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HomeMy WebLinkAboutRainier-Grady-Junction-TOD-Planned-Action-Final-EISArmondoPavoneIIMayorCommunity&EconomicDevelopment/1BrianneBannwarth,InterimAdministratorMarch27,2024Subject:Rainier/GradyJunctionTODPlannedActionFinalEnvironmentalImpactStatementDearReader:TheattachedFinalEnvironmentalImpactStatementfEIS)respondstocommentsontheDraftEISandcompletestheenvironmentalanalysisoftheRainier/GradyJunctionTransitOrientedDevelopment(TOD)SubareaPlan(“SubareaPlan”).TheCityofRenton(City)adoptedtheSubareaPlanin2021toestablishacommunity-drivenvisionforapedestrian-orienteddistrictsurroundingthefutureSouthRentonTransitCenterlocatedatthenortheastcorneroftheRainierAveSandSW/SGradyWayjunction.Theproposedconceptsincludemixed-usedevelopmentatscalesexceedingcurrentallowances,strongpedestrianandbicycleconnections,newstreetsthatcreatebetteraccessforallmodesinthesuper-blockreferredtoas“RentonVillage,”apedestrian-orientedinternalmainstreet,thecreationofpublicopenspaceuponutilityeasementcorridors,andhousingthataccommodatesawiderangeofincomes.TheCitysecuredagrantfromtheWashingtonStateDepartmentofCommercetocompletean[ISpursuanttotheStateEnvironmentalPolicyAct(SEPA)toassessthreealternativesthatincludedifferentlevelsofhousingandemploymentgrowthinthestudyarea:•Alternative1—ExistingPlan(NoAction):Continuationofexistingregulationsandtrends.•Alternative2—Incentive-BasedGrowth:SetminimumstandardsandincentivestoachieveoptimalSubareaPlanimplementationresultinginapredominatelymid-risedevelopmentpatternwithsomehigh-risedevelopmentpossiblethroughincentivizedstandards;and•Alternative3—RequiredPublicBenefit:Allowhigh-risedevelopmentwithrequiredstandardsandpublicbenefits.AsofMarch2024,theRentonPlanningCommissionandCityCouncilPlanningandDevelopmentCommitteerecommendAlternative2withitsincentive-basedapproach.BuildingheightandgrowthlevelscouldrangeuptolevelsstudiedwithAlternative3.TheSEPArequiresastatementofobjectivesdescribingthepurposeandneedfortheproposals.TheSubareaPlanincludesthefollowingfourgoals,whichserveasobjectivesforthisEIS:1.AlignwithOverallVisionforRenton:AlignwithoverallvisionforRenton’sCityCenterareaandsupporttheuniqueroleofthesubareainwaysthatarecomplementarytoDowntown,thelargerCityCenterarea,andRentonasawhole.1055SGradyWay,Renton,WA98057IIrentonwa.gov Page2of2Match27,20242.TransitiontoMultimodalCenter:Transitiontheareaintoapedestrian-orienteddistrictwithamulti-modalcenterandstrongpedestrianconnections.3.CreateaLivableNeighborhood:Createalivable,distinctneighborhoodthatisactive18hoursaday,complementsDowntown,andgracefullyintegrateswithneighboringareas.4.CatalyzeDesiredChanges:Leveragetherecentandplannedpublicinvestmentintheareafortheprivateinvestmenttofollow.TheCityissuedaDraftElSinJanuary2024,andtheCityprovideda30-daycommentperiodandahearing.TheFinalEIScompletestheSEPAprocess,identifiesaPreferredAlternative,andprovidesresponsestocommentsontheDraftEIS.TheDraftEISandFinalElSshouldbeconsideredtogether.TheFinalEISidentifiesenvironmentalimpactsofthealternativesandwaystomitigateimpactsofdevelopment.EnvironmentalmattersevaluatedintheEISinclude:thenaturalenvironment;landuse;transportation;publicservices;andutilities.YourinterestintheCityofRentonandthecontentoftheFinalEISisgreatlyappreciated.Ifyouwouldlikemoreinformationaboutthisproposal,pleasecontactPaulHintz,PrincipalPlannerat(425)430-7436.Sincerely,MartinPastucha,PublicWorksAdministratorSEPAResponsibleOfficialCityofRenton1055SGradyWay.Renton,WA98057IIrentonwa.gov Rainier/Grady Junction TOD Subarea Planned Action Final Environmental Impact Statement March 2024 Prepared For: Consultant Team: BERK Consulting Perteet The Transpo Group Comments & Responses Commenters This section of the Final EIS summarizes the comments received on the Draft EIS from January 24 to February 28, 2024. Approximately nine written comments were received on the Draft EIS. In addition, comments were shared via a public hearing on February 21, 2024. Exhibit 0-1. Draft EIS Commenters Number Agency Last Name First Name Comment Date Government Agencies 1 Duwamish Tribe Sackman Nancy February 22, 2024 2 King County Wastewater Treatment Division (WTD) Satterwhite Zanna February 21, 2024 3 King County Metro Markwell Thi February 8, 2024 Business/ Non-profit 4 McCullough Hill PLLC, on behalf of Innovatus Capital McCullough John February 23, 2024 February 28, 2024 (supersedes February 23, 2024 comments) Individuals 5 Artze Andres February 21, 2024 6 Kelly Jeff January 26, 2024 7 Tamasan Ion January 30, 2024 8 LaFranchi Philip January 27, 2024 Rainier/Grady Junction TOD Subarea Planned Action DRAFT Ch. - ▪ Comments & Responses Correction Note: The Draft EIS cover letter and Notice of Availability indicated the end of the comment period as February 24, 2024 (providing a 31st day of the comment period), while the Fact Sheet identified the end of the comment period as February 23, 2024. Regardless, the City accepted comments for one week after the public hearing, effectively extending the comment period to February 28, 2024. Comments and Responses Below is a summary of comments and responses. Full copies of the comments are included in the Appendix. Responses provide clarifications about the Draft EIS analysis