HomeMy WebLinkAboutC_Withdrawl Request1
Jill Ding
From:Richard Tran <Richard@coatesdesign.com>
Sent:Wednesday, August 20, 2025 2:37 PM
To:Jill Ding
Cc:Emily Banks; Scott Kaul; Mark (markdraabe@comcast.net); Michael Burns Real Estate
Subject:RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on
hold letter (EE-532)
Jill,
I just talked to Mark Raabe, and he has confirmed to withdraw the land use application.
Thank you,
Richard Tran
Project Architect
COATES DESIGN
(206) 780.0876 ext. 305
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Tuesday, August 19, 2025 11:35 AM
To: Richard Tran <Richard@coatesdesign.com>
Cc: Emily Banks <emily@coatesdesign.com>; Scott Kaul <skaul@AHBL.com>; Mark (markdraabe@comcast.net)
<markdraabe@comcast.net>; Michael Burns Real Estate <michael@brokerseattle.com>; Allyson Burket
<aburket@AHBL.com>; Matthew Coates <matthew@coatesdesign.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Richard,
I am sorry to hear this.
Just to confirm, you would like to withdraw the land use application for the project at this time, correct? If
so, I will update our system.
Thanks,
JILL DING, Senior Planner
City of Renton // Planning
Virtual Permit Center // Online Applications and Inspections
office 425-430-6598
NOTICE OF PUBLIC DISCLOSURE: This message complies with Washington State’s Public Records Act – RCW 42.56
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
2
From: Richard Tran <Richard@coatesdesign.com>
Sent: Tuesday, August 19, 2025 10:28 AM
To: Jill Ding <JDing@Rentonwa.gov>
Cc: Emily Banks <emily@coatesdesign.com>; Scott Kaul <skaul@AHBL.com>; Mark (markdraabe@comcast.net)
<markdraabe@comcast.net>; Michael Burns Real Estate <michael@brokerseattle.com>; Allyson Burket
<aburket@AHBL.com>; Matthew Coates <matthew@coatesdesign.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Jill,
I have bad news: after reviewing the loss of units due to the updated stream setback and redesign costs,
plus other fees, Mark R. has decided not to move forward with the project at this time. The site was
feasible with 5 townhouses but not 3 townhouses. You have been very helpful with the process and
enjoyable to work with. If anything changes, we will let you know.
Thank you,
Richard Tran
Project Architect
COATES DESIGN
(206) 780.0876 ext. 305
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Tuesday, August 19, 2025 7:42 AM
To: Richard Tran <Richard@coatesdesign.com>
Cc: Emily Banks <emily@coatesdesign.com>; Scott Kaul <skaul@AHBL.com>; Mark (markdraabe@comcast.net)
<markdraabe@comcast.net>; Michael Burns Real Estate <michael@brokerseattle.com>; Allyson Burket
<aburket@AHBL.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Richard,
Yes, this requirement can be deferred, I will make it a condition of approval.
Thanks,
JILL DING, Senior Planner
City of Renton // Planning
Virtual Permit Center // Online Applications and Inspections
office 425-430-6598
NOTICE OF PUBLIC DISCLOSURE: This message complies with Washington State’s Public Records Act – RCW 42.56
From: Richard Tran <Richard@coatesdesign.com>
Sent: Monday, August 18, 2025 1:08 PM
To: Jill Ding <JDing@Rentonwa.gov>
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
3
Cc: Emily Banks <emily@coatesdesign.com>; Scott Kaul <skaul@AHBL.com>; Mark (markdraabe@comcast.net)
<markdraabe@comcast.net>; Michael Burns Real Estate <michael@brokerseattle.com>; Allyson Burket
<aburket@AHBL.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Jill,
We are working on the hold comments. We plan to remove the gas easement and complete the
form. The planned townhouse will not be using gas, but all electricity. Since Mark is still in negotiation
with the seller, we don’t own the lot yet. Can you have this requirement pushed back to a later
date? Consider waiving to a later date so we can proceed as a contingency item.
