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ERC_Report_3_Plus_Empire_250722_Final
ENVIRONMENTAL REVIEW COMMITTEE REPORT
ERC Meeting Date: July 21, 2025
Project File Number: PR25-000048
Project Name: 3 Plus Empire
Land Use File Number: LUA25-000142, ECF
Project Manager: Mariah Kerrihard, Associate Planner
Owner: John Pietromonaco, PO Box 776, Mercer Island, WA 98040
Applicant: Hai Zeng, 3 Plus Empire, 12121 SE 27th St, Bellevue, WA 98005
Contact: Julie Templeton, 2470 S Ferdinand St, Seattle, WA 98108
Project Location: 2900 Lind Ave SW, Unit B (APN 1253790010)
Project Summary: The applicant is requesting Environmental (SEPA) Review for the change of use
of an existing 33,150 square foot tenant space, currently classified as vacant
warehouse space, to an I-502 Tier 3 marijuana production and processing
facility. All proposed improvements would be interior to the tenant space, no
exterior site improvements are proposed. The project site totals 188,862
square feet in area and is located within the Heavy Industrial (IH) zoning
designation, the Employment Area (EA) Comprehensive Plan Land Use
Designation and the Valley Community Planning Area. Existing driveway access
curb cuts off of Lind Avenue SW and SW 29th Street would be maintained.
According to City of Renton (COR) Maps, a seismic hazard area is mapped on
the project site. The applicant submitted an Environmental Checklist to
evaluate the application.
Exist. Bldg. Area SF: 78,752 SF Proposed New Bldg. Area
(footprint):
Proposed New Bldg. Area
(gross):
N/A
N/A
Site Area: 188,862 SF (4.34
acres)
Total Building Area GSF: 78,752 SF
STAFF
RECOMMENDATION:
Staff Recommends that the Environmental Review Committee issue a
Determination of Non-Significance - Mitigated (DNS-M).
Docusign Envelope ID: AD508782-352F-4D87-AF59-AFC842A6F6BD
City of Renton Department of Community & Economic Development
3 Plus Empire
Staff Report to the Environmental Review Committee
LUA25-000142, ECF
Report of July 21, 2025 Page 2 of 6
ERC_Report_3_Plus_Empire_250722_Final
PART ONE: PROJECT DESCRIPTION / BACKGROUND
The applicant is requesting Environmental (SEPA) Review for the change of use of an existing 33,150 square
foot tenant space. The space was previously occupied by North Pacific Industrial Coatings Powder Coating
and Metal Painting Company and then used for new boat storage. The applicant is proposing to change the
building occupancy classification from S occupancy to F-1 occupancy for a Tier Three (3) I-502 recreational
marijuana production and processing facility located fully within a portion of the existing warehouse space
(Suite B).
The subject property is located on the southeast corner of SW 29th St and Lind Ave SW. The subject property
totals 188,862 square feet (4.34 acres) is zoned Heavy Industrial (IH) and is located in the Employment Area
(EA) Comprehensive Plan Land Use Designation. The site is currently occupied with a 78,752 square foot
structure that is segregated into two tenant spaces (Suites A and B). The proposal would occupy Suite B. Suite
A is currently occupied by Soulshine Development Group, which is also a recreational marijuana production
and processing facility. All improvements to the site would be interior to Suite B; no changes are proposed to
Suite A under this application.
The development of the project site will be phased in through two (2) phases, with Phase 1 being the setup
phase and Phase 2 will include the full build-out and maximum operations phase.
Access is provided via existing driveways off of Lind Ave SW and SW 29th St. The project site has a total of 149
parking spaces, of which 96 parking spaces are available to Suite B.
The existing building has a maximum height of 20 feet and 3 5/8 inches. No exterior changes are proposed to
the existing building. All improvements would be interior to the tenant space.
PART TWO: 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 provide additional traffic analysis to mitigate any traffic volumes realized
should operational changes occur, such as an employee shift change resulting in an increase in
net new PM Peak Hour Vehicle trips. The additional traffic study shall be reviewed and approved
by Development Engineering and Transportation staff to determine applicable transportation
impact fees. Any applicable transportation impact fees would be subject to the current fee
schedule. Alternatively, the applicant may choose to pay the Transportation Impact Fee based on
the PM site peak hour trips prior to building permit issuance in accordance with the current fee
schedule rates.
