HomeMy WebLinkAboutSR_Renton High School_HEX Report_260106_FINAL.pdfDEPARTMENT OF COMMUNITY
AND ECONOMIC DEVELOPMENT
SR_Renton High School_HEX Report_260106_FINAL
A. REPORT TO THE HEARING EXAMINER
Hearing Date: January 13, 2026
Project File Number: PR25-000065
Project Name: Renton High School Replacement and Site Expansion
Land Use File
Number:
LUA25-000343, PUD, CU-H, LC
Project Manager: Alex Morganroth, Principal Planner
Owner: Renton School District, Office of the Executive Director, 7812 S 124th St,
Seattle, WA 98178
Applicant: Brianne Tomlin, Renton School District, 7812 S 124th St, Seattle, WA 98178
Contact: Lisa Klein, AHBL, Inc., 2215 N 30th St, Suite 200, Tacoma, WA 98403
Project Location: 400 S 2nd St, Renton, WA 98057 (APN 0007200060) and Parcel Nos.
7229300490, 7229300545, 7229300580, 7229300595, 7229300630,
7229300635, 0007200016, 0007200017, 0007200033, 0007200034,
0007200035, 0007200036, 0007200037, 0007200038, 0007200039,
0007200040, 0007200041, 0007200043, 0007200072, 0007200078,
0007200079, 0007200108, 0007200110, 0007200114, 0007200127,
0007200128, 0007200167, 0007200171, 0007200179, 0007200214,
5696000140, 5696000145, 5696000150, 5696000155, 5696000160,
5696000165, 5696000169, 5696000170, 5696000180, 5696000185,
5696000190, 3806000065.
Project Summary: The applicant, the Renton School District, is requesting Preliminary and Final
Planned Urban Development approval and a Conditional Use Permit to
reconstruct and expand the Renton High School campus at 400 S 2nd St (APN
0007200060 and 42 acquisition parcels, see parcel numbers above). The site is
approximately 35.2 acres and is developed with the original 1931 school
building, an annex classroom building, gymnasium, Ikea Center for the
Performing Arts (IPAC), sports fields, and associated surface parking. The site
also includes the former Renton High School vocational training building which
currently serves as the Renton School District central warehouse. The applicant
proposes to expand the site through the on-going acquisition of approximately
42 single-family and commercial properties on the block bounded by Logan Ave
S, S Tobin St, Shattuck Ave S, and Airport Way, as well as two (2) properties off of
Lake Ave S. The 42 properties total approximately ten (10) acres in area. Upon full
acquisition of the additional properties, the site will have zoning designati ons of
Commercial Arterial (CA), Center Downtown (CD), and Residential-8 (R-8). The
site will also be located in Urban Design Districts A and D. The applicant
proposes to preserve and renovate approximately 93,500 square feet of existing
buildings (the original 1931 building and IPAC), demolish the remaining
structures, and construct a new 310,000 square foot three -story classroom
building and three (3) small accessory buildings totaling 6,270 square feet. Upon
completion, the campus will total approximately 409,770 square feet of building
area, include 476 parking spaces, and a new bus load/unload zone along Logan
Ave S. Vehicular access is proposed via two (2) driveways on S 2nd St, one (1)
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 2 of 70
SR_Renton High School_HEX Report_260106_FINAL
driveway on Lake Ave S, and gated/event access at Logan Ave S and S Tobin St,
with pedestrian circulation improved through frontage improvements and off -
site intersection upgrades. The project also includes athletic field lighting poles
up to 77 feet (77’) in height. The site is mapped with a high seismic hazard and
both Downtown Wellhead Protection Areas Zones 1 and 2. The site is also within
the Renton Municipal Airport Overlay. Approximately 4,900 cubic yards (CY) of
cut and 33,000 CY of fill are proposed. A Tree Retention Plan identifies 212
significant trees, of which 28 will be retained. The applicant submitted a
Geotechnical Report, Transportation Technical Report, Arborist Report,
Technical Information Report, and Critical Areas Report with the application.
Construction of the new campus will be phased with work beginning in summer
2026 with parking and frontage improvements, followed by construction of the
new high school starting September 2026. The new building is expected to open
in fall 2028. Demolition of existing buildings and completion of athl etic fields,
parking, and frontage improvements will occur in 2028–2029, with final site work
continuing through September 2030.