Thank you,
Richard Tran
Project Architect
COATES DESIGN
(206) 780.0876 ext. 305
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Wednesday, July 23, 2025 10:01 AM
To: Richard Tran <Richard@coatesdesign.com>; Scott Kaul <skaul@AHBL.com>
Cc: Emily Banks <emily@coatesdesign.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Richard,
It sounds like you are being required to dedicate 1.5’ of your property for right-of-way. This will shift the
property, you would measure the setback from the new property line/right-of-way.
Thanks,
JILL DING, Senior Planner
City of Renton // Planning
Virtual Permit Center // Online Applications and Inspections
office 425-430-6598
NOTICE OF PUBLIC DISCLOSURE: This message complies with Washington State’s Public Records Act – RCW 42.56
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
4
From: Richard Tran <Richard@coatesdesign.com>
Sent: Wednesday, July 23, 2025 9:43 AM
To: Jill Ding <JDing@Rentonwa.gov>; Scott Kaul <skaul@AHBL.com>
Cc: Emily Banks <emily@coatesdesign.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Jill,
I have a question to clarify the setback. Our front setback is 10’, but is that measured off the property
line or the ROW (right of way)? The new street improvement will eat 1.5’ over the property line. With
ROW that is 11.5’ setback from the property line.
Thanks,
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
5
Richard Tran
Project Architect
COATES DESIGN
(206) 780.0876 ext. 305
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Thursday, July 17, 2025 9:40 AM
To: Richard Tran <Richard@coatesdesign.com>; Scott Kaul <skaul@AHBL.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>; Kellen Maloney <KMaloney@wetland-consulting.com>; Ken Large <klla@comcast.net>;
Tim Price <timp@arwengineers.com>; Troy Dye <troyd@arwengineers.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Richard,
We have discussed the proposed layout internally and would be supportive of the proposed layout. We
would support waiving the minimum density requirement due to the environmental constraints and
would support the inclusion of the private open space within the front yard setback.
Please let me know if you have additional questions.
Thanks,
JILL DING, Senior Planner
City of Renton // Planning
Virtual Permit Center // Online Applications and Inspections
office 425-430-6598
NOTICE OF PUBLIC DISCLOSURE: This message complies with Washington State’s Public Records Act – RCW 42.56
From: Richard Tran <Richard@coatesdesign.com>
Sent: Thursday, July 17, 2025 9:08 AM
To: Scott Kaul <skaul@AHBL.com>; Jill Ding <JDing@Rentonwa.gov>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>; Kellen Maloney <KMaloney@wetland-consulting.com>; Ken Large <klla@comcast.net>;
Tim Price <timp@arwengineers.com>; Troy Dye <troyd@arwengineers.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Jill,
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
6
Scott is correct; we will relocate water detention to the rear parking area and possibly under part of the
south green space, as per the updated civil design. We are still using the per-app civil drawing as the
background. We don’t plan on having anything within the 90’ stream buffer area, except for the
maintenance driveway and gate that was agreed to before.
Thanks,
Richard Tran
Project Architect
COATES DESIGN
(206) 780.0876 ext. 305
From: Scott Kaul <skaul@AHBL.com>
Sent: Thursday, July 17, 2025 7:50 AM
To: Jill Ding <JDing@Rentonwa.gov>; Richard Tran <Richard@coatesdesign.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>; Kellen Maloney <KMaloney@wetland-consulting.com>; Ken Large <klla@comcast.net>;
Tim Price <timp@arwengineers.com>; Troy Dye <troyd@arwengineers.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
We will resize and relocate our storm facility once this overall concept is generally accepted.
Scott Kaul, PE, LEED AP | Associate Principal
AHBL, Inc. | TACOMA • SEATTLE • SPOKANE • TRI-CITIES
253.383.2422 TEL | 253.284.9645 DIRECT | skaul@ahbl.com EMAIL | Send us a file.
Career Opportunities available | Learn more today!
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Thursday, July 17, 2025 7:48 AM
To: Richard Tran <Richard@coatesdesign.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>; Kellen Maloney <KMaloney@wetland-consulting.com>; Ken Large <klla@comcast.net>;
Tim Price <timp@arwengineers.com>; Troy Dye <troyd@arwengineers.com>; Scott Kaul <skaul@AHBL.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Richard,
Is there a stormwater facility proposed within the stream buffer? If so, this would need to be relocated
outside of the stream buffer.
