HomeMy WebLinkAboutERC_RRFA_Fire_Station_FINALDEPARTMENT OF COMMUNITY
AND ECONOMIC DEVELOPMENT
ERC_RRFA_Fire Station_FINAL
ENVIRONMENTAL REVIEW COMMITTEE REPORT
ERC Meeting Date: January 27, 2025
Project File Number: PR24-000084
Project Name: Renton Regional Fire Authority New Fire Station 16 and Maintenance Building
Land Use File Number: LUA24-000373, SA-H, CU-H, ECF, MOD
Project Manager: Jill Ding, Senior Planner
Owner: Renton Regional Fire Authority, 18002 108th Ave SE, Renton, WA 98055
Applicant/Contact: Brian Harris, TCA Architecture Planning, 6211 Roosevelt Way NE, Seattle, WA
98115
Project Location: 15815 SE 128th St, Renton, WA 98059 (APNs 3664500007, 3664500008,
3664500009, and 3664500330)
Project Summary: The applicant is requesting a Hearing Examiner Conditional Use Permit,
Hearing Examiner Site Plan Review, Environmental (SEPA) Review, and a Street
Standards Modification for the construction of a new fire station and
maintenance building. The project site totals 151,721 sq. ft. (3.48 acres) and is
located within the Residential-4 (R-4) dwelling unit per acre zone. A Lot
Combination (LUA24-000371) is being processed under a separate application
to combine all parcels into one lot and a Street Vacation request has been
submitted to vacate the existing onsite alley. The proposed fire station would
consist of three (3) drive-thru apparatus bays, living/administrative and
apparatus bay support spaces. The fire station would have a total area of
14,314 sq. ft. The proposed maintenance building would consist of five (5)
back-in maintenance bays with maintenance staff area and support spaces
required to service apparatuses. The maintenance building would have a total
building area of 13,282 sq. ft. The proposed fire station would have a maximum
height of approximately 25 feet (25’) and the maintenance building would have
a maximum height of approximately 38 feet (38’). Access to the site is proposed
via two (2) curb cuts off NE 128th St and one (1) curb cut off 158th Ave SE.
Approximately 20 surface parking stalls are proposed on the project site. A
Street Standards Modification is requested to allow the frontage improvements
along SE 128th St to comply with the corridor improvement plan for NE 4th St.
According to COR Maps, no critical areas are mapped on the project site.
Exist. Bldg. Area SF: N/A Proposed New Bldg. Area
(footprint):
Proposed New Bldg. Area (gross):
22,910 sq. ft.
27,596 sq. ft.
Site Area: 151,721 sq. ft.
(3.48 acres)
Total Building Area GSF: 27,596 sq. ft.
STAFF
RECOMMENDATION:
Staff Recommends that the Environmental Review Committee issue a
Determination of Non-Significance - Mitigated (DNS-M).
Docusign Envelope ID: 9C8AD163-664C-4B8F-8817-4315F1866DB3
City of Renton Department of Community & Economic Development
Renton Regional Fire Authority New Fire Station 16 and Maintenance
Building
Staff Report to the Environmental Review Committee
LUA24-000373, SA-H, CU-H, ECF, MOD
Report of January 27, 2025 Page 2 of 8
ERC_RRFA_Fire Station_FINAL
Project Location Map
ENVIRONMENTAL REVIEW
In compliance with RCW 43.21C.240, the following environmental (SEPA) review addresses only those project
impacts that are not adequately addressed under existing development standards and environmental
regulations.
A. Environmental Threshold Recommendation
Based on analysis of probable impacts from the proposal, staff recommends that the Responsible
Officials:
Issue a DNS-M with a 14-day appeal period
B. Mitigation Measures
1. Construction on the project site shall comply with the recommendations of the submitted
Geotechnical Report, prepared by GeoEngineers, Inc., dated August 5, 2022, and any future
addenda.
2. The applicant’s geotechnical engineer shall submit a sealed letter stating that he/she has
reviewed the civil construction and building permit plans and in their opinion the plans and
specifications meet the intent of the report(s).
3. The applicant’s geotechnical engineer shall provide notes on the construction and building permit
plans identifying when on-site geotechnical engineer supervision of construction events is
recommended.
4. The applicant shall submit an Inadvertent Discoveries Plan prepared by a qualified professional
with the civil construction permit for review and approval by the Current Planning Project Manager
prior to permit issuance.