Site Area: 35.2 acres
Project Location Map
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 3 of 70
SR_Renton High School_HEX Report_260106_FINAL
B. EXHIBITS:
Exhibit 1: Staff Report to the Hearing Examiner
Exhibit 2: Neighborhood Detail Map
Exhibit 3: Site Plan
Exhibit 4: Floor Plans
Exhibit 5: Civil Plans
Exhibit 6: Conceptual Landscape Plans
Exhibit 7: Architectural Elevations
Exhibit 8: Architectural Renderings
Exhibit 9: Photometrics Plan
Exhibit 10: Screening Plan
Exhibit 11: Tree Retention Plan
Exhibit 12: Tree Retention/Land Clearing Plan, prepared by Atlas Technical Consultants LLC,
dated September 4, 2025
Exhibit 13: Technical Information Report, prepared by AHBL, Inc., dated September 2025
Exhibit 14: Subsurface Exploration, Geologic Hazard, and Geotechnical Engineering Report,
prepared by Associated Earth Sciences, Inc., dated September 3, 2025
Exhibit 15: Transportation Technical Report, prepared by Heffron Transportation Inc, dated
September 16, 2025
Exhibit 16: Lighting Study, prepared by Musco Sports Lighting, LLC, dated September 12, 2025
Exhibit 17: Tree Retention and Credit Worksheet
Exhibit 18: Construction Mitigation Description
Exhibit 19: Neighborhood Meeting Packet
Exhibit 20: Conditional Use Permit Justification, prepared by Applicant, dated September 16,
2025
Exhibit 21: South 2nd Street Improvement Waiver Request, prepared by Applicant, dated
September 5, 2025
Exhibit 22: Transportation Concurrency Memo, prepared by Nathan Janders, dated December
11, 2025
Exhibit 23: Federal Aviation Administration (FAA) No Hazard to Air Navigation Determination
Letter, dated April 22, 2025
Exhibit 24: SEPA Environmental Checklist and MDNS Notice of Consultation, Checklist dated
September 12, 2025
Exhibit 25: SEPA Mitigated Determination of Non-Significance (MDNS), issued November 5,
2025
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 4 of 70
SR_Renton High School_HEX Report_260106_FINAL
Exhibit 26: City of Renton SEPA Comment Letter, dated November 19, 2025
Exhibit 27: SEPA Modified Mitigated Determination of Non-Significance (MDNS), dated
December 2, 2025
Exhibit 28: Becker Public Comment Letter, received on December 9, 2025
Exhibit 29: King Public Comment Email, dated October 22, 2025
Exhibit 30: City Response Email to Becker Comment Letter, dated December 10, 2025
Exhibit 31: City Response Email to King Comment Email, dated October 27, 2025
Exhibit 32: Advisory Notes
C. GENERAL INFORMATION:
1. Owner(s) of Record: Renton School District, Office of the Executive
Director, 7812 S 124th St, Seattle, WA 98178
2. Zoning Classification: Commercial Arterial (CA)), Center Downtown (CD),
Residential-8 (R-8)
Urban Design District ‘A’, Urban Design District ‘D’,
City Center Sign Regulation Area
3. Comprehensive Plan Land Use
Designation: Commercial Mixed Use (CMU)
Residential Medium Density (RMD)
4. Existing Site Use: Renton High School campus
5. Critical Areas: High Seismic Hazard Area and Downtown Wellhead
Protection Area Zones 1 and 2
6. Neighborhood Characteristics:
a. North:
Renton Municipal Airport, Single-Family Residential and Commercial/Retail/Office.
Industrial Medium (IM) zone, Residential-8 (R-8) zone, Employment Area (EA) land
use designation, and Residential Medium Density (RMD) land use designation
b. East:
Commercial/Retail/Office, Single-Family Residential and Multifamily Residential.
Center Downtown (CD) zone and Commercial Mixed Use (CMU) land use
designation
c. South: Retail and Multifamily Residential, Center Downtown (CD) zone, Commercial
Arterial (CA) zone, and Commercial Mixed Use (CMU) land use designation
d. West:
Single-Family Residential and Commercial/Retail/Office, Residential-8 (R-8),
Commercial Arterial (CA) zone, and Residential Medium Density (RMD) land use
designation
7. Site Area: 35.2 acres
D. HISTORICAL/BACKGROUND:
Action Land Use File No. Ordinance No. Date
Comprehensive Plan N/A 6153 01/01/2025
Zoning N/A 6160 06/24/2025
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 5 of 70
SR_Renton High School_HEX Report_260106_FINAL
Annexation (Incorporation) A-00-000 0 09/06/1901
Site Plan Review, Conditional
Use Permit, and Modification
LUA23-000355 N/A 05/19/2024
Temporary Use Permit LUA21-000336 N/A 10/07/2021
Site Plan Review and
Modification
LUA20-000111 N/A 08/31/2020
Temporary Use Permit LUA01-106 N/A 08/12/2001
Temporary Use Permit LUA00-058 N/A 06/09/2000
Site Plan Review and Variance LUA99-120 5813 02/07/2000
E. PUBLIC SERVICES:
1. Existing Utilities
a. Water: Water service will be provided by the City of Renton. The project site is located within the
Valley 196 Pressure Zone, with approximate static pressures ranging from 69 to 71 psi. Public
water mains serving and surrounding the site include a 12 -inch (12”) ductile iron main in S 2nd
St, a 12-inch (12”) cast iron main in S Tobin St, a 10-inch (10”) ductile iron main along the
southern segment of Logan Ave S, a 12-inch (12”) ductile iron main along the northern segment
of Logan Ave S, an 8-inch (8”) cast iron main in Airport Way, an 8-inch (8”) ductile iron main in
Shattuck Ave S, and an 8-inch (8”) cast iron main in Lake Ave S. Multiple existing domestic,
irrigation, and fire service meters currently serve the campus.
