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HomeMy WebLinkAboutSR_ERC_Report_LUA24-000367_CUP_and_Variance_250428_FinalDEPARTMENT OF COMMUNITY
AND ECONOMIC DEVELOPMENT
Project Location Map
SR_ERC_Report_LUA24-000367_CUP and Variance_250428_Final
ENVIRONMENTAL REVIEW COMMITTEE REPORT
ERC Meeting Date: May 5, 2025
Project File Number: PR24-000074
Bull Conditional Use Permit and Critical Areas Variance for Accessory
Dwelling Unit Development
Land Use File Number: LUA24-000367, ECF, CU-A, V-A
Project Manager: Nichole Perry, Associate Planner
Owner/Applicant/Contact: Leah and Tristan Bull, 5424 NE 10th St, Renton, WA 98059
Project Location: 5424 NE 10th St, Renton, WA 98059 (APN 1023059365)
Project Summary: The applicant is requesting Environmental (SEPA) Review, a Conditional
Use Permit (CUP), and a Reasonable Use Variance to construct a 968
square foot detached Accessory Dwelling Unit (ADU) over a garage at 5424
NE 10th St, Renton, WA 98059 (APN 1023059365). The 1.26-acre parcel is
located in the Residential-4 (R-4) zoning district and is designated
Residential Low Density (RLD) in the Comprehensive Plan. The site
currently contains an existing single-family dwelling unit. According to City
of Renton (COR) Maps, the site includes high erosion hazards, regulated
slopes (>15% & <=40%), a Category II Wetland, and a Type F stream (Honey
Creek) that flows through the western portion of the site. The applicant
submitted a Geotechnical Engineering Investigation, Wetland and Stream
Delineation Report, and Standard Stream Study with the application.
Exist. Bldg. Area SF: Single Family
Residence
Proposed New Bldg. Area
(footprint):
Proposed New Bldg. Area
(gross):
968 sq. ft.
968 sq. ft.
Site Area: 1.26 acres Total Building Area GSF: 4,208 sq. ft.
STAFF
RECOMMENDATION:
Staff Recommends that the Environmental Review Committee issue a
Determination of Non-Significance with Mitigation DNS-M.
Docusign Envelope ID: CF4F89F1-1EB5-4C12-B6C9-56F8F437FF55
City of Renton Department of Community & Economic Development
Bull Conditional Use Permit and Critical Areas Variance for Accessory
Dwelling Unit Development
Staff Report to the Environmental Review Committee
LUA 24-000367, ECF, CU-A, V-A
Report on May 5, 2025 Page 2 of 6
SR_ERC_Report_LUA24-000367_CUP and Variance_250428_Final
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. The applicant shall comply with the recommendations outlined in the Geotechnical Evaluation
Report, prepared by GEO Group Northwest, Inc., dated July 27, 2022 (Exhibit 5), as well as any
future addenda.
2. The applicant shall prepare and submit an Inadvertent Discovery Plan (IDP) prior to the start of
any ground-disturbing activities. In addition, the applicant shall provide notification to Tribes’
cultural committee prior to the start of construction per the Duwamish Tribe Comments.