Docusign Envelope ID: 9C8AD163-664C-4B8F-8817-4315F1866DB3
City of Renton Department of Community & Economic Development
Renton Regional Fire Authority New Fire Station 16 and Maintenance
Building
Staff Report to the Environmental Review Committee
LUA24-000373, SA-H, CU-H, ECF, MOD
Report of January 27, 2025 Page 3 of 8
ERC_RRFA_Fire Station_FINAL
EXHIBITS
Exhibit 1: Environmental Review Committee (ERC) Report
Exhibit 2: Conceptual Plan Set
Exhibit 3: Geotechnical Report, prepared by GeoEngineers, Inc., dated August 5, 2022
Exhibit 4: Technical Memorandum, prepared by Soundview Consultants, LLC, dated
September 1, 2022
Exhibit 5: Technical Information Report (TIR), prepared by LPD Engineering, PLLC, dated
November 12, 2024
Exhibit 6: Traffic Impact Analysis (TIA), prepared by Transpo Group, dated August 2024
Exhibit 7: U.S. Army Corps of Engineers Comments, dated December 26, 2024
Exhibit 8: U.S. Army Corps of Engineers City Response, dated January 15, 2025
Exhibit 9: Duwamish Tribe Comment Letter, dated December 23, 2024
Exhibit 10: Duwamish Tribe City Response, dated January 15, 2025
Exhibit 11: Transportation Concurrency Test Memorandum, dated December 12, 2024
Exhibit 12: SEPA Checklist
Exhibit 13: Advisory Notes
C. Environmental Impacts
The Proposal was circulated and reviewed by various City Departments and Divisions to determine
whether the applicant has adequately identified and addressed environmental impacts anticipated to
occur in conjunction with the proposed development. Staff reviewers have identified that the proposal is
likely to have the following probable impacts:
1. Earth
Impacts: The applicant submitted a Geotechnical Report, prepared by GeoEngineers, Inc., dated
August 5, 2022 (Exhibit 3) with the project application materials. Total earthwork proposed for the
project construction would include approximately 21,200 cubic yards of cut and 9,500 cubic
yards of fill. Subsurface conditions were evaluated by drilling ten (10) hollow-stem auger borings
to depths ranging from about ten and one-half feet (10 ½’) to fifty and one-half feet (50 ½’) below
the existing ground surface (bgs). The subsurface conditions at the site generally consist of
crushed gravel surfacing and fill overlying weathered glacial till and glacial till soils. Crushed
gravel was encountered in all of the explorations that occurred within the existing gravel driveway.
The existing gravel driveway generally consists of approximately six inches (6”) of crushed rock
mixed with underlying soft/loose fill soils. Fill was encountered in all of the explorations with the
exception of Boring 7. The fill generally consists of soft/loose to medium dense sandy silt/silty
sand with variable organic and gravel content. The fill, where encountered, was observed to be
approximately two feet (2’) to seven and one-half (7 ½’) feet thick. Weathered glacial till was
encountered in all of the explorations. The weathered glacial till generally consists of medium
dense to dense silty sand with variable content and extends to a depth of about four feet (4’) to
nine feet (9’) bgs. Very dense unweathered glacial till was encountered in all of the explorations
below the weathered soils. The unweathered glacial till generally consists of very dense silty sand
with variable gravel content, beginning at a depth ranging from about five feet (5’) to ten feet (10’)
bgs and extending to the depths explored (up to fifty and one-half feet [50 ½’] bgs).
Docusign Envelope ID: 9C8AD163-664C-4B8F-8817-4315F1866DB3
City of Renton Department of Community & Economic Development
Renton Regional Fire Authority New Fire Station 16 and Maintenance
Building
Staff Report to the Environmental Review Committee
LUA24-000373, SA-H, CU-H, ECF, MOD
Report of January 27, 2025 Page 4 of 8
ERC_RRFA_Fire Station_FINAL
Ground water was observed in the deepest boring (GEI-9) at approximately ten feet (10’) below
the existing ground surface. Seasonally perched groundwater is anticipated at the site above the
relatively impermeable dense to very dense glacial soils.