Docusign Envelope ID: AD508782-352F-4D87-AF59-AFC842A6F6BD
City of Renton Department of Community & Economic Development
3 Plus Empire
Staff Report to the Environmental Review Committee
LUA25-000142, ECF
Report of July 21, 2025 Page 3 of 6
ERC_Report_3_Plus_Empire_250722_Final
C. Exhibits
Exhibit 1: Environmental Review Committee (ERC) Report
Exhibit 2: Site Plan
Exhibit 3: Survey
Exhibit 4: SEPA Environmental Checklist
Exhibit 5: Project Narrative
Exhibit 6: Project Trip Generation Study, prepared by William Popp Associates, dated April
4, 2025
Exhibit 7: Duwamish Tribe Comment Letter, dated May 13, 2025
Exhibit 8: Duwamish Tribe City Response Email, dated May 13, 2025
Exhibit 9: Agency Comment from John Dawson, dated May 16, 2025
Exhibit 10: Staff Response to PSCAA dated July 17, 2025
Exhibit 11: Public Comment from David Levine, dated May 27, 2025
Exhibit 12: Staff Response to David Levine, dated May 28, 2025
Exhibit 13: Transportation Concurrency Memo, prepared by Nathan Janders, dated May 30,
2025
Exhibit 14: 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: According to COR Maps, the project site is located within a high seismic hazard area. A
Geotechnical Report was not included with the land use application materials as no exterior
improvements to the existing building are proposed. The proposed project is limited to a change
of use and interior tenant improvements. It is anticipated that the city’s adopted building code
and construction standards would adequately mitigate any impacts of the proposed tenant
improvements on the project site. No further mitigation is recommended.
Mitigation Measures: None recommended.
Nexus: Not applicable.
2. Air
Impacts: It is anticipated that some temporary air quality impacts could be associated with site
work during construction activities. Project development impacts during construction would
include exhaust emissions from construction workers’ vehicles, construction vehicles, and other
equipment. According to the applicant, cannabis production and processing results in emissions
of volatile organic compounds (VOCs) and other odorous compounds into the atmosphere, and
emissions of VOCs and odors are regulated under Washington’s Clean Air Act (Exhibit 9). A limited
number of chemicals will be stored and utilized on a regular basis within the facility, including
fertilizers necessary for cannabis cultivation, carbon dioxide for enhancing plant growth within a
controlled environment, and various standard cleaning solutions for maintaining facility hygiene,
Docusign Envelope ID: AD508782-352F-4D87-AF59-AFC842A6F6BD
City of Renton Department of Community & Economic Development
3 Plus Empire
Staff Report to the Environmental Review Committee
LUA25-000142, ECF
Report of July 21, 2025 Page 4 of 6
ERC_Report_3_Plus_Empire_250722_Final
with no significant quantities of highly toxic or acutely hazardous chemicals anticipated. To
proactively reduce and control any potential environmental health hazards associated with these
materials and operational processes, several measures are proposed: carbon dioxide (CO2) and
carbon monoxide (CO) monitors will be installed at appropriate locations to ensure safe
atmospheric conditions; charcoal air filtration systems will be installed and maintained in all
rooms used for growing, trimming, and processing cannabis, specifically designed to filter out
volatile organic compounds (VOCs) and odorous compounds to mitigate air quality impacts and
ensure a safe internal environment; all fertilizers and cleaning solutions will be stored and
handled strictly in accordance with manufacturers’ instructions, and applicable regulatory
requirements. The proposal includes the installation of a ductless HVAC system with no exhaust
air. Therefore, the applicant contends the air in the growing, drying, and processing rooms and
any other rooms that contain cannabis will be provided with charcoal air filtration and that no
noticeable smell should be detected from outside of the building. The Puget Sound Clean Air
Agency (PSCAA) has permitting requirements for I-502 Marijuana producers and processors that,
if applicable, the project proposal would be required to comply with. No further mitigation is
recommended.
Mitigation Measures: None recommended.
Nexus: Not applicable.
3. Light and Glare
Impacts: It is not anticipated that the proposal would result in any adverse light and glare
impacts. The project site is situated within a Heavy Industrial (IH) zone, with no residential uses
in the vicinity, thus eliminating potential impacts on residential properties. The applicant
contends that any new or modified outdoor lighting will be shielded and directed downwards to
prevent spillover onto adjacent properties.
Mitigation Measures: None recommended.
Nexus: Not applicable.
