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HomeMy WebLinkAboutC_DMarcus_PSE_Public_Comment_250924 September 24th, 2025 Mariah Kerrihard Associate Planner Community and Economic Development City of Renton 1055 S Grady Way Renton, WA 98057 MKerrihard@Rentonwa.gov Subject: City of Renton Critical Areas Ordinance Update Dear Ms. Kerrihard: Puget Sound Energy (PSE) appreciates the opportunity to provide input and feedback on the draft updates to the City of Renton’s Critical Area Ordinance (CAO, Renton Municipal Code (RMC) Chapter 4- 3-050). PSE is the state’s oldest and largest energy utility, serving millions of customers in a 6,000-mile service territory that includes Renton. PSE is committed to delivering safe and reliable service to the residents and businesses throughout our service territory and is regularly subject to critical areas regulations through our operations and maintenance activities. PSE supports the City's mission to protect critical areas and wants to work collaboratively with the City to ensure we can continue to efficiently and safely serve all our electric and gas customers, as mandated by state law. Initial Observations Based on our preliminary review of the draft CAO updates received on September 22, 2025, PSE has identified several areas that may impact our ability to maintain and upgrade critical utility infrastructure. However, given the short timeframe between receiving the draft (September 22) and the comment deadline (September 24), we have not had sufficient time to conduct a comprehensive analysis of all proposed changes. PSE is a regulated utility with an obligation to serve customers per WAC 480-100 and WAC 480-90. We must comply with state and federal regulations administered by various authorities, including the Washington Utilities and Transportation Commission (WUTC) and the North American Electric Reliability Corporation (NERC). PSE is also subject to state mandates to comply with the Clean Energy Transformation Act (CETA) and supply electricity that is 100% renewable and non-emitting by 2045. Much of PSE's utility infrastructure within critical areas is existing and was established decades ago. We must retain the ability to repair, maintain, and upgrade this critical infrastructure in a timely manner. We must also have the ability to install new infrastructure that could impact critical areas and buffers when there is no feasible alternative, particularly due to the linear nature of our facilities. Areas of Initial Concern Our preliminary review has identified potential concerns including – but not limited to – the following areas: 1. Utility Exemptions: The scope and applicability of exemptions for utility maintenance, repair, and replacement activities. 2. Permitting Processes: Administrative requirements for exempt activities that may affect our ability to efficiently plan, permit, and schedule necessary utility projects. Request for Extended Comment Period Given the complexity of the proposed changes and their potential impacts on critical utility infrastructure, PSE plans to provide more detailed and substantive comments prior to the updates being brought to the City Council's Planning Subcommittee on October 13, 2025. This additional time will allow us to:  Conduct a thorough analysis of all proposed changes  Assess potential impacts on existing and planned utility infrastructure  Develop specific recommendations for utility-related provisions  Coordinate with our technical and legal teams to ensure comprehensive feedback Ongoing Collaboration We request that the City consider the unique needs of utility providers and incorporate appropriate flexibility into the CAO regulations to balance safety, reliability, and environmental goals. PSE looks forward to working with you and other affected parties to identify solutions that protect critical areas while maintaining essential utility services. Please do not hesitate to contact me at (206) 716-2754 or at dylan.marcus@pse.com. PSE welcomes continued engagement throughout this process and looks forward to providing more detailed comments before the Planning Subcommittee meeting Sincerely, Dylan Marcus Municipal Land Planner Puget Sound Energy