The geotechnical report included recommendations for building and site construction including
recommendations for foundations, slab-on-grade floors, retaining walls, earthwork, structural
fill, utility trenches, drainage considerations, and new pavement design. Staff recommends, as
SEPA mitigation, that construction on the project site comply with the recommendations of the
submitted Geotechnical Report, prepared by GeoEngineers, Inc., dated August 5, 2022. In
addition, staff recommends, as a condition of approval, that the applicant’s geotechnical
engineer shall submit a sealed letter stating that he/she has reviewed the civil construction and
building permit plans and in their opinion the plans and specifications meet the intent of the
report(s). Lastly, staff recommends, as a mitigation measure, that the applicant’s geotechnical
engineer provide notes on the construction and building permit plans identifying when on-site
geotechnical engineer supervision of construction events is recommended.
Mitigation Measures:
1. Construction on the project site shall comply with the recommendations of the submitted
Geotechnical Report, prepared by GeoEngineers, Inc., dated August 5, 2022, and any future
addenda.
2. The applicant’s geotechnical engineer shall submit a sealed letter stating that he/she has
reviewed the civil construction and building permit plans and in their opinion the plans and
specifications meet the intent of the report(s).
3. The applicant’s geotechnical engineer shall provide notes on the construction and building
permit plans identifying when on-site geotechnical engineer supervision of construction
events is recommended.
Nexus: State Environmental Policy Act (SEPA) Environmental Review; and RMC 4-4-060 Grading,
Excavation, and Mining Regulations.
2. Air
Impacts: It is anticipated that some temporary air quality impacts could be associated with site
work and building construction required to develop this site. Project development impacts during
construction would include primarily particulate matter and small amounts of carbon monoxide
and oxides of nitrogen, resulting from grading and exhaust from construction vehicles. Dust
control would be mitigated using temporary erosion control measures. A Temporary Erosion and
Sedimentation Control (TESC) plan and system would be developed and submitted to the city in
accordance with the city’s development regulations and with the Department of Ecology (DOE)
Construction Stormwater Pollution Prevention Plan (SWPPP). Proposed measures to reduce or
control emissions and other impacts to air quality during construction would include the
following, as appropriate: a) cover loads, wet down and/or ensure adequate free board on trucks
during transport of fill material and topsoil; b) clean up spills of transported material on public
roads promptly by frequent use of a street sweeper machine; c) cover loads of hot asphalt to
minimize odors; d) schedule work tasks to minimize disruption of existing vehicle traffic on streets
in the vicinity of the proposed project; and e) maintain all construction machinery engines in good
mechanical condition to minimize exhaust emissions.
Following construction, vehicle emissions in the form of carbon monoxide and oxides of nitrogen
associated with the day-to-day operation of the fire station are anticipated to be very low. No
further site-specific mitigation for the identified impacts from typical vehicle and construction
exhaust is required.
Docusign Envelope ID: 9C8AD163-664C-4B8F-8817-4315F1866DB3
City of Renton Department of Community & Economic Development
Renton Regional Fire Authority New Fire Station 16 and Maintenance
Building
Staff Report to the Environmental Review Committee
LUA24-000373, SA-H, CU-H, ECF, MOD
Report of January 27, 2025 Page 5 of 8
ERC_RRFA_Fire Station_FINAL
Mitigation Measures: No further mitigation recommended.
Nexus: Not applicable.
3. Water
a. Wetland, Streams, Lakes
Impacts: There are no wetlands, streams, or lakes mapped on or around the project site,
according to the City of Renton (COR) Mapping system. In addition, the applicant provided a
Technical Memorandum prepared by Soundview Consultants, LLC, dated September 1, 2022
(Exhibit 4). The Technical Memorandum concluded that there are no wetlands on the project
site. During the 14-day public comment period, comments were received from the U.S. Army
Corps of Engineers stating that it seems there could be impacts to aquatic features and that
a Corps permit may be needed (Exhibit 8). Those comments were provided to the applicant
for future coordination with the Corps. No further mitigation is recommended.
Mitigation Measures: No further mitigation recommended.
Nexus: Not applicable.
b. Storm Water
Impacts: The applicant submitted a Technical Information Report (TIR), prepared by LPD
Engineering, PLLC, dated November 12, 2024 (Exhibit 5) with the application. According to the
submitted TIR, topographically, the site slopes down from the southwest to the northeast. The
project site has two (2) threshold discharge areas that discharge to separate drainage basins.
