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701 Fifth Avenue • Suite 6600 • Seattle, Washington 98104 • 206.812.3388 • Fax 206.812.3389 • www.mhseattle.com
September 24, 2025
VIA ELECTRONIC MAIL
Matt Herrera, AICP, Planning Director
City of Renton
Community and Economic Development
1055 S Grady Way
Renton, WA 98057
Re: Comments on Draft Critical Areas Ordinance
Dear Matt:
On behalf of Seattle Children's, we would like to present some preliminary comments on the first
draft of the new revisions to the Critical Areas Ordinance for the City of Renton (“CAO”). Our
team has had a short period of time to review the draft CAO and prepare initial comments, and we
look forward to supplementing these comments in the weeks ahead.
Overall, we appreciate that the City is focusing on the protection and preservation of high-quality
wetlands and providing appropriate flexibility for addressing lower-quality wetlands. Our
preliminary comments are as follows:
• The increase in wetland buffers for high-quality wetlands to 300’, particularly in the case of
Category III wetlands, is a large increase over the current 125’ required buffer and seems
excessive for a lower-category wetland.
• We would like to include as much flexibility as possible in the CAO’s approach to buffer
enhancement, reduction and averaging for all wetlands . This would include provisions that
allow for “paper fill” of wetland buffers, tied to appropriate mitigation.
• For Category III and IV wetlands, the new CAO should permit the filling of such wetlands
with appropriate mitigation.
• Existing nonconforming buffer conditions should be grandfathered in new development,
with buffer enhancement as appropriate.
• Buffer interruptions, such as roads, parking lots, paved areas and buildings, should be used
to define the maximum extent of a buffer. Buffers should not extend beyond such
interruptions.
• Mitigation opportunities, both onsite and offsite, should be as flexible as possible. Use of
mitigation banks should be emphasized.
September 24, 2025
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• The new CAO should recognize cases where the US Army Corps of Engineers declines
jurisdiction for isolated wetlands and treat those wetlands with less restrictive standards.
• The new CAO should clearly provide that aerial structures or below-grade utilities that enter
into wetland buffer areas should be allowed, as long as appropriate performance standards
are met. We look forward to working with you to develop these appropriate performance
standards.
• Our further review of the CAO may identify other issues, and we would add those to our
upcoming conversations as appropriate.
We will be providing more detailed comments on the CAO in the near future and look forward to
meeting with you in the meantime to discuss these issues.
Sincerely,
/s/ John C. McCullough
John C. McCullough