C. Exhibits
Exhibit 1: Environmental Review Committee (ERC) Report
Exhibit 2: Site Plans, Pacific Home Source LLC, dated September 4, 2024
Exhibit 3: Boundary and Topographic Survey, prepared by Plog Engineering Surveyors and
Civil Engineers, dated February 21, 2024
Exhibit 4: Tree Retention and Credit Worksheet, received October 8, 2024
Exhibit 5: Geotechnical Engineering Investigation, prepared by GEO Group Northwest, Inc.,
dated July 27, 2022
Exhibit 6: Wetland and Stream Delineation Report, prepared by DCG/Watershed, dated
November 21, 2023
Exhibit 7: Standard Stream Study, prepared by Cascade Ecology LLC, dated February 3, 2023
Exhibit 8: Project Narrative, dated September 19, 2024
Exhibit 9: Conditional Use Permit and Variance Justification, dated October 7, 2024
Exhibit 10: SEPA Environmental Checklist, prepared by Tristan Bull, dated April 8, 2025
Exhibit 11: Duwamish Tribe Comments Comment Letter, prepared by Duwamish Tribal
Historic Preservation, dated April 9, 2025
Exhibit 12: Staff Response Email to the Duwamish Tribe’s Comment Letter, dated April 9, 2025
Exhibit 13: King County Wastewater Treatment Division Comments, dated April 17, 2025
Exhibit 14: Staff Response Email to the King County Wastewater Treatment Division, dated
April 17, 2025
Docusign Envelope ID: CF4F89F1-1EB5-4C12-B6C9-56F8F437FF55
City of Renton Department of Community & Economic Development
Bull Conditional Use Permit and Critical Areas Variance for Accessory
Dwelling Unit Development
Staff Report to the Environmental Review Committee
LUA 24-000367, ECF, CU-A, V-A
Report on May 5, 2025 Page 3 of 6
SR_ERC_Report_LUA24-000367_CUP and Variance_250428_Final
Exhibit 15: Advisory Notes
D. 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 1.26-acre parcel located at 5424 NE 10th St is currently developed with an existing
single-family residence. The applicant is proposing to construct a 968 square-foot detached
Accessory Dwelling Unit (ADU) over a garage within a mapped wetland buffer area (Exhibit 2).
According to the Geotechnical Engineering Investigation, prepared by GEO Group Northwest,
Inc., dated July 27, 2022 (Exhibit 5), the site is underlain by a small peat deposit (Qlp) overlaying
glacial till (Qgt). The peat layer, which varies in thickness from approximately three feet (3’) to 23
feet (23’), is noted to be very soft and may exhibit lateral flow when under load. This material is
compressible and has a low shear strength, which poses challenges for conventional foundation
support. The underlying glacial till is dense and more suitable for structural support but lies
beneath the soft organic soils.
Subsurface exploration consisted of one (1) boring (BH-1). The soils encountered were loose to a
depth of 15 feet (15’) where they became dense throughout the rest of the 25-foot (25’) boring. The
borehole revealed saturated conditions and a relatively high groundwater table, approximately
seven and one-half feet (7.5’) below ground surface, in proximity to a north-south oriented creek
located near the proposed structure. These site conditions suggest a potential for settlement,
especially if construction occurs directly over the peat layer without adequate mitigation
measures. Lateral spreading may also be a concern if significant loads are imposed without
specialized engineering solutions.
The report includes comprehensive recommendations for foundations, grading and earthwork,
and slab-on-grade floors. The geotechnical report recommends the use of deep foundation
systems or other engineered structural supports (e.g., 2-inch [2”] to 4-inch [4”] diameter
galvanized pipe piles) to transfer building loads through the peat and into the more competent
glacial till below. Site grading and earthwork activities will need to be carefully managed to avoid
differential settlement and to maintain slope stability along the adjacent creek corridor. Erosion
control measures will also be necessary during construction to prevent sediment transport into
the nearby wetland buffer and associated critical areas. As such, staff recommends as a
mitigation measure, that the applicant comply with the recommendations found in the submitted
Geotechnical Engineering Investigation, prepared by GEO Group Northwest, Inc., dated July 27,
2022, and any future addenda.
The Boundary and Topographic Survey, prepared by Plog Engineering Surveyors and Civil
Engineers, dated February 21, 2024 (Exhibit 3) indicates that there is a deciduous tree, multi-trunk
deciduous trees and a conifer tree near the proposed site.
Mitigation Measures: The applicant shall comply with the recommendations outlined in the
Geotechnical Engineering Investigation, prepared by GEO Group Northwest, Inc., dated July 27,
2022 (Exhibit 5), and any future addenda.