Threshold Discharge Area 1 (TDA 1) includes the majority of the stormwater from the site and
flows northeasterly to discharge into the May Creek drainage basin. Threshold Discharge Area
2 (TDA 2) includes a small area on the southwestern most parcel and flows southerly, and
discharges into the Lower Cedar River drainage basin.
The proposed project improvements would include a fire station building and maintenance
building with a central driveway connecting access to both buildings, 158th Ave SE to the west,
and SE 128th St to the north. There would be three (3) parking areas, one (1) located in the
northeast corner of the site with three (3) stalls, one (1) located south of the fire station
building with 12 stalls, and one (1) located to the south of the maintenance building with five
(5) stalls. The project proposes 82,759 sq. ft. (1.90 acres) total of new plus replaced
impervious surface.
TDA 1 is comprised of 4.24 acres located within the project site and adjacent right-of-way
along SE 128th St, with 80,924 sq. ft. (1.86 acres) of new plus replaced impervious surface.
Stormwater runoff from TDA 1 would be collected in a series of catch basins and trench drains
and routed via pipe conveyance systems to one (1) of two (2) detention facilities, an SC-740
StormTech Chamber system located in the north portion of the site and a detention vault
located in the eastern area of the site. Pollution generating surfaces would be routed to a
Modular Wetland System for water quality treatment prior to entering the detention facilities.
The detained and treated discharge will discharge to the existing ditch near the northeast
corner of the site at SE 128th St.
There is no proposed stormwater detention system for TDA 2. The TIR argues that flow control
for TDA 2 is not required since the proposed improvements in TDA 2 result in less than 5,000
sq. ft. of new plus replaced impervious surface and less than ¾ acres of new pervious surface
will be added. However, the Basic Exemption’s 5,000 sq. ft. threshold is crossed at the project
level. TDA 2 may still qualify for a flow control exemption if the applicant can demonstrate that
Docusign Envelope ID: 9C8AD163-664C-4B8F-8817-4315F1866DB3
City of Renton Department of Community & Economic Development
Renton Regional Fire Authority New Fire Station 16 and Maintenance
Building
Staff Report to the Environmental Review Committee
LUA24-000373, SA-H, CU-H, ECF, MOD
Report of January 27, 2025 Page 6 of 8
ERC_RRFA_Fire Station_FINAL
there is no more than a 0.15-cfs difference in the sum of developed 100‐year peak flows and
the sum of historical (forested) site conditions 100‐year peak flows.
The project proposal would be required to comply with the 2022 City of Renton Surface Water
Design Manual (RSWDM). It is anticipated that any impacts to surface water flows would be
adequately mitigated through the RSWDM, therefore no further mitigation is recommended.
Mitigation Measures: No further mitigation recommended.
Nexus: Not applicable.
4. Environmental Health
a. Noise
Impacts: During project construction, noise levels would temporarily increase near the
construction activity due to heavy equipment use and construction materials transport.
Sound levels generated during construction would vary based on the construction phase and
equipment used. Generally, at a distance of 50 feet (50’), sound levels for various types of
construction equipment or vehicles typically vary from 76 decibels (dBA) to 89 dBA.
Construction activity is proposed on weekdays between the hours of seven o’clock (7:00) a.m.
and eight o’clock (8:00) p.m. No night work is proposed.
Ongoing noise impacts from the maintenance and operation of the fire station would be
anticipated. Safety sirens (115 dBA) from the fire trucks and other safety vehicles would be
short and infrequent and would also be a source of noise during operation of the fire station
facility. However, safety sirens are exempt from the noise ordinance. Regular traffic and
operational noise is also anticipated from incoming/departing fire apparatuses, medic, and
firefighter vehicles including operation of apparatus bay doors.
Construction related noise complaints (if any) would be discussed during weekly
construction meetings and addressed as necessary if it becomes an issue. To mitigate noise
impacts from returning and visiting apparatuses, the proposed fire station has been setback
from neighboring residences. The fire station includes an approximately fifteen-foot (15’)
setback from the abutting residential property line to the west and the maintenance building
includes an approximately eighteen-foot (18’) setback from the abutting west property line. In
addition, landscaping is proposed around the site perimeter. Proposed landscaping would
include a mix of trees, shrubs, and ground cover. It is anticipated that proposed landscaping
would aid as a noise buffer. The proposed on-site standby generator would be placed within
a sound attenuating enclosure. It is anticipated that any temporary or permanent noise
impacts would be adequately mitigated through the city’s adopted Noise Regulations as well
as through the additional landscaped setbacks buffering the fire station from the neighboring
residences, and thus, no further mitigation is recommended.