or alternatives. Where preferences are noted, the responses acknowledge them and note the comments are forwarded to City decision makers. Exhibit 0-2. Comments and Responses Number Comment Summary Response 1 The project location is culturally significant for the Duwamish Tribe consisting of three ancient village sites. The DAHP WISAARD map also shows several known archaeological sites within the vicinity. Recommends: An archaeological survey and monitoring with an IDP (inadvertent discovery plan) for the development within and around the Rainier/Grady Junction subarea, especially if any ground disturbance cuts below fill/asphalt/topsoil or other modern and/or impervious surfaces into native soil. Notification for any archaeological work or monitoring. Only native vegetation be used for any proposed landscaping and that wetland and stream buffers are maintained to enhance fish habitat, native avian life and native pollinators as well as to mitigate seasonal urban flooding. Supports Alternative 2 Permitting standards to be maintained for development in the Rainier/Grady subarea. Duwamish Tribe to be a part of the story and vision of the subarea. An area be laid out for the Duwamish where the village sites once were and have a space to practice the traditional lifeways. The Draft EIS identifies archaeological review and monitoring as a potential mitigation measure. See page 3-11 of the Draft EIS; also summarized in Chapter 1. The City can address that as a mitigation measure in the Planned Action Ordinance. The use of native plantings is another potential mitigation measure on page 3-10 of the Draft EIS; also summarized in Chapter 1. Street trees are chosen for appropriateness. In green space, City standards could emphasize native plants. The City can consider its current landscaping standards and potential adjustments in its proposed zoning and development standards for the Planned Action Area. The support of Alternative 2 is noted and forwarded to City decision makers. The City will continue to have notices of application for development in the Planned Action Area and such notices can identify if a planned action is proposed. Proposed requirements for long-term and short- term bike parking are intended to encourage non-motorized travel to enhance health of people and the environment in this higher density alternative. No adverse impacts are anticipated. Rainier/Grady Junction TOD Subarea Planned Action DRAFT Ch. - ▪ Comments & Responses Number Comment Summary Response “We would like to see water and fish flowing through the Black River again.” Concerns: Concern about long- and short-term bike parking requirements, width of the pedestrian clear zones. Many times Tribes are left out of the details and nuances of planning and design once a planned action is put in place. This urban planning strategy disregards changes that can occur from the time of adoption to actual groundbreaking construction. Thank you for your review of the Draft EIS. The Black River is located west of the study area. The Black River forest is largely in public ownership and contains protected wetlands. The cultural importance of the Black River is noted and forwarded to City decision makers. The comments regarding urban design are noted. The City is interested in positive placemaking. When public green spaces are designed, the City would have opportunities for engagement. 2 King County has multiple facilities and sewers in the EIS Study Area. In order to protect these wastewater facilities and sewers during construction, WTD requires that City of Renton submit construction drawings for proposed project identified as a result of the EIS that lie within 500-feet of the WTD facilities and sewers, so that WTD can assess its potential impacts. King County has permanent easements for facilities and sewers in the EIS study area, and must be assured the right to maintain and repair the facilities and sewers. The comment is noted. The notification of King County WTD can be included in the proposed Planned Action Ordinance. The notice is added as a mitigation measure and reflected in the Chapter 1 Summary under Utilities. 3 All construction and other work activity affecting King County Metro Transit Operations or Facilities must be coordinated through the KCM System Impacts workgroup. Please contact them to provide specific information related to the activity and allow the required lead time necessary for responding to any impacts caused by it. The comment is noted. The notification of King County Metro can be included in the proposed Planned Action Ordinance. The notice is added as a mitigation measure and reflected in the Chapter 1 Summary under Transportation. 