Docusign Envelope ID: CF4F89F1-1EB5-4C12-B6C9-56F8F437FF55
City of Renton Department of Community & Economic Development
Bull Conditional Use Permit and Critical Areas Variance for Accessory
Dwelling Unit Development
Staff Report to the Environmental Review Committee
LUA 24-000367, ECF, CU-A, V-A
Report on May 5, 2025 Page 4 of 6
SR_ERC_Report_LUA24-000367_CUP and Variance_250428_Final
Nexus: State Environmental Policy Act (SEPA) Environmental Review; City of Renton
Comprehensive Plan Policy L-35; RMC 4-3-050 Critical Areas Regulations; and RMC 4-4-060
Grading, Excavation, and Mining Regulations.
2. Water
a. Wetland, Streams, Lakes
Impacts: Due to the presence of a wetland and stream on the property, the applicant submitted
a Wetland and Stream Delineation Report, prepared by DCG/Watershed, dated November 21,
2023 (Exhibit 6), and a Standard Stream Study, prepared by Cascade Ecology LLC, dated February
3, 2023 (Exhibit 7). These studies included an analysis of existing conditions and the potential
impacts of the proposed development on the wetland, stream, and their associated buffers.
The wetland, Wetland A, is classified as a Category II wetland, consistent with the Washington
State Wetland Rating System. Wetland A scored a six (6) for habitat, reflecting its moderate
ecological value. The wetland’s total area covers approximately one-quarter (0.25) acre on-site.
A standard 150-foot (150’) buffer is required for Wetland A, as stipulated by the City of Renton
regulations. This buffer is essential in protecting water quality, wildlife habitat, and hydrological
processes within the wetland and its surrounding environment.
The stream on the property, Stream A (Honey Creek), is classified as a Type F (fish-bearing) stream
as per the City of Renton’s classification system. Stream A flows through the western portion of
the site, entering the property from the south edge and losing channel definition shortly after
entering the parcel (approximately 30 feet (30’) northwest of the culvert). Stream A is associated
with a 115-foot (115’) buffer in compliance with the city’s regulations for Type F streams. The
buffer serves to protect the stream from potential impacts due to construction activities, ensuring
that water quality, sedimentation, and habitat functions are maintained.
The proposed development includes the construction of a detached garage and accessory
dwelling unit (ADU) located approximately 29 feet, 7 inches from the edge of the wetland. This
represents an encroachment of approximately 120 feet, 5 inches into the required 150-foot
buffer. It’s important to note that the wetland buffer extends beyond the property lines and is
therefore not fully shown on the site map. The existing single-family residence is already located
within the wetland buffer. The current layout provides a 29-foot, 7-inch buffer from the wetland
edge to the new development. Due to the wetland, stream, and topographical constraints on the
property, the proposed building location is in one of the only flat and accessible portions of the
lot, making it one of the only feasible area for the property owners to construct an ADU without
significant grading or earthwork.
Construction activities would result in impacts to the buffer areas, particularly due to minor
grading and erosion control activities during construction. According to the Standard Stream
Study, the applicant is currently planting the east-bank of the stream, closest to the project site
and main residence, with native plants including Sword Fern (Polystichum munitum), Deer Fern
(Struthiopteris spicant), and Bog Kalmia (Kalmia microphylla). In addition, the stream study
indicated that the homeowners have previously restored the stream banks and the upland areas
through removal of invasive Himalayan Blackberry shrubs (Rubus armeniacus) and replacement
with a variety of native shrubs and trees. All proposed wetland buffer impacts would be subject
to current code requirements. For example, compensation for wetland buffer impacts shall occur
at a minimum one to one (1:1) ratio and compensatory mitigation for buffer impacts shall include
enhancement of degraded buffers by planting native species, removing structures and
impervious surfaces within buffers, and other measures. The 1:1 ratio refers to the practice of
replanting one square foot of native vegetation for every square foot of wetland buffer that is
Docusign Envelope ID: CF4F89F1-1EB5-4C12-B6C9-56F8F437FF55
City of Renton Department of Community & Economic Development
Bull Conditional Use Permit and Critical Areas Variance for Accessory
Dwelling Unit Development
Staff Report to the Environmental Review Committee
LUA 24-000367, ECF, CU-A, V-A
Report on May 5, 2025 Page 5 of 6
SR_ERC_Report_LUA24-000367_CUP and Variance_250428_Final
disturbed during development. This requirement comes from the City of Renton’s Critical Areas
Regulations (RMC 4-3-050J.4.d). It is a common standard used in environmental mitigation to
ensure that the ecological functions and values of wetlands are maintained or restored. In
contrast, the 3:1 ratio applies specifically to direct wetland impacts, such as filling or altering the
wetland itself, and requires three square feet of mitigation for every one square foot impacted.