Mitigation Measures: No further mitigation recommended.
Nexus: Not applicable.
5. Aesthetics
Impacts: The proposed fire station would be located within the R-4 zone and would be
surrounded primarily by single family residences and an existing church. The proposed fire station
would have a maximum height of approximately twenty-five feet, eleven and a quarter inches (25’
11 ¼”). The proposed maintenance building would have a maximum height of approximately
thirty-seven feet, ten inches (37’ 10”). The proposed fire station would comply with the height
requirements of the R-4 zone. The proposed maintenance building would exceed the standard
maximum height permitted in the R-4 zone, therefore, Site Plan Review has been requested as the
Docusign Envelope ID: 9C8AD163-664C-4B8F-8817-4315F1866DB3
City of Renton Department of Community & Economic Development
Renton Regional Fire Authority New Fire Station 16 and Maintenance
Building
Staff Report to the Environmental Review Committee
LUA24-000373, SA-H, CU-H, ECF, MOD
Report of January 27, 2025 Page 7 of 8
ERC_RRFA_Fire Station_FINAL
proposal is a public building. The maximum height requirements for public buildings within the R-
4 zone are established through Site Plan Review. It is not anticipated that the proposed buildings
would adversely impact views within the project vicinity, therefore no further mitigation is
recommended.
Mitigation Measures: No further mitigation recommended.
Nexus: Not applicable.
6. Light and Glare
Impacts: Sources of light and glare associated with the project proposal include new overhead
site lighting and vehicle lights. Glare from fire trucks and other safety vehicles would be more
prevalent at dawn and dusk during the winter months when primary commute periods extend
beyond daylight hours. Onsite lighting would be provided for safety, security, and wayfinding.
The following measures would be incorporated into the project design to reduce or control light
and glare impacts: lighting types will be carefully planned to reduce potential spill of light off the
project site; maximum height of on-site lighting is expected to be approximately 25 feet (25’)
above lowest grade at building; plant materials for landscaping and buffer plantings would be
considered and located to effectively reduce light and glare from vehicles maneuvering on the
site; and use of sharp cutoff fixtures and the strategic locating of fixtures such that lighting would
not extend beyond site boundaries. It is anticipated that light or glare impacts from the project
site would be adequately mitigated through the implementation of the city’s Lighting Regulations,
therefore no further mitigation is recommended.
Mitigation Measures: No further mitigation recommended.
Nexus: Not applicable.
7. Historic and Cultural Preservation
Impacts: No archeological studies were submitted with the project application materials. Staff
did receive comments from the Duwamish Tribe (Exhibit 9) requesting that an Inadvertent
Discovery Plan (IDP) be prepared prior to proposed construction activities due to the potential for
archeological resources being discovered on the project site. To ensure that any archeological
deposits are managed appropriately, staff recommends, as a SEPA mitigation measure, that the
applicant submit an Inadvertent Discoveries Plan prepared by a qualified professional with the
civil construction permit for review and approval by the Current Planning Project Manager prior to
permit issuance. The applicant shall provide notification to Tribes’ cultural committee prior to the
start of construction.
Mitigation Measures: The applicant shall submit an Inadvertent Discoveries Plan (IDP) prepared
by a qualified professional with the civil construction permit for review and approval by the
Current Planning Project Manager prior to permit issuance. The applicant shall provide
notification to Tribes’ cultural committee prior to the start of construction.
Nexus: City of Renton Comprehensive Plan Goals and Policies LU-AA, LU-44, and LU-45; Chapter
27.53 RCW, Archaeological Sites and Resources; Chapter 27.44 RCW, Indian Graves and
Records; Chapter 197-11 WAC, SEPA Rules.
8. Transportation
Impacts: A Traffic Impact Analysis (TIA), prepared by Transpo Group, dated August 2024 (Exhibit
6) was submitted with the project application materials. The TIA concluded that the proposed
project would result in eight (8) net new AM and two (2) net new PM peak hour trips for the
relocated fire station and seven (7) net new AM
and seven (7) net new PM trip hour for the maintenance facility.