b. Sewer: Sewer service will be provided by the City of Renton. Existing sanitary facilities include a
15-inch (15”) PVC trunk main and associated manholes running through the western portion of
the campus within an easement and connecting to the sewer main within S Tobin St. Additional
8-inch (8”) PVC sewer mains are located in Logan Ave S, S Tobin St, and Shattuck Ave S, all of
which connect to the downstream system in S Tobin St. A private 8 -inch (8”) PVC main located
south of the IPAC building currently serves portions of the campus.
c. Surface/Storm Water: The site is served by multiple public and private stormwater conveyance
systems located within adjacent streets and across the existing campus. Stormwater systems
include a 12-inch (12”) concrete main in Airport Way discharging toward the Cedar River, 24-inch
(24”) concrete mains in Logan Ave S, a 12-inch (12”) PVC main in S 2nd St, and a 24-inch (24”)
PVC main in Lake Ave S, as well as private onsite systems conveying runoff toward S Tobin St.
The site drains to both the Black River and Lower Cedar River basins. The eastern portion of the
site is located within Wellhead Protection Area Zone 1, where open infiltration facilities and
stormwater ponds are prohibited, while the western portion lies within Zone 2, where lined or
limited-capacity facilities may be required.
2. Streets: The project site fronts Airport Way, S Tobin St, Logan Ave S, S 2nd St, S Tillicum St, Lake Ave
S, and Shattuck Ave S, which together serve a range of neighborhood and regional travel functions.
S 2nd St is classified as a five-lane Principal Arterial with an existing right-of-way (ROW) width ranging
from approximately 60 to 90 feet (60-90’); it is also listed as a City TIP project, with future
improvements coordinated through a separate City capital project. Airport Way is classified as a six-
lane Principal Arterial with an existing ROW of approximately 80 feet (80’). Logan Ave S is classified
as a two-lane Minor Arterial with an existing ROW of approximately 60 feet (60’) and is subject to
downtown streetscape standards. Lake Ave S, S Tobin St, and Shattuck Ave S are each classified as
Residential Access streets, with ROW widths generally ranging from approximately 50 to 60 feet (50-
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 6 of 70
SR_Renton High School_HEX Report_260106_FINAL
60’). S Tillicum St is classified as a public alley, with a ROW width that varies between approximately
10 feet (10’) and 50 feet (50’). The proposal includes a combination of right-of-way dedications,
frontage improvements, and the vacation of approximately 800 linear feet (800’) of S Tobin St and S
Tillicum St, between Shattuck Ave S and Logan Ave S, to support site circulation, access
management, and redevelopment of the expanded campus, with final design and phasing to be
coordinated through civil construction permitting. The sections of street proposed for vacation are
each approximately 810 linear feet (810’). Consideration of the vacation application by City Council
would occur after issuance of the subject land use decision.
3. Fire Protection: Renton Regional Fire Authority (RRFA)
F. APPLICABLE SECTIONS OF THE RENTON MUNICIPAL CODE:
1. Chapter 2 Zoning Districts – Uses and Standards
a. Section 4-2-020: Purpose and Intent of Zoning Districts
b. Section 4-2-060: Zoning Use Table – Uses Allowed in Zoning Designations
c. Section 4-2-110: Residential Development Standards
d. Section 4-2-120: Commercial Development Standards
2. Chapter 3 Environmental Regulations and Overlay Districts
a. Section 4-3-050: Critical Areas Regulations
b. Section 4-3-100: Urban Design Regulations
c. Section 4-3-020: Airport Related Height and Use Restrictions
3. Chapter 4 City-Wide Property Development Standards
4. Chapter 6 Streets and Utility Standards
a. Section 4-6-060: Street Standards
b. Section 4-6-070: Transportation Concurrency Requirements
5. Chapter 7 Subdivision Regulations
a. Section 4-7-060: Detailed Procedures for Lot Line Adjustments
6. Chapter 9 Permits – Specific
a. Section 4-9-030: Conditional use Permits
b. Section 4-9-150: Planned Urban Development Regulations
7. Chapter 11 Definitions
G. APPLICABLE SECTIONS OF THE COMPREHENSIVE PLAN:
1. Land Use Element
2. Transportation Element
3. Climate and Resilience
4. Capital Facilities
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 7 of 70
SR_Renton High School_HEX Report_260106_FINAL
H. FINDINGS OF FACT (FOF):
1. The Planning Division of the City of Renton accepted the above master application for review on
October 8, 2025 and determined the application complete on October 14, 2025. The project
complies with the 170-day review time period.