4. Historic and Cultural Preservation
Impacts: The project site is located within the ancestral lands of the Duwamish people. Staff
received a comment from the Duwamish Tribal Historic Preservation Office (Exhibit 7) during the
14-day public comment period identifying the area as culturally significant with a high probability
of encountering unknown archaeological deposits. This letter notes that this area is considered
culturally significant and that there are four (4) historical and ancestral Duwamish place names
within about 1.5 miles of the project location. The Duwamish Tribe requested that an Inadvertent
Discovery Plan (IDP) be provided for the proposed project if any groundbreaking activity occurs
below fill, topsoil, or other impervious surfaces into native soil. As the project proposal does not
include any exterior additions or alterations requiring excavation, rather is limited to a change of
use with interior tenant improvements, staff is not recommending that an IDP be required at this
time. If the scope of work changes and construction is proposed, the proposal would be subject
to additional Environmental Review and an IDP could be required at that time.
Mitigation Measures: None recommended.
Nexus: Not applicable.
5. Transportation
Impacts: A Project Trip Generation Study, prepared by William Popp Associates (Exhibit 6), and a
Transportation Concurrency Test (Exhibit 13) were conducted to assess the proposal's
transportation impacts. This Level 1 traffic study, which included trip generation analysis, trip
Docusign Envelope ID: AD508782-352F-4D87-AF59-AFC842A6F6BD
City of Renton Department of Community & Economic Development
3 Plus Empire
Staff Report to the Environmental Review Committee
LUA25-000142, ECF
Report of July 21, 2025 Page 5 of 6
ERC_Report_3_Plus_Empire_250722_Final
assignment, and mitigation fee assessment, was conducted for the tenant improvements within
Suite B of the existing warehouse at 2900 Lind Ave SW, with no change in building size. The
findings confirm that the project would not generate more than 20 net new trips in either the AM
or PM commute peak hours, thus a full Traffic Impact Analysis was not required per City of Renton
guidelines.
According to the traffic report, the proposed use is a fully indoor cultivation facility operated
primarily by an automated computer system, which would require minimal on-site staff and
would not have a customer-facing component. This type of operational model and no retail aspect
would allow for employee work schedule flexibility. Thus, the employees would not be required to
be in the facility during typical business hours (8 am to 5 pm). The proposed development is
projected to generate an increase of approximately 12 weekday daily trips overall. Crucially, the
project is designed to generate no increase in trips during the weekday AM and PM commute peak
hours. The AM commute peak hour is defined as the peak one hour period between 7 am and 9
am, and the PM commute peak hour is defined as the peak one hour period between 4 pm and 6
pm. This finding is a direct result of the proposed shift schedule, which seeks to avoid typical peak
hour congestion in the surrounding area. The proposed project is electing to shift the more
standard employee workday hours by setting the employee shift schedules as follows: 9:30 AM to
6:30 PM (Phase 1: 3 FTE; Phase 2: 4 FTE, Monday-Friday) and 11:00 AM to 8:00 PM (Phase 1: 2 FTE;
Phase 2: 3 FTE, Tuesday-Saturday). Additionally, part-time harvest staff (Phase 1: 3 FTE; Phase 2:
6 FTE) would work 9:30 AM to 6:30 PM, three days every other week (Tuesday-Thursday). Non-
employee vehicle trips, such as shipping and parcel deliveries, are anticipated during non-street
peak hours (e.g., incoming shipments 10 AM to 12 PM, outgoing before 4 PM) and are projected to
be infrequent.
While no trips are anticipated during the commute peak hours, the project is estimated to
generate an AM site peak between 9 AM and 10 AM and a PM site peak between 6 PM and 7 PM.
For the site peak hour, the project is estimated to generate 6 AM and 6 PM site peak hour trips
based on a monthly average of weekday trips. Vehicle arrivals are anticipated 5 to 10 minutes prior
to scheduled start times, and departures within approximately 15 minutes after scheduled ends.
Trip assignment analysis assumes 67% of project trips would originate from/be destined to the
south, with 33% to/from the north.
Again, the proposed development would generate an increase of approximately 12 weekday daily
trips. It was estimated that there would be six (6) trips in between 9 am and 10 am (the AM site
peak hour), and six (6) trips out of the site between 6 pm and 7 pm (the PM site peak hour) during
a typical month. This finding means that there would be no long-term transportation impacts.
Thus, during the weekday AM and PM peak hours, the project would generate no increase in trips
due to a proposed shift schedule. The existing driveway access curb cuts on Lind Ave SW and SW
29th St would be maintained, providing continued access to the site. The project currently offers
156 parking spaces to accommodate operational needs.