4 Development plans for the Triton Tower site is well-aligned with the overall vision of the adopted Subarea Plan to encourage dense, mixed-use development with improved pedestrian and bike connections near the Transit Center. Policy objective of catalyzing desired changes through zoning incentives will be vitally important (see comments added below). The comment is noted and forwarded to City decision makers. Rainier/Grady Junction TOD Subarea Planned Action DRAFT Ch. - ▪ Comments & Responses Number Comment Summary Response 4.1 Flexibility and Incentives: Supports Alternative 2 to the extent that it studies the same amount of height and density but would provide for voluntary incentives for extra development capacity. EIS should remain as flexible as possible to allow for site-specific modifications during the entitlement process. Does not support mandatory inclusionary requirements such as for affordable housing or other public benefits because it will not result in more development, but rather the opposite. Voluntary incentives should be used in this location to achieve the City’s goal of catalyzing development. The Draft EIS and resulting development standards provided by the Planned Action Ordinance will be as flexible as possible; however, mitigation measures are necessary to lessen or avoid adverse impacts. While open space dedication beyond current Renton Municipal Code (RMC) requirements was identified as a public benefit to be derived as either an incentive for greater building height or density under Alternative 2 or as a requirement under Alternative 3, pedestrian connections such as “thru-block connections” identified in the Subarea Plan are necessary to create transit- oriented development (TOD) and will be required under either of the Action Alternatives. 4.2 Typologies: The Preferred Alternative should study mixed-use and a flexible range of height throughout the Subarea. On the Triton site, the Preferred Alternative should study height limits up to at least 85 feet, or seven stories to accommodate the most likely residential typology in this location: midrise, modular or five-over-two construction. Typologies indicated are too specific as to the number of floors and should not exclude seven- story buildings. The “typologies” identified in the Draft EIS were used to model a range of possible development for analysis of impacts, but these modeled typologies will not be used to limit use or building height on any of the parcels in the Planned Action Area to be the typology shown. A range of building heights were studied between single- story commercial uses to mixed-use buildings up to 150 feet tall. The proposed development standards would not require or limit land uses or building height to reflect what was modeled in the Draft EIS; the code would set the maximum height and density but allow those maximums to be exceeded in exchange for providing public benefits. Please refer to Draft EIS Exhibit 1-9, Alternative Features Compared, also shown in Final EIS Error! Reference source not found., for a summary of the proposed development standards for each alternative. 4.3 Height: Support the 70-150 foot height ranges reflected in Alternatives 2 and 3 in Exhibit 2-20. The studied building typologies should be revised to include these height ranges. See response to comment 4.2. 4.4 Uses: See response to comment 4.2. Rainier/Grady Junction TOD Subarea Planned Action DRAFT Ch. - ▪ Comments & Responses Number Comment Summary Response Residential uses should be allowed throughout. Limiting significant parts of the Subarea to commercial uses as shown in Alternatives 2 and 3 seems contrary to the City’s mixed-use vision. The entire Triton Towers site should be studied in the FEIS as mixed-use to allow for flexibility and without any minimum story height requirements. 4.5 Ground-floor commercial: At present, the cost of development of any required ground-floor commercial space in this location would be assigned to residential units for the purposes of underwriting due to current lack of demand for retail space. The FEIS and future zoning should reflect this reality by containing flexible ground-floor requirements. The FEIS should study some amount of commercial uses at the ground-level focused on street frontages on large sites but zoning should allow less than 40% ground floor commercial. The 20-foot ground-floor story height articulated in the Draft EIS (pg. 1-5) is not realistic or feasible. The Final EIS should assume 15-foot ground-floor story heights. While a substantial amount of housing is anticipated in the area, the area is zoned for commercial land uses and it is important for the City regulations to require commercial space be created for the sake of economic development, livability, and creating the vibrant mixed-use district envisioned by the Subarea Plan. Commercial uses are necessary for successful TOD to improve access to shopping, entertainment, and other daily needs while discouraging auto-dependence for residents. While the vision of the area as a vibrant mixed- use district will not be realized in the near-term, the cumulative effects of requiring development to provide ground floor commercial, public open spaces, mixed-income housing, and quality urban design, are needed to help make the vision a reality. The City’s current mixed-use development standards (e.g., 40% floor plate requirement, 20- foot tall podium height, etc.), applied to all commercial zones, were carefully considered before they were adopted in 2018 and were in response to commercial zones being developed with only a modicum of commercial space. The decision to base the amount of commercial space required on a percentage of the building footprint was chosen, in part, because it can be applied uniformly and it incentivizes smaller building footprints, which can result in buildings that allow more sunlight to penetrate public realms and more opportunities for pedestrian connections. Per RMC 4-4-150.F, modifications to the City’s mixed-use development standards are allowed on a case-by-case basis. 