Thanks,
7
JILL DING, Senior Planner
City of Renton // Planning
Virtual Permit Center // Online Applications and Inspections
office 425-430-6598
NOTICE OF PUBLIC DISCLOSURE: This message complies with Washington State’s Public Records Act – RCW 42.56
From: Richard Tran <Richard@coatesdesign.com>
Sent: Wednesday, July 16, 2025 9:52 PM
To: Jill Ding <JDing@Rentonwa.gov>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>; Kellen Maloney <KMaloney@wetland-consulting.com>; Ken Large <klla@comcast.net>;
Tim Price <timp@arwengineers.com>; Troy Dye <troyd@arwengineers.com>; Scott Kaul <skaul@AHBL.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Hi Jill,
Per our phone call, you said you could waive the minimum density requirement. That was 4 min., but we
are able to place 3 townhouse units. You said you wanted to see the new layout before we could respond
to the land-use comments. Please let us know if this works, and we will proceed with the
permitting. See the attached site plan.
General Land Use Code changes:
1. With 3 units, the fire sprinkler requirement can be removed.
2. No community space and all the walkways.
3. Private space has been increased from 250sf to 600sf per unit.
4. No need to upgrade the street lighting as it is 3 or fewer.
5. The water line comes straight from the street, so we don’t need an additional water line setback.
6. We are removing the gas easement on the east, now we can have a side setback to 4 ‘ per zoning. The
building will be all electric, no gas.
7. Per comment, we located the 115’ stream buffer that can be reduced to 90’ through mitigation per 4-3-
050I.
Design layout site narrative:
1. 3 townhouses facing S132nd. It should be the same side as the previous units, just 2 fewer townhouse
units. Same elevation but rotated.
2. The parking is in the rear, so the 24' car driveway applies only to the rear.
3. The side alley driveway can be 12-15', since we already have a 15' easement for the sewer. The site
maintenance road will still be 15’. They can use the rear alley as a T-bone turnaround.
4. Jill said the front setback can be part of the private area. We are counting the front private area of each
unit, plus the rear areas, to get a minimum of 600 sf per unit.
8. All previous code still applies.
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
8
9
Thanks,
Richard Tran
Project Architect
COATES DESIGN
(206) 780.0876 ext. 305
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Friday, July 11, 2025 8:03 AM
To: Richard Tran <Richard@coatesdesign.com>; Scott Kaul <skaul@AHBL.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>; Kellen Maloney <KMaloney@wetland-consulting.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Richard,
Our code prevents us from approving a variance to the maximum density standards, RMC 4-2-110E.2
states:
2. Applicable provision(s) or standard(s) are not eligible for a variance.
We do have Density Bonus provisions outline in RMC 4-9-065, linked here:
https://www.codepublishing.com/WA/Renton/#!/Renton04/Renton0409/Renton0409065.html#4-9-065.
These provisions are applicable to the R-14 zone, provided affordable housing or a cash fee-in-lieu is
provided/paid. If affordable units are provided onsite, the units would be required to remain affordable
for a period of 50 years. Any applicant or owner with on-site affordable housing shall either demonstrate
to the Administrator’s satisfaction that they possess the experience and ability to monitor and prepare
reports for on-site affordable housing, or the applicant/owner shall provide monitoring and reporting by a
qualified, independent third-party professional.
Please let me know if you have additional questions.
JILL DING, Senior Planner
City of Renton // Planning
Virtual Permit Center // Online Applications and Inspections
office 425-430-6598
NOTICE OF PUBLIC DISCLOSURE: This message complies with Washington State’s Public Records Act – RCW 42.56
From: Richard Tran <Richard@coatesdesign.com>
Sent: Thursday, July 10, 2025 11:36 AM
To: Jill Ding <JDing@Rentonwa.gov>; Scott Kaul <skaul@AHBL.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
10
<markdraabe@comcast.net>; Kellen Maloney <KMaloney@wetland-consulting.com>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Jill,
With the stream setback at 115’ and reduction option to 90’ +15’ setback, plus all the setbacks and
easements we have. The buildable footprint is approximately 3,771 square feet or less. The site r-14
designation has a 7-14 units per acre, which is still 3.6 units =4 units minimum. We can only fit 2
townhouses/ or 2 homes with all the land use code. 4 A four-unit flat would also be difficult, but I am not
sure if Mark is interested in a flat/ apartment. Can the minimum density be waived? The reasonable use
couldn’t be applied to the stream, maybe the density calculation? The stream buffer has taken over the
site.