2. Public notice for the Notice of Application and Notice of Public Hearing was provided in accordance
with the requirements of RMC 4-8-090, Public Notice Requirements. Upon deeming the land use
application complete, the City issued a Notice of Application, which was mailed to the applicant,
property owner, and to all property owners and tenants of record within three hundred (300) feet of
the subject property. The Notice of Application was also posted on the City’s website and on notice
boards located at the project site and City Hall, consistent with RMC 4-8-090C. A neighborhood
meeting facilitated by the applicant was held on August 6, 2025, at the Renton High School Library
(400 S 2nd St, Renton, WA 98055). The meeting consisted of a formal presentation at 6:00 p.m.,
followed by an open house, as described in the neighborhood meeting notice poster. The sign -in
sheet indicates at least ten (10) attendees, including nearby residents and a representative from the
City of Renton. Questions and comments generally focused on construction timing, safety during
school operations, traffic circulation, residential property acquisitions, athletic field use, lighting,
and parking (Exhibit 19).
3. The project site is located at 400 S 2nd St, Renton, WA (APN 0007200060 and 42 associated
acquisition parcels), generally bounded by Airport Way to the north, Logan Ave S to the east, S 2nd
St to the south, and Shattuck Ave S/Lake Ave S to the west. The site consists of the existing Renton
High School campus along with multiple adjoining properties proposed for consolidation as part of
the project (Exhibits 2 and 3).
4. The applicant intends to request vacation of portions of S Tobin St and S Tillicum St, along the
northern edge of the campus, to allow the project to unify circulation, accommodate the proposed
athletic field layout, and provide safer internal pedestrian connections. Street vacations are
processed under a separate review and approval procedure and require City Council action
following a recommendation from the Planning Division and other affected departments.
Consideration of the vacation request would occur after issuance of the land use decision and is not
guaranteed as part of PUD/CUP approval. If the City Council approves the vacation, any conditions
placed on that approval (including compensation, easements, or reservations for utilities or public
access) would be required to be satisfied prior to final construction permitting or recording, as
applicable. If the vacation is not approved, the applicant would be required to modify the site plan
accordingly through formal revision process to maintain public right-of-way function and access.
5. The project site is presently developed with the existing Renton High School campus, including the
historic school building constructed in 1931, the IKEA Performing Arts Center (IPAC), classroom
buildings, gymnasium, sports fields, parking areas, and district warehouse facilities, along with the
remaining single-family residences and commercial structures located within the identified
acquisition area. The proposal includes the demolition of most existing structures, renovation of
select historic facilities, and redevelopment of the expanded campus (Exhibits 2-8).
6. Vehicular access to the redeveloped campus would be provided by multiple site driveways,
including three (3) primary access points off of S 2nd St and three (3) gated access points off Logan
Ave S, S Tobin St/Shattuck Ave S, and Lake Ave S. A designated bus load/unload area is proposed
along Logan Ave S, and internal circulation would be provided via new drive aisles and parking lots.
Pedestrian access would be provided through frontage improvements and enhanced crossings,
consistent with City standards and project phasing (Exhibit 3).
7. The site is located within the Commercial & Mixed Use (CMU) and Residential Medium Density (RMD)
Comprehensive Plan land use designations.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 8 of 70
SR_Renton High School_HEX Report_260106_FINAL
8. The site contains multiple zoning classifications, including Commercial Arterial (CA), Center
Downtown (CD), and Residential-8 (R-8). Because no dwelling units would be developed on the site,
the applicant would be exempt from the Residential Design and Open Space Standards Renton
Municipal Code (RMC) 4-2-115B.1.
9. According to the Tree Retention/Land Clearing Plan (Arborist Report) submitted by the applicant,
there are approximately 212 significant trees located within the project limits (Exhibit 12). The
applicant proposes to retain 28 significant trees, with the remaining trees proposed for removal to
accommodate building construction, circulation improvements, athletic facilities, and utility
installation.
10. According to City of Renton (COR) Maps, the site is mapped with a High Seismic Hazard and both
Downtown Wellhead Protection Areas Zones 1 and 2.
11. Approximately 4,900 cubic yards of cut and 33,000 cubic yards of fill are proposed for the project
(Exhibits 5 and 24).
12. The applicant is proposing to begin construction of the new school campus in the summer of 2026
and would finish approximately four (4) years later in 2030. The project would be constructed in
multiple coordinated phases beginning in summer 2026 and continuing through 2030. Early Phase 1
work (2026–2027) focuses on construction of the west parking lot and frontage improvements,
maintaining access to the food service loading dock, abandoning S Tobin St where vacated,
demolishing the auxiliary locker room, and installing underground utilities for the new building.
Phase 2 (2026–2028) includes construction of the new three-story high school building, followed by
development of new softball and baseball fields in 2028. Phase 3 (2028–2029) includes demolition
of existing school buildings and the gym, renovation of the existing track and field, renovation of the
historic 1930 building facade and the IPAC, construction of a new service entry and teacher parking,
and continued site improvements. Final Phase 3C work (2029) includes relocation and demolition of
food services facilities and completion of remaining athletic and site amenities, w ith final site work
extending into 2030 consistent with the applicant’s phasing plan (Exhibits 18 and 24).
13. Staff received two (2) public comment letters on the application (Exhibits 28 and 29). One (1) letter
expresses concerns regarding the submitted traffic study while the other letter notes support of the
project. Staff provided responses to each comment (Exhibits 30 and 31).