4.6 Air and Sound Quality: The Subarea Plan recommends several opportunities to mitigate for impacts to air and noise, including a buffer from I-405 for residential Rainier/Grady Junction TOD Subarea Planned Action DRAFT Ch. - ▪ Comments & Responses Number Comment Summary Response 500-foot “buffer” from I-405 to mitigate air and sound impacts to residential use - would create added costs to housing or even make housing development infeasible, undermining the purpose of the TOD. Air quality and sound issues should be addressed by the new state Building Code, and do not require any additional mitigation in the zoning code. No explanation on why buffer should be 500 ft. Supportive of landscaping within the Subarea to mitigate air and sound quality issues development, site and building design features, centralized air filtration systems, air intake vents located away from polluted areas, continuous sound walls with vegetation along I-405, and consideration of the California Environmental Protection Agency’s – Air Resources Board: Strategies to Reduce Air Pollution Exposure Near High Volume Roadways (April 2017, pages 20-39). The following excerpt from the DEIS is found on page 3-28. “Air Quality and Noise Compatibility: Pollution Sources The air and noise pollution sources most relevant to this study include aircraft at the Renton Municipal Airport and roadway traffic such as along I-405. Aircraft landing and take-off paths see concentrated air pollutants and noise impacts. Roadways see air pollution from vehicle exhaust and brake/tire/road wear. Pollutant particle size, topography, and wind patterns affect the geographic extent of concern, with the greatest impacts adjacent to and downwind of major freeways. Some patterns include: ▪ Pollutants are most concentrated within 500 ft of a roadway. Within that 500 feet, ultrafine particles “rapidly decay” to a 50% concentration (UW Mov-Up Report, 2019, p 38). ▪ Areas within 1,000 – 1,600 ft of a busy highway are most affected by a range of pollutants and particle sizes (American Lung Association). ▪ Close, long-term exposure (within 165 feet) to a heavily trafficked roadway has the strongest association with dementia (American Lung Association).” 4.7 Rolling Hills Creek: Daylighting Rolling Hills Creek as a mitigation measure – this is not justifiable since it is a pre- existing condition. Current zoning would impose a 75-ft buffer and additional 15 structure setback on the Triton Tower One site. This would reduce the size of proposed residential development on The Draft EIS suggests different options for daylighting of Rolling Hills Creek, with setbacks already required, and daylighting incentives a focus, or only a possible requirement if development is actually moving the creek. The following is from the DEIS and provides a summary of the intent for the Planned Action Ordinance. Rainier/Grady Junction TOD Subarea Planned Action DRAFT Ch. - ▪ Comments & Responses Number Comment Summary Response this site, which is also constrained by existing utilities easements. DEIS statement is incorrect that daylighting the creek would not result in reduced development potential if residential density transfer is allowed. The allowable density in this location is not a limiting factor and towers are not feasible in this location. The trade-off for daylighting a portion of a creek in this location near the highway would be to preclude a significant amount of housing development within the subarea for minimal benefit to the public. We ask the City to remove this recommendation from the Final EIS. Include off-site or nearby critical areas mitigation instead of requiring creek daylighting that would impose significant buffer constraints on the Property. Page 1-15 and 1-23: “The City currently restricts buildings over piped streams and easements to maintain the piping. Mitigation opportunities for daylighting Rolling Hills Creek include allowing transfer of residential density/floor area ratio so the daylighted stream and any natural buffer does not reduce the development potential when the stream is daylighted. The City could also require daylighting if development would relocate the creek, as well as incentivize daylighting where increased heights are allowed.” Page 1-41, 3-66, or 3-185: “A portion of Rolling Hills Creek is currently piped underneath development. It should be noted that daylighting the creek or portions of the creek would allow for an increased impervious surface lot coverage per RMC 4-3-050 section 7f-ii. This is a viable option to improve existing conditions as well as benefit the developer. The City code allows for, but does not specify, incentives for developers to daylight streams. The City should consider implementing specific incentives to encourage developers to daylight portions of Rolling Hills Creek to restore more natural habitat to