Docusign Envelope ID: 9C8AD163-664C-4B8F-8817-4315F1866DB3
City of Renton Department of Community & Economic Development
Renton Regional Fire Authority New Fire Station 16 and Maintenance
Building
Staff Report to the Environmental Review Committee
LUA24-000373, SA-H, CU-H, ECF, MOD
Report of January 27, 2025 Page 8 of 8
ERC_RRFA_Fire Station_FINAL
Proposed public access and apparatus response access is proposed off SE 128th St via two (2)
separate curb cuts. Maintenance building access, firefighter crew access, and apparatus return
would occur off 158th Ave SE via one (1) curb cut. Project construction is anticipated to begin in
spring of 2025 and end in fall of 2026. Construction activity is proposed on weekdays between the
hours of seven o’clock (7:00) a.m. and eight o’clock (8:00) p.m.
A Transportation Concurrency Test (Exhibit 11) was issued for the proposal. It was concluded that
the proposal passed the transportation concurrency test in accordance with RMC 4-6-070D. It is
anticipated that any new trips generated by the proposal would be adequately mitigated through
the payment of a Traffic Impact Fee. Therefore, no further mitigation is recommended.
Mitigation Measures: No further mitigation recommended.
Nexus: Not applicable.
D. Comments of Reviewing Departments
The proposal has been circulated to City Department and Division Reviewers. Where applicable, their
comments have been incorporated into the text of this report and/or “Advisory Notes to Applicant”.
✓ Copies of all Review Comments are contained in the Official File and may be attached to this
report.
The Environmental Determination decision will become final if the decision is not appealed within the
14-day appeal period (RCW 43.21.C.075(3); WAC 197-11-680).
Environmental Determination Appeal Process: Appeals of the environmental determination must be
filed in writing on or before 5:00 p.m. on February 10, 2025. Appeals must be submitted electronically to
the City Clerk at cityclerk@rentonwa.gov or delivered to City Hall 1st floor Lobby Hub Monday through Friday.
The appeal fee, normally due at the time an appeal is submitted, will be collected at a future date if your
appeal is submitted electronically. The appeal submitted in person may be paid on the first floor in our
Finance Department. Appeals to the Hearing Examiner are governed by RMC 4-8-110 and additional
information regarding the appeal process may be obtained from the City Clerk’s Office,
cityclerk@rentonwa.gov.
Docusign Envelope ID: 9C8AD163-664C-4B8F-8817-4315F1866DB3
CITY OF RENTON
DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT
STAFF REPORT TO THE ENVIRONMENTAL REVIEW COMMITTEE
EXHIBITS
Project Name:
Renton Regional Fire Authority New Fire
Station 16 and Maintenance Building
Land Use File Number:
LUA24-000373, SA-H, CU-H, ECF, MOD
Date of Meeting
January 27, 2025
Staff Contact
Jill Ding
Senior Planner
Project Contact/Applicant
Brian Harris
TCA Architecture Planning
6211 Roosevelt Way NE,
Seattle, WA 98115
Project Location
15815 SE 128th St, Renton, WA
98059 (APNs 3664500007,
3664500008, 3664500009, and
3664500330)
The following exhibits are included with the ERC Report:
Exhibit 1: Environmental Review Committee (ERC) Report
Exhibit 2: Conceptual Plan Set
Exhibit 3: Geotechnical Report, prepared by GeoEngineers, Inc., dated August 5, 2022
Exhibit 4: Technical Memorandum, prepared by Soundview Consultants, LLC, dated September 1,
2022
Exhibit 5: Technical Information Report (TIR), prepared by LPD Engineering, PLLC, dated November
12, 2024
Exhibit 6: Traffic Impact Analysis (TIA), prepared by Transpo Group, dated August 2024
Exhibit 7: U.S. Army Corps of Engineers Comments, dated December 26, 2024
Exhibit 8: U.S. Army Corps of Engineers City Response, dated January 15, 2025
Exhibit 9: Duwamish Tribe Comment Letter, dated December 23, 2024
Exhibit 10: Duwamish Tribe City Response, dated January 15, 2025
Exhibit 11: Transportation Concurrency Test Memorandum, dated December 12, 2024
Exhibit 12: SEPA Checklist
Exhibit 13: Advisory Notes
Docusign Envelope ID: 9C8AD163-664C-4B8F-8817-4315F1866DB3