14. The full proposal consists of a Planned Urban Development, a Conditional Use Permit, a Lot
Combination, and a street vacation for the construction of a new 310,000 square foot, three-story
classroom building and three (3) small accessory buildings totaling 6,270 square feet. Upon
completion, the campus will total approximately 409,770 square feet of building area, include 476
parking spaces, and a new bus load/unload zone along Logan Ave S. The project also includes
athletic field lighting poles up to 77 feet (77’) in height.
15. The applicant has requested the Preliminary Planned Urban Development and Final Planned Urban
Development be combined into a single decision as permitted in RMC 4 -9-150H.1.
16. The Renton School District acted as lead agency for the State Environmental Policy Act (SEPA)
Review for the project. On November 5, 2025, the Renton School District issued a Mitigated
Determination of Non-Significance (MDNS) for the Renton High School Replacement and Site
Expansion (Exhibit 25). A 14-day comment period commenced on November 5, 2025 and ended on
November 19, 2025. Comments received during the comment period, including timely comments
from the City of Renton (Exhibit 26), resulted in the Renton School District issuing a modified MDNS
on December 2, 2025 (Exhibit 27). The modified MDNS included 13 mitigation measures. No
comments, aside from agency comments, were received on the threshold determination according
to the Renton School District. The Renton School District issued a Notice of Action to conclude the
appeal period on January 2nd, 2026. No appeals were filed.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 9 of 70
SR_Renton High School_HEX Report_260106_FINAL
17. Requested Modifications from RMC through the PUD: The site comprises of multiple residential
and commercial zoning designations that have development standards which vary significantly. It is
not possible to develop the proposed high school school on the property without deviating from
many of the standards. Therefore, a PUD is being requested to allow for flexibility in order to
construct the public facility that meets the educational needs of the School District, but also is
complimentary to the site and neighborhood in which it is located. When approving a PUD, the City
may modify those standards listed in RMC 4-2, 4-4, 4-7, and RMC 4-6-060 Street Standards, except
as listed in RMC 4-9-150B.3. All of the following modifications are required to be considered
simultaneously as part of the planned urban development:
RMC Code Citation Required Standard Modification
RMC 4-2-100 Zoning
Standards Tables
There are three (3) separate
tables dealing with the various
zones (R-8, CA, and CD) which
contain the minimum and, in
some cases, maximum
requirements of the zone.
The application of a single
zoning classification (CD) and
corresponding Design District
‘A’ for the entire site for the
purposes of review.
RMC 4-2-120A
Development Standards
for Commercial Zones
Maximum secondary front yard
setback along a street is 15 feet,
or 25 feet for any portion of a
building over 25 feet.
Library portion of the building is
setback greater than 25 feet in
order to provide space for
landscape buffer along Logan
Ave S.
RMC 4-2-120A
Development Standards
for Commercial Zones
If the CD lot abuts a lot zoned
residential, then there shall be a
15-foot landscaped strip or a 5-
foot wide sight-obscuring
landscaped strip and a solid 6-
foot high barrier along the
common boundary with an
additional 5-foot setback from
the barrier.
Widths of buffer abutting to
residential vary from 8 to 15
feet; existing fence type varies
from chain-link to solid board.
RMC 4-2-120A
Development Standards
for Commercial Zones
Max height is 150 feet, or 20 feet
more than the maximum height
allowed in the abutting
residential zone (44 feet based
on abutting R-8 zone).
Building is 65 feet tall and field
lights range between 46 and 75
feet tall.
RMC 4-3-100 Urban
Design Districts (Surface
Parking Location)
No surface parking between a
building and the front or side
street. Parking must be
screened by buildings or
landscaping.
Student drop-off lane and
parallel visitor parking located
between the IPAC and S 2nd St,
with screening provided
primarily through site design
and landscaping.
RMC 4-3-100 Urban
Design Districts (Vehicular
Access Location)
Parking should be accessed
from alleys or side streets rather
than primary streets.
Student and visitor
parking/drop-off accessed
primarily from S 2nd St, with
secondary access from Lake
Ave S.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 10 of 70
SR_Renton High School_HEX Report_260106_FINAL
RMC 4-3-100 Urban
Design Districts (Surface
Parking)
Parking areas shall be fully
screened from adjacent streets.
Student parking lot is located
adjacent to the side of the
1930s building and adjacent to
S 2nd St. It is partially screened
with the exception of areas
where the sidewalk is
expanded.
RMC 4-3-100 Urban
Design Districts
(Recreation Areas and
Common Open Space)
Provide at least three (3) lineal
feet of seating area (bench,
ledge, etc.) or one individual
seat per sixty (60) square feet of
plaza area or open space.
The proposal is required to
provide 17,813 SF of common
open space (17,849 SF
provided), which requires 297
seats or 892 LF of seating. The
proposal is providing 260 LF/17
seats.