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
11
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Tuesday, July 8, 2025 2:31 PM
To: Scott Kaul <skaul@AHBL.com>; Richard Tran <Richard@coatesdesign.com>; Kellen Maloney <KMaloney@wetland-
consulting.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Scott,
12
Yes, the City adopted Unit Lot Subdivision standards a few years ago. Here is a link to those regulations:
https://www.codepublishing.com/WA/Renton/#!/Renton04/Renton0407/Renton0407090.html#4-7-090,
they can be found in our subdivision regulations under RMC 4-7-090.
Let me know if you have additional questions.
Thanks,
JILL DING, Senior Planner
City of Renton // Planning
Virtual Permit Center // Online Applications and Inspections
office 425-430-6598
NOTICE OF PUBLIC DISCLOSURE: This message complies with Washington State’s Public Records Act – RCW 42.56
From: Scott Kaul <skaul@AHBL.com>
Sent: Tuesday, July 8, 2025 1:36 PM
To: Jill Ding <JDing@Rentonwa.gov>; Richard Tran <Richard@coatesdesign.com>; Kellen Maloney <KMaloney@wetland-
consulting.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>
Subject: RE: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Jill –
I believe Senate Bill 5559 goes into effect later this month. Has Renton developed unit lot subdivision
standards? Curious how that might be an opportunity for this property due to the found constraints.
Scott Kaul, PE, LEED AP | Associate Principal
AHBL, Inc. | TACOMA • SEATTLE • SPOKANE • TRI-CITIES
253.383.2422 TEL | 253.284.9645 DIRECT | skaul@ahbl.com EMAIL | Send us a file.
Career Opportunities available | Learn more today!
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Thursday, June 26, 2025 10:29 AM
To: Scott Kaul <skaul@AHBL.com>; Richard Tran <Richard@coatesdesign.com>; Kellen Maloney <KMaloney@wetland-
consulting.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>
Subject: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Scott,
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
13
Below are the maximum buffer reductions permitted by the Critical Areas Regulations. Reductions
beyond those permitted by code would not be supported by the City, unless the property owner could
demonstrate that the critical areas and buffers denied the owner of all “reasonable use” of their
property.
4-3-050I ALTERATIONS TO CRITICAL AREAS BUFFERS:
1. Maximum Permissible Administrative Alterations to Critical Areas Buffers – Alteration of Critical
Area Buffers: The required critical area buffers may be reduced to no less than the minimums set forth in
this subsection. Greater buffer width reductions require review as a variance pursuant to RMC 4-9-250.
Critical Area Category
or Type
Reduced Buffer: Minimum Widths
Possible
Averaged Buffer:
Minimum Widths
Possible
Geologically Hazardous Areas
Landslide Hazard Areas:
Very High Based on City acceptance of a
geotechnical report1 N/A
Streams and Lakes
Type F 90 feet2 75 feet3
Type Np 60 feet2 37.5 feet3
Type Ns 40 feet2 25 feet3
Wetlands
Wetland buffer widths shall be reduced by no more than 25% of the buffer required in
subsection G of this Section.
1. Subject to approval pursuant to the criteria in RMC 4-3-050G5hii.
2. Subject to approval pursuant to the criteria in RMC 4-3-050I2a.
3. Subject to approval pursuant to the criteria in RMC 4-3-050I2b.
2. Streams:
a. Criteria for Reduction of Degraded Stream Buffer Width with Enhancement: A reduced buffer will
be approved in a degraded stream buffer only if:
i. It will provide an overall improvement in water quality; and
ii. It will provide an overall enhancement to fish, wildlife, or their habitat; and
iii. It will provide a net improvement in drainage and/or stormwater detention capabilities; and
iv. It will not be materially detrimental to any other property or the City as a whole; and
v. It will provide all exposed areas with stabilized native vegetation, as appropriate; and
vi. The request is not made in conjunction with buffer reduction, and
vii. It will provide, as part of the buffer reduction request, buffer enhancement plan prepared by a
qualified professional and fund a review of the plan by the City’s consultant. The plan shall assess
habitat, water quality, stormwater detention, groundwater recharge, shoreline protection, and erosion
protection functions of the buffer; assess the effects of the proposed modification on those functions;
and address the six (6) criteria listed above.