However, because the proposed development is entirely within the wetland buffer and does not
disturb the wetland itself, only the 1:1 buffer mitigation ratio applies. Therefore, the construction
of the 968-square-foot ADU requires 968 square feet of replanting with native vegetation. If the
project had directly impacted the wetland, the mitigation requirement would have been 2,904
square feet (3:1 ratio), reflecting the greater ecological impact. By complying with the 1:1 buffer
mitigation requirement, the development ensures that water quality is protected, wildlife has
adequate habitat, and the buffer’s protective function is preserved. This is essential for
maintaining the long-term health and sustainability of the wetland and its surrounding
ecosystem.
Finally, all compensatory mitigation projects shall be monitored for a period necessary to
establish that performance standards have been met, but generally not for a period less than five
(5) years to ensure that the proposal would not result in a net loss of functions or values. It is
anticipated that the requirements set forth by RMC 4-3-050 would be sufficient to mitigate
wetland buffer impacts generated by the proposed development and no specific mitigation
measures are recommended.
Mitigation Measures: No further mitigation is recommended.
Nexus: Not applicable.
3. Vegetation
Impacts: According to the Tree Retention and Credit Worksheet, received October 8, 2024
(Exhibit 4), the site contains a total of 60 significant trees, as defined by RMC 4-11-200. After
applicable deductions (including trees located within wetlands, streams, and associated buffers,
as well as those within existing or proposed public right-of-way), 46 trees are proposed to remain.
Per the SEPA checklist prepared by the applicant (Exhibit 10), no vegetation other than invasive
species would be removed within the critical area buffers to accommodate the construction of
the ADU and associated grading activities. The area of work is currently used as a second driveway
which will be removed and a single driveway will be used for both the ADU and primary residence.
There is a variety of deciduous trees, evergreen trees, shrubs, grass, and wet soil plants on-site.
This vegetation is within the critical area buffer and would not disturb the wetland/stream itself.
Removal and replanting portions of the second driveway would support more long-term
ecological health. Therefore, no further mitigation is being proposed.
Mitigation Measures: No further mitigation is recommended.
Nexus: Not applicable.
4. Historic and Cultural Preservation
Impacts: The project site is located within the ancestral lands of the Duwamish people.
According to the SEPA Environmental Checklist, prepared by the applicant (Exhibit 10), no known
cultural or archaeological resources are currently documented on the property. However, the
Duwamish Tribal Historic Preservation Office submitted comments, dated April 9, 2025 (Exhibit
11), identifying the site as an area of cultural significance with the potential for unknown
archaeological deposits. The Tribe requires the applicant to receive notice and prepare and
submit an Inadvertent Discovery Plan (IDP) prior to the start of ground-disturbing activities. City
Docusign Envelope ID: CF4F89F1-1EB5-4C12-B6C9-56F8F437FF55
City of Renton Department of Community & Economic Development
Bull Conditional Use Permit and Critical Areas Variance for Accessory
Dwelling Unit Development
Staff Report to the Environmental Review Committee
LUA 24-000367, ECF, CU-A, V-A
Report on May 5, 2025 Page 6 of 6
SR_ERC_Report_LUA24-000367_CUP and Variance_250428_Final
staff responded to the comments and is recommending that the applicant prepare and submit an
Inadvertent Discovery Plan (IDP) prior to the start of any ground-disturbing activities. In addition,
the applicant shall provide notification to Tribes’ cultural committee prior to the start of
construction per the Duwamish Tribe Comments.