RMC 4-3-100 (Ground
Level Details)
Any facade visible to the public
shall be comprised of at least
seventy five percent (75%)
transparent windows and/or
doors for at least the portion of
the ground floor facade that is
between four feet (4') and eight
feet (8') above ground (as
measured on the true elevation).
The Logan Ave facade (2,843 SF
of ground floor facade) has 53
percent (53%) transparency.
RMC 4-4-070 (Street
Frontage Landscaping)
10 feet of on-site landscaping to
be provided along public street
frontages (i.e., Airport Way,
Shattuck Ave S, and S Tobin St,
which are not in the CD zone).
Variable 5 to 10 feet of
landscaping provided along
Airport Way; Other frontages
meet code.
RMC 4-4-070 (Landscape
Buffers)
10-foot fully sight-obscuring or
15-foot partially sight-obscuring
buffer required along shared
property lines when a
commercial zone abuts a
residential zone.
Applicable on S Tobin St where
abutting residential. Widths of
buffer adjacent to residential
vary from 8 to 15 feet; existing
fence type varies from chain-
link to solid board.
RMC 4-4-040 (Fence
Height)
Fences within 15 feet of
front/secondary yards ≤ 48
inches; chain-link prohibited in
CD zone (unless vinyl-coated).
Outfield chain-link fences (with
wind screens) up to 8 feet tall
along Airport Way and Logan
Ave S, located approximately 5
feet from property line.
Ornamental fencing up to 6 to 8
feet provided along street
frontages.
RMC 4-4-090 (Refuse &
Recycling Enclosures)
Enclosures must have 6-foot
walls, 12-foot minimum gate
width, and 15-foot vertical
clearance.
Refuse enclosure walls are
proposed at 11 to 12 feet, with
8-foot gate panels and vertical
clearances of 11 to 12 feet.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 11 of 70
SR_Renton High School_HEX Report_260106_FINAL
RMC 4-4-090 (Screening of
Refuse Areas)
Enclosures must be surrounded
by a 6-foot wall or fence.
Refuse areas enclosed with 11-
foot and 12-foot high walls and
10.5 to 11 foot gates to screen
equipment and serve adjacent
mechanical yard.
RMC 4-4-090 (Refuse Area
Gate Width & Clearance)
Minimum 12-foot-wide gate
opening with 15-foot vertical
clearance.
Gate openings reduced to 8
feet (6.5 feet for smaller
dumpsters) with enclosure roof
clearances of 10.5 to 12 feet
due to scale and operational
constraints.
RMC 4-4-130 (Tree
Retention and Land
Clearing Regulations)
Administrator may allow fee-in-
lieu of tree replacement.
Allow for potential off-site
planting to supplement fee-in-
lieu replacement.
RMC 4-6-060 (Streets) 12-foot-wide sidewalk on all
streets in the City Center
Planning Area. The sidewalk
width includes street tree grates
for locating street trees.
Sidewalk widths vary from 5
feet to 8 feet on frontages,
except for 12 feet on Logan Ave
S (a pedestrian street) and on S
2nd St the existing sidewalk is
to remain until the City
improvement project.
18. Representatives from various city departments have reviewed the application materials to identify
and address issues raised by the proposed development (Exhibit 32). These comments are
contained in the official file, and the essence of the comments has been incorporated into the
appropriate sections of this report and the Departmental Recommendation at the end of this report.
19. Comprehensive Plan Compliance: The site is designated Error! Reference source not found. on
the City’s Comprehensive Plan Map. The purpose of the CMU designation is to allow residential uses
as part of mixed-use development and supports new office and commercial development that is
more intensive than what exists to create a vibrant district and increase employment opportunities.
The intention of this designation is to transform strip commercial development into business
districts through the maximization of uses and with cohesive site planning, landscaping, signage,
circulation, parking, and the provision of public amenity features. The proposal is compliant with the
following development standards if all conditions of approval are met:
Compliance Comprehensive Plan Analysis
✓
Policy LU-2: Support compact urban development to improve health outcomes,
support transit use, maximize land use efficiency, and maximize public investment
in infrastructure and services.
✓
Policy LU-37: Development in areas subject to flooding, seismic, geologic, and
coal mine hazards should be designed to prevent property damage and
environmental degradation before, during, and after construction.
✓ Goal LU-BB: Ensure new development supports a high quality of life with design
that is functional and attractive.
✓ Goal LU-FF: Strengthen the visual identity of Renton and its Community Planning
Areas and neighborhoods through quality design and development.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 12 of 70
SR_Renton High School_HEX Report_260106_FINAL
✓ Policy LU-48: Consider scale and context for infill project design to preserve
privacy and quality of life for residents.
✓
Policy LU-49: Encourage the creation and maintenance of places and events
throughout the community where people can gather and interact. Allow for
flexibility in public gathering places to encourage place-making efforts and
activities.
✓
Policy LU-51: Require human-scale features such as pedestrian pathways, quality
landscaping, and public spaces that have discernible edges, entries, and borders
to create a distinctive sense of place in neighborhoods, commercial areas, and
centers.
✓ Policy LU-52: Require buildings in developments to be oriented toward the street
or a common area, rather than toward parking lots.