The project successfully passed the City of Renton Traffic Concurrency Test, indicating that the
City's investment in forecast traffic improvements is 100% of the scheduled expenditure through
2025. The citywide traffic concurrency trip capacity for 2025 is 2,274 trips, providing sufficient
capacity to accommodate the approximately zero (0) additional PM peak hour trips from this
project, leaving a remaining capacity unchanged. Consequently, since no vehicle trips are
generated in the PM commute peak hour, the project is not estimated to incur transportation
mitigation fees. All proposed improvements are interior to the tenant space, with no exterior site
improvements planned. Should the applicant make operational changes to the employee work
schedule that creates a demand for additional public facilities, such that PM peak hour trips are
generated during the PM commute peak hour, the development activity would be subject to
transportation mitigation fees. Therefore, staff is recommending a mitigation measure that the
Docusign Envelope ID: AD508782-352F-4D87-AF59-AFC842A6F6BD
City of Renton Department of Community & Economic Development
3 Plus Empire
Staff Report to the Environmental Review Committee
LUA25-000142, ECF
Report of July 21, 2025 Page 6 of 6
ERC_Report_3_Plus_Empire_250722_Final
applicant provide additional traffic analysis to mitigate any traffic volumes realized should
operational changes occur, such as an employee shift change resulting in an increase in net new
PM Peak Hour Vehicle trips. The additional traffic study shall be reviewed and approved by
Development Engineering and Transportation staff to determine applicable transportation impact
fees. Any applicable transportation impact fees would be subject to the current fee schedule.
Alternatively, the applicant may choose to pay the Transportation Impact Fee based on the PM
site peak hour trips at time of building permit issuance in accordance with the current fee
schedule rates.
Mitigation Measures:
1. The applicant shall provide additional traffic analysis to mitigate any traffic volumes realized
should operational changes occur, such as an employee shift change resulting in an increase
in net new PM Peak Hour Vehicle trips. The additional traffic study shall be reviewed and
approved by Development Engineering and Transportation staff to determine applicable
transportation impact fees. Any applicable transportation impact fees would be subject to the
current fee schedule. Alternatively, the applicant may choose to pay the Transportation
Impact Fee based on the PM site peak hour trips prior to building permit issuance in
accordance with the current fee schedule rates.
Nexus: City of Renton Comprehensive Plan Goal TR-A; State Environmental Policy Act (SEPA)
Environmental Review; and RMC 4-1-190 Impact Fees.
6. Fire & Police
Impacts: Police and Fire Prevention staff indicated that sufficient resources exist to furnish
services to the proposed development; subject to the condition that the applicant provides Code
required improvements and fees.
Mitigation Measures: None recommended.
Nexus: Not applicable.
E. 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 August 6, 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: AD508782-352F-4D87-AF59-AFC842A6F6BD
CITY OF RENTON
DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT
STAFF REPORT TO THE ENVIRONMENTAL REVIEW COMMITTEE
EXHIBITS
Project Name:
3 Plus Empire
Land Use File Number:
LUA25-000142, ECF
Date of Meeting
July 21, 2025
Staff Contact
Mariah Kerrihard
Associate Planner
Project Contact/Applicant
Julie Templeton
2470 S Ferdinand St,
Seattle, WA 98108
Project Location
2900 Lind Ave SW, Unit B (APN
1253790010)
The following exhibits are included with the ERC Report:
Exhibit 1: Environmental Review Committee (ERC) Report
Exhibit 2: Site Plan
Exhibit 3: Survey
Exhibit 4: SEPA Environmental Checklist
Exhibit 5: Project Narrative
Exhibit 6: Traffic Study Memo
Exhibit 7: Duwamish Tribe Comment Letter, dated May 13, 2025
Exhibit 8: Duwamish Tribe City Response Email, dated May 13, 2025
Exhibit 9: Public Comment from John Dawson, dated May 16, 2025
Exhibit 10: Staff Response to John Dawson, dated July 17, 2025
Exhibit 11: Public Comment from David Levine, dated May 27, 2025
Exhibit 12: Staff Response to David Levine, dated May 28, 2025
Exhibit 13: Transportation Concurrency Memo
Exhibit 14: Advisory Notes
Docusign Envelope ID: AD508782-352F-4D87-AF59-AFC842A6F6BD