the area.” 4.8 New Street Network: Generally supportive of increased connectivity within the Subarea but it should not have the end result of precluding housing production. Exact street locations should be determined as the Subarea develops based on site-specific conditions and proposals during project-level review. The Final EIS should assume that streets on private property may remain private, and street sections should also remain flexible and be reviewed by the City at project-level entitlements. The Subarea Plan established the concept of a new street network within Renton Village. The Subarea Plan identifies the general location of future streets as well as the features and dimensions of the streets, which were designed specifically for the area. While the exact locations of the proposed streets will be determined during the entitlement process, the need for a street network and streets designed for TOD is clearly demonstrated by the Subarea Plan and the Draft EIS. Similar to all newly created streets in the city, the exact specifications of new streets are provided by Renton Municipal Code (See RMC 4-4-060, Street Standards) which also provides the means for variations from the adopted standards on a case-by-case basis. 5 Concerned about the safety and speed of traffic moving along Grady Way. Future improvements to the road to include traffic-calming devices such Speeds were not specifically included in this study but are not anticipated to increase on Grady Way due to development with intersection Rainier/Grady Junction TOD Subarea Planned Action DRAFT Ch. - ▪ Comments & Responses Number Comment Summary Response as chicanes and speed cushions to discourage speeding. Paths leading to Benson Rd S is missing. That should be a priority to keep many of the existing local businesses in the area (such as Uwajimaya) supported throughout the construction process. delays remaining close to the No Action alternative. Slowing vehicle speeds would induce additional delays for vehicular traffic on this arterial roadway that is also a truck route. Although chicanes and speed cushions are not appropriate traffic calming treatments for high- volume roadways, several other safety measures are proposed. These include updating the roadway section along Grady Way to provide wider roadway-separated non-motorized facilities, as well as performing a study to determine implementation options to enhance safety for crossing Grady Way. The Subarea Plan provides direction for future improvements of pedestrian and bicycle connections leading to Benson Rd S, which will help inform future Capital Improvement Projects. Additionally, the newly developed streets in Renton Village will provide complete streets with buffered bicycle lanes. 6 Questions and comments related to height, road network, parking, mixed-use, zoning, mitigation and utilities such as: 5 to 10 stories for Alternative 2, and 10 – 14 stories for alternative 3 Road network, loop road, car-unfriendly Main Street No separation of commercial and mixed use Location of light rail along Shattuck Ave Include pedestrian crossings and roundabouts Question about Home Depot and the City Hall being excluded. 500 ft buffer for all uses. Specific suggestions about zoning on pages 26 and 27. Mitigation – green space buffer no benefit to building tenants nor pedestrians; temperature impact is missing; charge high for parking and provide bus-only lanes Utilities - Is this how we want to use 50% of our remaining tap-water capacity as a city? The Home Depot site had a major construction already in the permit pipeline. City Hall, as a public site, is not under consideration for changes in use or growth. Therefore, those properties were excluded from the Planned Action. However, the broader study area accounts for cumulative conditions and growth such as pipeline development or growth under current zoning. Other suggestions for zoning, mitigation, and infrastructure are noted and forwarded to City decision makers. Rainier/Grady Junction TOD Subarea Planned Action DRAFT Ch. - ▪ Comments & Responses Number Comment Summary Response 7 Fully supports and prefer Alternative 3 over the other options. Need for more housing, more jobs, more foot traffic activity. Build a walkable neighborhood with restaurants/bars/entertainment. Alternative 3 will produce more revenue for the city that can be allocated into more similar projects and accumulate revenue like a snowball effect and make Renton an economic powerhouse/popular place. The comment is noted and forwarded to City decision makers. Both action alternatives are expected to create a walkable community. 8 Supports added density in this underutilized area of Renton. if Renton wants to follow the lead of upzoning (see Vancouver suburbs and Bellevue) then there is a real opportunity to create tall slender residential buildings to allow more light at ground level. No boxy-bulky buildings. 14 stories is a good start, but can go up to 20-25 floors. As much residential near transit as possible. The comment is noted and forwarded to City decision makers. Development regulations will ensure good massing and building design. Proposed building heights are consistent with the market.