✓
Policy LU-56: Complement the built environment with landscaping using native,
naturalized, and ornamental plantings that are appropriate for the situation and
circumstance and provide for respite, recreation, and sun/shade.
✓ Policy LU-59: Balance the need for appropriate lighting levels for safety and
security to avoid light intrusion and glare impacts, and to preserve the night sky.
✓ Policy LU-60: Require landscaping and screening to improve the appearance of
parking lots, promote green infrastructure, and reduce heat islands.
✓ Policy LU-65: Coordinate with tribes and recognize their treaty rights.
✓
Goal TR-B: Balance transportation needs with other community values and needs
by providing facilities that promote vibrant commerce, clean air and water, and
health and recreation.
✓ Policy TR-11: Limit direct access onto arterials when access opportunities via
another route exist.
✓ Policy TR-24: Support vacating streets when they meet the criteria in Renton
Municipal Code, Chapter 14, Vacations.
✓ Policy TR-28: Ensure provision of safe and convenient storage and parking
facilities for cyclists.
✓
Policy CR-28: Identify and plan for climate impacts to essential and valued
community assets such as schools, libraries, parks, and other social service,
cultural, and community centers.
✓
Policy CF-12: Coordinate with federal, state, regional and local jurisdictions,
private industry, businesses and citizens in the planning, design and development
of facilities serving and affecting the community.
20. Zoning Development Standard Compliance: Pursuant to RMC 4-9-150D.4, each Planned Urban
Development (PUD) must demonstrate compliance with the applicable underlying zoning standards
unless a modification has been specifically requested and justified through the PUD process. The
subject site consists of multiple zoning designations, including Center Downtown (CD), Commercial
Arterial (CA), and Residential-8 (R-8). The proposed campus redevelopment locates the primary
school building entirely within the CD-zoned portion of the site, while the athletic fields, track,
courts, parking areas, and associated campus infrastructure extend across the CA and R-8 zoned
areas on the northern portion of the site.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 13 of 70
SR_Renton High School_HEX Report_260106_FINAL
Through the PUD, the applicant requests that the development standards of the CD zone and the
Urban Design District A standards be applied to the project as a whole. Strict adherence to three (3)
separate sets of zoning and design standards would create fragmented site design, conflicting
frontage expectations, and inconsistent circulation and building relationships that are incompatible
with a unified K-12 educational campus. Applying a single coherent standard allows the building and
site to function cohesively, while still meeting or exceeding the overall intent of the underlying zones
(see FOF 17: Requested Modifications from RMC through the PUD).
The CD zoning designation is appropriate as the primary regulatory framework because the school
building fronts the urban corridor, supports pedestrian -oriented design elements, and is located
within an area envisioned for higher -intensity public, institutional, and mixed-use activity. In
addition, much of the site, including the entire footprint of the proposed new high school building
and existing IPAC and 1931 building are located in the CD zone. The CD zone’s purpose is to promote
an urban, connected development pattern that accommodates significant public-serving uses,
supports multimodal transportation, and integrates with surrounding downtown -oriented growth.
Staff supports application of the CD development standards and Urban Design District A standards
to the full campus provided all recommended conditions of approval are satisfied (see FOF 22: PUD
Decision Criteria and Analysis). The table that follows identifies the project’s compliance with the
applicable CD development standards contained in RMC 4-2-120B, as modified through the PUD.
The purpose of the CD zone is to provide a mixed-use urban commercial center serving a regional
market as well as high-density residential development. Uses include a wide variety of retail sales,
services, multi-family residential dwellings, and recreation and entertainment uses. The proposal is
compliant with the following development standards, as outlined in RMC 4 -2-120B, if all conditions
of approval are met:
Compliance CD Zone Develop Standards and Analysis
Compliant if
the Condition
Use Permit is
Approved, see
FOF 27 for
Analysis
Use: The applicant proposes to replace and expand the existing Renton High
School campus with a new three-story educational building, integrated with the
existing 1930s building and IKEA Performing Arts Center (IPAC), and to
reconfigure and enhance associated parking, circulation, plazas, and athletic
facilities (including new and improved baseball, softball, multi-purpose, and
court facilities). A planned urban development may not authorize uses that are
inconsistent with those uses allowed by the underlying zones.
Staff Comment: K-12 educational institutions are permitted in the CD, CA, and
R-8 zones through a Hearing Examiner Conditional Use Permit. See FOF 27:
Conditional Use Permit Analysis.
N/A
Density: The density range permitted in the CD zone is a minimum of 75 up to a
maximum of 150 dwelling units per net acre. Density may be increased to 200
dwelling units per net acre subject to conditional use permit approval.
Staff Comment: No dwelling units are proposed.
N/A
Lot Dimensions: There are no minimum lot size, width or depth requirements in
the CD zone.
Lot Coverage: No maximum lot coverage in the CD zone.
Staff Comment: Not applicable.
