HomeMy WebLinkAboutC_TSears_DNR_Public_Comment_2510161
Mariah Kerrihard
From:Sears, Tricia (DNR) <Tricia.Sears@dnr.wa.gov>
Sent:Thursday, October 16, 2025 4:32 PM
To:Mariah Kerrihard
Cc:Sears, Tricia (DNR); Vanegas, Ted (COM)
Subject:Renton’s Critical Areas Ordinance Amendments (2025-S-9912): WGS comments
Categories:CAO
Hello Mariah,
In keeping with the interagency correspondence principles, I am providing you with comments on Renton’s Critical Areas
Ordinance Amendments (2025-S-9912).
For this proposal submitted via Planview, I looked at the proposal and focused on areas related to WGS work. Of note,
but not limited to, I look for language around the geologically hazardous areas, mineral resource lands, mining, climate
change, and natural hazards mitigation plans.
Specifically in this proposal, I reviewed the Draft CAO Amendments 250924 Strikethrough Underlined.pdf. Kudos to you
for working on your CAO!
Draft CAO Amendments
Page 2, 4-3-050B states that the geologic hazards are steep slopes, landslide, erosion, seismic, and coal mine hazards.
Good! It’s really useful to have the types of hazards stated clearly and early in the code provisions.
Page 3, 4-3-050C has a table of exempt activities and critical areas. “If an “X” appears in a box, the listed exempƟon
applies in the specified criƟcal area and required buffer. If an “X” does not appear in a box, then the exempƟon does not
apply in the parƟcular criƟcal area or required buffer.” A useful table.
Page 18, The maps description for city maps does not refer to any specific map or database like the Washington Geologic
Information Portal.
Page 18 refers to a qualified consultant. Page 19 refers to a qualified professional. Page 20 refers to a qualified specialist.
There are references to an engineering geologist and geotechnical engineer. Suggest using a consistent term and
defining it. Many jurisdictions have a definition of qualified professional that includes the types of professionals for each
critical area. For example, for geologically hazardous areas there would be a requirement under the qualified
professional definition that the engineering geologist and the geotechnical engineer be licensed in Washington.
Page 20, 4-3-050F in Geologically Hazardous Areas, the provisions of 2.a.i refer to different hazards and categories of
low, medium, high. The maps mentioned here are part of the critical areas inventory maps and are on the online map
system the city has. The provisions of 2.a.ii are brief and broad. Consider having more specifically detailed provisions.
The provisions of 6 refer to an independent secondary review. In that situation there are additional requirements for
geologically hazardous areas. So these are only required when the independent secondary review is required? Is the
independent secondary review always required for the three listed situations?
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Page 27, In Native Growth Protection Areas, there is a requirement to record to title that there are critical areas on the
property. If there is no NGPA, then they don’t have to record the critical areas to title?
Below, I include our usual language for this and future endeavors.
Recognizing the limitations of the current proposals, I want to mention that it would be great for you to consider these
in current or future work, be it in your comprehensive plan, development code, and SMP updates, and in your work in
general:
Consider adding a reference to the definition of geologically hazardous areas, WAC 365-190-120, in other areas
besides the CAO. In addition, consider adding a reference to WAC 365-196-480 for natural resource lands.
Consider adding in other areas besides the CAO. If you have not checked our interactive database, the
Washington Geologic Information Portal, lately, you may wish to do so. Geologic Information Portal | WA - DNR
If you have not checked out our Geologic Planning page, you may wish to do so. Geologic Planning | WA - DNR
Thank you for considering our comments. If you have any questions or need additional information, please contact me.
For your convenience, if there are no concerns or follow-up discussion, you may consider these comments to be final as
of the 60-day comment deadline of 11/24/25.
Have a great day!
Tricia
Tricia R. Sears (she/her/hers)
Geologic Planning Liaison
Washington Geological Survey (WGS)
Washington Department of Natural Resources (DNR)
Cell: 360-628-2867 | Email: tricia.sears@dnr.wa.gov