14
7. Special Review Criteria – Reasonable Use Variance – Critical Areas Regulations Only: For variance
requests related to the critical areas regulations not subject to subsections B8 to B13 of this Section, a
reasonable use variance may be granted if all of the following criteria are met: (Ord. 5676, 12-3-2012)
a. That the granting of the variance will not be materially detrimental to the public welfare or injurious to
the property or improvements in the vicinity and zone in which subject property is situated;
b. There is no reasonable use of the property left if the requested variance is not granted;
c. The variance granted is the minimum amount necessary to accommodate the proposal objectives;
d. The need for the variance is not the result of actions of the applicant or property owner; and
e. The proposed variance is based on consideration of the best available science as described in
WAC 365-195-905; or where there is an absence of valid scientific information, the steps in subsection F
of this Section are followed. (Ord. 4835, 3-27-2000; Amd. Ord. 4851, 8-21-2000)
REASONABLE USE: A legal concept that has been articulated by Federal and State courts in regulatory
takings issues.
JILL DING, Senior Planner
City of Renton // Planning
Virtual Permit Center // Online Applications and Inspections
office 425-430-6598
NOTICE OF PUBLIC DISCLOSURE: This message complies with Washington State’s Public Records Act – RCW 42.56
From: Scott Kaul <skaul@AHBL.com>
Sent: Thursday, June 26, 2025 10:11 AM
To: Jill Ding <JDing@Rentonwa.gov>; Richard Tran <Richard@coatesdesign.com>; Kellen Maloney <KMaloney@wetland-
consulting.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Emily Banks
<emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>
Subject: RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Good morning Jill –
I believe the Team acknowledges the upgraded stream classification, Type F. However, per Kellen’s
email below we have done substantial enhancement where we believe there is a good argument to allow
for reduction to the Type F stream buffer in accordance with Renton Code. I believe this is the avenue
we’re looking to pursue.
Kellen, can you please confirm.
Scott Kaul, PE, LEED AP | Associate Principal
AHBL, Inc. | TACOMA • SEATTLE • SPOKANE • TRI-CITIES
253.383.2422 TEL | 253.284.9645 DIRECT | skaul@ahbl.com EMAIL | Send us a file.
Career Opportunities available | Learn more today!
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
15
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Thursday, June 26, 2025 10:00 AM
To: Richard Tran <Richard@coatesdesign.com>; Kellen Maloney <KMaloney@wetland-consulting.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Scott Kaul
<skaul@AHBL.com>; Emily Banks <emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK
RAABE <markdraabe@comcast.net>
Subject: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Richard,
I was able to have an internal discussion with respect to this project and the stream classification. As
WDFW and King County both have the stream classified as a Type F stream, it would be unlikely that the
City would support a change in the classification of this stream.
If you decide you would like to continue to pursue the reclassification of the stream, your biologist would
need to provide documentation that demonstrates that the stream does not meet the Type F criteria, but
instead meets the criteria of a different classification. Once this information is submitted, I would
request a scope of work and budget from the City’s biologist for review. The applicant would be
responsible for the payment of the City’s consultant to review this information. If the City’s consultant
did agree that the stream should be reclassified from an F to a different classification, a legislative map
amendment from the City Council would need to be requested before a reduced buffer could be applied
(see applicable code section below).
5. Streams and Lakes: Water class shall be determined in accordance with subsection G7a of this
Section.
a. Reclassification: The reclassification of a water body to a lower class (i.e., F to Np, or Np to Ns, etc.)
requires Administrator acceptance of a stream or lake study, followed by a legislative amendment to the
map in this subsection E prior to its effect. The reclassification of a water body to a higher class (i.e., Ns
to Np, Np to F, or F to S) requires either: Administrator acceptance of a stream or lake study or
consultation with the Washington Department of Fish and Wildlife, followed by a legislative amendment
to the map in this Section.