Mitigation Measures: The applicant shall prepare and submit an Inadvertent Discovery Plan (IDP)
prior to the start of any ground-disturbing activities. In addition, the applicant shall provide
notification to Tribes’ cultural committee prior to the start of construction per the Duwamish Tribe
Comments.
Nexus: State Environmental Policy Act (SEPA) Environmental Review; RCW 27.53 Archaeological
Sites and Resources; RCW 27.44 Indian Graves and Records; and City of Renton Comprehensive
Goals and Policies, L-AA, L-44, and L-45; and Duwamish Tribe Comment, dated April 9, 2025.
5. Utilities
Impacts: The project proposal is resulting in an additional residential unit on the property. This
change in use would result in a new connection to the public sanitary sewer system and an
increase in plumbing fixtures. King County Wastewater Treatment Division (WTD) submitted
comments on April 17, 2025 (Exhibit 13), indicating that the project is subject to a capacity charge
in accordance with King County Code, which applies to all new connections to the regional
wastewater treatment system. The capacity charge is a one-time fee that recovers the cost of
system expansion necessary to accommodate growth, such as additional residential units. This
creates a direct and proportionate impact on the public wastewater infrastructure operated by
King County. The capacity charge serves as a legally established mitigation tool that ensures
those who generate new demand contribute equitably to the cost of expanding the system to
maintain capacity, reliability, and service standards. The requirement to submit the Sewer Use
Certification form and pay the capacity charge is consistent with the State Environmental Policy
Act (SEPA) and the King County Code WTD (Exhibit 13). The Residential Sewer Use Certification
form will be forwarded to the city department responsible for Sewer Use Certification forms. No
further site-specific mitigation is proposed.
Mitigation Measures: No further mitigation is recommended.
Nexus: Not applicable.
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 May 19, 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: CF4F89F1-1EB5-4C12-B6C9-56F8F437FF55
CITY OF RENTON
DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT
STAFF REPORT TO THE ENVIRONMENTAL REVIEW COMMITTEE
EXHIBITS
Project Name:
Bull Conditional Use Permit and Critical Areas
Variance for Accessory Dwelling Unit Development
Land Use File Number:
LUA24-000367, ECF, CU-A, V-A
Date of Meeting
May 5, 2025
Staff Contact
Nichole Perry
Associate Planner
Project Contact
Leah and Tristan Bull,
5424 NE 10th St,
Renton, WA 98059
Project Location
5424 NE 10th St,
Renton, WA 98059
(APN 1023059365)
The following exhibits are included with the ERC Report:
Exhibit 1: Environmental Review Committee (ERC) Report
Exhibit 2: Site Plans, Pacific Home Source LLC, dated September 4, 2024
Exhibit 3: Boundary and Topographic Survey, prepared by Plog Engineering Surveyors and
Civil Engineers, dated February 21, 2024
Exhibit 4: Tree Retention and Tree Credit Worksheet, dated October 24, 2023
Exhibit 5: Geotechnical Engineering Investigation, prepared by GEO Group Northwest, Inc.,
dated July 27, 2022
Exhibit 6: Wetland and Stream Delineation Report, prepared by DCG/Watershed, dated
November 21, 2023
Exhibit 7: Standard Stream Study, prepared by Cascade Ecology LLC, dated February 3, 2023
Exhibit 8: Project Narrative, dated September 19, 2024
Exhibit 9: Conditional Use and Variance Justification, dated October 7, 2024
Exhibit 10: SEPA Environmental Checklist, prepared by Tristan Bull, dated April 7, 2025
Exhibit 11: Duwamish Tribe Comments, prepared by Duwamish Tribal Historic Preservation,
dated April 9, 2025
Exhibit 12: Staff Response Email to the Duwamish Tribe’s Comment Letter, dated April 9, 2025
Exhibit 13: King County Wastewater Treatment Division Comments, dated April 17, 2025
Exhibit 14: Staff Response Email to the King County Wastewater Treatment Division, dated
April 17, 2025
Exhibit 15: Advisory Notes
Docusign Envelope ID: CF4F89F1-1EB5-4C12-B6C9-56F8F437FF55