along the edges where there are lower points water collects. It is unclear what impact the flow of water has on the vegetation, and a closer inspection may be necessary to assess if there are areas that could be considered as wetlands due to the pooling of water in lower areas on the property. Again, the odd-shape of the property—a long rectangle—and the three levels of the land --may result in areas that are considered surface water or wetland. 2) Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If yes, please describe and attach available plans. See comments for item 1) above 3) Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill material. See comments for item 1) above 4) Would the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if known. See comments for item 1) above 5) Does the proposal lie within a 100 year floodplain? Answer is “No.” Is this correct? The location is near the Cedar River from both the South side of the property and the west side of the property. The applicant states the river is 450 feet to the south. It is possible the river is similarly close to the west. 6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge. See comments for item 1) above c) Water runoff (including stormwater) 1) Describe the source of runoff (including stormwater) and method of collection and disposal, if any (including quantities, if known). Where will this water flow? Will this water flow into other waters? Is so, describe. No answer provided. 2) Could waste materials enter ground or surface waters? If so, generally describe See comments under “a. Surface Water 1)” above. 3) Does the proposal alter or otherwise affect drainage patterns in the vicinity of the site? If so, describe See comments under “a. Surface Water 1)” above. d) Proposed measures to reduce or control surface, ground, and runoff water, and drainage pattern impacts, in any. See comments under “a. Surface Water 1)” above. 4) Plants See comments under “a. Surface Water 1)” above. 5) Animals See comments under “a. Surface Water 1)” above. 6) Energy and Natural Resources a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the competing project’s energy needs? Describe whether it will be used for heating, manufacturing, etc. No answer given. b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally describe No answer given. Considering the height of the proposed structure, it is likely the building will “shade” light later in the day, essentially advancing “sundown” by some amount of time such as an hour, two hours, etc. c. What kinds of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any. No answer given. 7) Environmental Health a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste, that could occur as a result of this proposal? If so, describe. 1) Describe any known or possible contamination at the site from present or past uses. No answer given. 2) Describe existing hazardous chemicals/conditions that might affect project development and design. This includes underground hazardous liquid and gas transmission pipelines located within the project area and in the vicinity. No answer given. 5) Proposed measures to reduce or control environmental health hazards, if any. Answer is “None necessary”. However, without answering questions 1 and 2 it would seem premature to make such a definitive statement. b. Noise 2) What types and levels of noise would be created by or associated with the project on a short-term or long-term basis (for example: traffic, construction, operation, other)? Indicate what hours noise would come from the site. Answer does not indicate what hours vehicular access and parking would create noise. Also, wouldn’t services like garbage, recycle, yard waste vehicles, and site maintenance cause noise? Leaf blowers, etc. 3) Proposed measures to reduce or control noise impacts, if any. See comments directly above. 8) Land and Shoreline Use a) What is the current use of the site an adjacent properties? Will the proposal affect current land uses on nearby or adjacent properties? Answer refers to the site being vacant; however, there is as major utility pipeline or pipelines that serve/s the Boeing plant running along the property. The applicant’s answer underemphasizes the impact to the residential neighborhood to the North, South, and East which would be impacted by the sheer mass and size of the proposed development and the traffic access into, through, and alongside the property. h) Has any part of the site been classified as a critical area by the city or county? If so, specify. No answer given. Presumably the answer is “no” but the applicant did not state this. i) Approximately how many people would reside or work in the completed project? No answer given. j) Approximately how many people would the competed project displace? No answer given. Apparently the answer is “no” but the applicant did not state this. Also, is it true the developer has purchased a home that is adjacent to the property? If so, couldn’t one argue the project will displace however many people live in the adjacent property? k) Proposed measures to avoid or reduce displacement impacts, if any: No answer given. L) Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any: No answer given. This is a critical issue, considering the impacts to the residential neighborhood by the size and mass of the proposed structure, traffic impacts, etc. n) Proposed measures to reduce or control impacts to agricultural and forest lands of long-term significance, if any. No answer given. Presumably the answer is “no” but the applicant did not state this. 9) Housing a) Approximately how many units would be provided, in any? Indicate whether high, middle, or low-income housing. No answer given. How can the applicant ignore this question? How can this city accept this document with such an obvious omission? As this is a proposed apartment/condo development, why doesn’t the applicant answer this fundamental question? It seems this document should be returned and an answer be required. Also, the applicant at first indicated the proposal would have 40% senior housing. During a ‘public’ meeting the amount was revised downward to 25%. And now the amount of senior housing is 0%. It seems the developer should have to explain how a development that was to be nearly half senior housing is now no senior housing at all. 11) Light and Glare c) What existing off-site sources of light or glare may affect your proposal? Answer says “None”. However, across the street there is a football stadium with open end facing towards the development and a large stadium parking lot across the street. It is hard to imagine there are not light impact from the stadium when in use AND also from the large parking lot across the street from night lighting. There are also street lights on Logan Avenue which is a major thoroughfare so there are bright street lights along Logan Avenue. 12) Recreation a) What designated and information recreational opportunities are in the immediate vicinity? Answer mentions several parks. Does not mention Cedar River Trail (a riverwalk), Jones Park, or the Renton Senior Activity Center, which is literally across the street from the property. The reduction in senior units is particularly troubling due to the very close proximity the property has to the Renton Senior Center, which has many activities, including outdoor exercise equipment. This is related to a question “shouldn’t the applicant have to explain why the proposal was presented as 40% senior housing, then lowered to 25% senior housing, and now is no senior housing?