JILL DING, Senior Planner
City of Renton // Planning
Virtual Permit Center // Online Applications and Inspections
office 425-430-6598
NOTICE OF PUBLIC DISCLOSURE: This message complies with Washington State’s Public Records Act – RCW 42.56
From: Richard Tran <Richard@coatesdesign.com>
Sent: Wednesday, June 25, 2025 4:58 PM
To: Jill Ding <JDing@Rentonwa.gov>; Kellen Maloney <KMaloney@wetland-consulting.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Scott Kaul
<skaul@AHBL.com>; Emily Banks <emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK
16
RAABE <markdraabe@comcast.net>
Subject: RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Jill,
Thanks for the update. Keep us posted.
Richard Tran
Project Architect
COATES DESIGN
(206) 780.0876 ext. 305
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Wednesday, June 25, 2025 1:39 PM
To: Richard Tran <Richard@coatesdesign.com>; Kellen Maloney <KMaloney@wetland-consulting.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Scott Kaul
<skaul@AHBL.com>; Emily Banks <emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK
RAABE <markdraabe@comcast.net>
Subject: RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Richard,
I was able to do some research regarding the stream classification, this particular stream classification
was updated to be consistent with King County’s stream data. Here is a link to the King County
Watershed Mapping Toolbox:
https://experience.arcgis.com/experience/f866212a8b75402ea07200a5ffde9e7a/page/Explore?views=L
ayer-List
I will look into whether or not there is a process to reconsider the stream classification and get back to
you.
Thanks,
JILL DING, Senior Planner
City of Renton // Planning
Virtual Permit Center // Online Applications and Inspections
office 425-430-6598
NOTICE OF PUBLIC DISCLOSURE: This message complies with Washington State’s Public Records Act – RCW 42.56
From: Richard Tran <Richard@coatesdesign.com>
Sent: Tuesday, June 24, 2025 1:49 PM
To: Jill Ding <JDing@Rentonwa.gov>; Kellen Maloney <KMaloney@wetland-consulting.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Scott Kaul
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
17
<skaul@AHBL.com>; Emily Banks <emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>; MARK
RAABE <markdraabe@comcast.net>
Subject: RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Jill,
Also, the City of Renton needs to update its GIS HUB stream category.
https://gishub-rentonwa.hub.arcgis.com/documents/adb083af3d37454c903df4df4de25866/explore
Thank you,
Richard Tran
Project Architect
COATES DESIGN
(206) 780.0876 ext. 305
From: Richard Tran
Sent: Tuesday, June 24, 2025 1:46 PM
To: Jill Ding <jding@rentonwa.gov>; Kellen Maloney <KMaloney@wetland-consulting.com>; MARK RAABE
<markdraabe@comcast.net>
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>; Scott Kaul
<skaul@AHBL.com>; Emily Banks <emily@coatesdesign.com>; Matthew Coates <matthew@coatesdesign.com>
Subject: RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Jill,
I also talked to Mark Raabe, the owner, and he agreed to move forward with the City’s biologist
review. He is aware of the $5,000 (rough estimate) review fee for the city’s biologist to review the report,
as you mentioned over the phone.
Can you give Kellen the process form and link for this review step?
Thank you,
Richard Tran
Project Architect
COATES DESIGN
(206) 780.0876 ext. 305
From: Matthew Coates <matthew@coatesdesign.com>
Sent: Tuesday, June 24, 2025 1:13 PM
To: Kellen Maloney <KMaloney@wetland-consulting.com>; Richard Tran <Richard@coatesdesign.com>; Emily Banks
<emily@coatesdesign.com>; MARK RAABE <markdraabe@comcast.net>; Scott Kaul <skaul@AHBL.com>
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
18
Cc: Jessica Bruce <jbruce@AHBL.com>; Michael Burns Real Estate <michael@brokerseattle.com>; Emily Newton-
Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer <AshleyM@wetland-consulting.com>
Subject: RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
I would suggest moving ahead with amending the report.
Matthew Coates AIA, NCARB, LEED AP
President
COATES DESIGN
Architecture + Interiors
206.780.0876 office
206.607.7508 mobile
www.coatesdesign.com
CONFIDENTIALITY NOTICE: This message contains privileged and confidential information. The sender intends that the message and its
attachments are to be read only by the person(s) named above. Any unauthorized review, use, disclosure or distribution is strictly
prohibited. If you have received this message in error, please immediately delete it and notify Coates Design, Inc. by e-mail or phone. No
waiver of privilege is intended.
From: Kellen Maloney <KMaloney@wetland-consulting.com>
Sent: Tuesday, June 24, 2025 11:48 AM
To: Richard Tran <Richard@coatesdesign.com>; Emily Banks <emily@coatesdesign.com>; MARK RAABE
<markdraabe@comcast.net>; Scott Kaul <skaul@AHBL.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; Matthew Coates <matthew@coatesdesign.com>; Michael Burns Real Estate
<michael@brokerseattle.com>; Emily Newton-Weideman <EmilyNW@wetland-consulting.com>; Ashley Moyer
<AshleyM@wetland-consulting.com>
Subject: Re: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter (EE-532)
Raabe Townhomes Team,
Following the recent comment from the City of Renton regarding the Critical Areas Report for your project site,
we’ve completed a detailed regulatory review and wanted to provide our recommendations for next steps.
1. We Believe There Is Still a Clear Path to Permit the Development As-Is
While the City and WDFW have reclassified the on-site stream as fish-bearing (Type F), our analysis shows
that we can still move forward with the proposed site plan without major changes, provided we meet the
City’s performance criteria for buffer modifications and variance criteria. Our mitigation approach already
aligns with these criteria. The City didn't challenge the stream buffer reduction we proposed - they simply
challenged the stream 'typing'.
2. Consistency With Renton Code – Even if the Buffer or Stream Typing Changes
Under Renton Municipal Code 4-3-050G, a reduced buffer on a Type F stream is allowable if specific
conditions are met. Our plan satisfies these conditions, including:
• Avoiding Impacts: Based on our latest field review, no tree removal is proposed onsite (please
confirm).
19
• Minimizing buffer impacts: All impacts are limited and temporary. No construction will occur within
areas supporting mature riparian vegetation.
• Enhancing buffer functions: We are providing overall ecological improvement through native
plantings, instream tire removal, and stabilization, consistent with buffer enhancement standards.
• Improving stormwater function: The plan incorporates better water quality and detention
capability. We may need to go a little further with our methods, if there's an opportunity for increased
stormwater enhancement. I've worked on similar projects, where we proposed enhanced stormwater
function (beyond levels in the SWM), by adding additional filters, which satisfied the jurisdiction.
• Meeting all 8 performance criteria listed in RMC 4-3-050G.2.e.iii, including demonstration of no net
loss of ecological function.
• Variance Criteria: Based on RMC 4-9-250, we believe the project can satisfy all required variance
decision criteria:
o Practical difficulty and unnecessary hardship – The site’s narrow width and configuration limit
the buildable area outside the buffer.
o Special circumstances – The stream has been historically degraded and partially piped, with
limited on-site habitat functions relative to typical Type F conditions.
o No special privilege – The reduced buffer does not create privileges inconsistent with nearby
development, which faces similar constraints.
o Minimum necessary variance – The buffer reduction is the least needed to achieve the
development goals while maximizing mitigation and habitat enhancement.
We believe this presents a strong case for buffer flexibility under both Critical Areas and Variance review.
This gives the City discretion to approve the reduced buffer—even for a Type F stream—as long as we provide
a qualified enhancement plan and meet the criteria noted above.
3. Stream Typing – Why the Current Designation Will Stand
Although the stream was previously shown as a Type N on Renton’s map when we submitted, the City has
recently updated the classification to Type F, consistent with WDFW’s mapping. This change may have
occurred after consultation with WDFW.
Washington law and agency guidance (RCW 76.09.020, WAC 222-16-030) are clear: artificial barriers like long
culverts or pipes—including the 6,660-foot pipe downstream of this site—do not justify downgrading a stream
to non-fish-bearing. A stream that meets the physical criteria for fish habitat is treated as a Type F, even if fish
cannot currently access it. Unless a formal protocol-level fish absence survey is conducted (which is outside of
our capability), this designation cannot be formally challenged. Even if a protocol-level fish absence survey
could be conducted, WDFW may further challenge it, as they are the regulatory authority for making these
stream typing determinations. In January, we discussed this possibility of the City challenging the Type N
determination and mentioned that this is certainly a possibility.
4. Report Adjustments Will Be Minimal
20
To align the report with the updated classification and ensure compliance, we will:
• Update the stream typing and buffers from Type Ns to Type F.
• Expand the discussion in the buffer mitigation section to emphasize how our proposed enhancement
meets Renton’s code for buffer modification on Type F streams. Expand variance consistency section.
• Reference WDFW guidance and best available science where appropriate, showing how we're meeting
those criteria.
In addition, it would be helpful to coordinate a Team discussion about further potential stormwater system
upgrades. We believe this relatively minor adjustment is sufficient to respond to the City’s comment and
achieve approval.
5. Next Steps
Please let us know how you’d prefer to proceed. Would you like us to scope and prepare a revised report for
resubmittal? Or would you like to set up a meeting with the City to determine if we're tracking with their
expectations on stream buffer reduction despite typing changes?
Sincerely,
Kellen Maloney, PWS
Owner/Ecologist (he/him)
www.EastsideEnvironmentalPros.com
T: (425) 949-6659
From: Scott Kaul <skaul@AHBL.com>
Sent: Thursday, June 12, 2025 4:24 PM
To: Richard Tran <Richard@coatesdesign.com>; Emily Banks <emily@coatesdesign.com>; Emily Newton-Weideman
<EmilyNW@wetland-consulting.com>; Kellen Maloney <KMaloney@wetland-consulting.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; MARK RAABE <markdraabe@comcast.net>; Matthew Coates
<matthew@coatesdesign.com>; Michael Burns Real Estate <michael@brokerseattle.com>
Subject: RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter
I am available tomorrow and Monday between 10-3
Scott Kaul, PE, LEED AP | Associate Principal
AHBL, Inc. | TACOMA • SEATTLE • SPOKANE • TRI-CITIES
253.383.2422 TEL | 253.284.9645 DIRECT | skaul@ahbl.com EMAIL | Send us a file.
Career Opportunities available | Learn more today!
21
From: Richard Tran <Richard@coatesdesign.com>
Sent: Thursday, June 12, 2025 3:41 PM
To: Scott Kaul <skaul@AHBL.com>; Emily Banks <emily@coatesdesign.com>; Emily Newton-Weideman
<emilynw@wetland-consulting.com>; KMaloney@wetland-consulting.com
Cc: Jessica Bruce <jbruce@AHBL.com>; MARK RAABE <markdraabe@comcast.net>; Matthew Coates
<matthew@coatesdesign.com>; Michael Burns Real Estate <michael@brokerseattle.com>
Subject: [EXTERNAL] RE: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF on hold letter
Emily NW, Kellen, Scott,
Let me know when you guys are free to meet to discuss the 115’ FS stream issues that have held up this
project. We want a team meeting as soon as possible.
Thanks,
Richard Tran
Project Architect
COATES DESIGN
(206) 780.0876 ext. 305
From: Scott Kaul <skaul@AHBL.com>
Sent: Thursday, June 12, 2025 3:14 PM
To: Richard Tran <Richard@coatesdesign.com>; Emily Banks <emily@coatesdesign.com>; Emily Newton-Weideman
<emilynw@wetland-consulting.com>
Cc: Jessica Bruce <jbruce@AHBL.com>; MARK RAABE <markdraabe@comcast.net>
Subject: City of Renton: Raabe Townhomes, LUA25-000152, SA-A, ECF
All see attached ON-HOLD letter.
Should we schedule a call to coordinate these comments?
Scott Kaul, PE, LEED AP | Associate Principal
AHBL, Inc. | TACOMA • SEATTLE • SPOKANE • TRI-CITIES
253.383.2422 TEL | 253.284.9645 DIRECT | skaul@ahbl.com EMAIL
Civil Engineers • Structural Engineers • Landscape Architects • Community Planners • Land Surveyors
Visit us at www.ahbl.com. | Follow us on LinkedIn and Facebook. | Send us a file.
Career Opportunities available | Learn more today!