Compliant if
Modified per
Setbacks: There is no minimum front yard setback. The maximum front yard
setback is 15 feet for that portion of the building that is 25 feet or less in height.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 14 of 70
SR_Renton High School_HEX Report_260106_FINAL
the PUD
Regulations
There is no minimum secondary front yard setback. The maximum secondary
front yard setback is 15 feet for that portion of the building that is 25 feet or less
in height. There is no minimum rear yard setback, unless the ground floor facade
provides windows for living rooms of attached dwellings – then 10 ft. – unless
adjacent to an alley, then none. Additionally, if the CD lot abuts a lot zoned
residential, then there shall be a 15 ft. landscaped strip or a 5 ft. wide sight -
obscuring landscaped strip and a solid 6 ft. high barrier along the common
boundary with an additional 5 ft. setback from the barrier. There is no minimum
side yard setback, unless the ground floor facade provides living room windows
of attached dwellings – then 10 ft. – unless adjacent to an alley, then none.
Additionally, if the CD lot abuts a lot zoned residential, then there shall be a 15
ft. wide landscaped strip or a 5 ft. wide sight -obscuring landscaped strip and a
solid 6 ft. high barrier along the common boundary with an additional 5 ft.
setback from the barrier.
Staff Comment: The project is proposed to be built across the common
boundaries of the multiple parcels that make up the site. Therefore, staff
recommends as a condition of approval, the applicant shall record a formal Lot
Combination to ensure the proposed buildings are not built across property
lines. The Lot Combination shall include all high school campus parcels as part
of the project. The instrument shall be recorded prior to the issuance of
Temporary Certificate of Occupancy.
Building setbacks would be measured from the property lines established
following the Lot Combination recording, which would be the exterior lines
adjacent to Airport Way, Logan Ave S, S 2nd St, Shattuck Ave S, and Lake Ave S.
Due to the location of the building on a lot with multiple street frontages, front
yard setbacks would be applied (north, south, east, and west along Shattuck Ave
S) in-lieu of the typical rear or side yard setbacks. Rear yard setbacks would
apply to the exterior lines adjacent to the other properties abutting the site north
and west of the proposed track and existing tennis courts.
Along S 2nd St, the primary academic building is set back approximately 30 feet
(30’) from the future right-of-way, exceeding the CD maximum. The applicant
requests a PUD deviation to allow this increased setback, explaining that the
additional space is necessary to accommodate a required fire lane, provide safe
pedestrian circulation and an entry plaza that functions as required common
open space, and align the new structure with the remaining buildings. Staff
agrees these components are functional elements rather than unused
separation and finds that the expanded setback still creates an active, cohesive
campus frontage while maintaining public-safety access. Staff supports this
deviation because it meets the intent of the CD standards by organizing
circulation, reinforcing pedestrian activity, and integrating new and existing
campus facilities.
Four (4) athletic-field light poles are located within approximately one foot (1’) of
the secondary front yard frontages along Logan Ave S and Airport Way. These
poles have been carefully sited to retain existing trees, allow the Airport Way
sidewalk to shift south to protect the canopy, comply with Federal Aviation
Administration (FAA) airspace height constraints, maintain regulation athletic-
field dimensions, and minimize light spill onto adjacent properties. Although this
portion of the site is zoned CA, the PUD applies CD standards across the project.
Because the CD zone establishes no minimum secondary front yard along a
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 15 of 70
SR_Renton High School_HEX Report_260106_FINAL
street, the light poles comply, and no deviation is required.
The library wing of the building is proposed with a maximum setback of
approximately 70 feet (70’) from Logan Ave S, exceeding the CD maximum
secondary frontage standard. The applicant requests a PUD deviation and
explains that this setback is intentionally designed to orient a fully glazed facade
toward a landscaped “forested” feature, creating a quiet library environment
and supporting building modulation and articulation required under Urban
Design District A. Staff finds that the additional setback functions as intentional
public-realm design rather than residual space and enhances both visual
character and usability. Staff supports the deviation, subject to detailed
landscape and facade plans confirming that the space remains activated and
visually engaging.
The three (3) buildings on the northern portion of the site, including a
concessions building, maintenance building, and storage building, are set back
approximately 67 feet (67’) from Shattuck Ave S at the nearest point and
approximately 305 feet (305’) from Airport Way. These buildings also exceed the
maximum front or secondary front yard setbacks for the CD zone, for which the
applicant requests a PUD deviation. Staff supports the deviation because the
increased setbacks are driven by functional campus design rather than
unnecessary separation. Locating these small support structures farther from
the street allows the primary athletic fields to occupy the central portion of the
site, maintains large contiguous open areas, and reduces potential conflicts
between service/sport activities and pedestrians. The greater setback also
provides space for a landscaped buffer along both street frontages, which helps
soften views, limits noise and activity spillover, and preserves a campus -like
character appropriate for a high school setting. Given the site’s unique
programming needs and the overall benefits to circulation, buffering, and
campus organization, staff finds that the requested deviation meets the intent of
the development standards and is appropriate under the PUD.
Where the site abuts residential zoning near the northwest edge of the site, the
applicant proposes variable buffer widths ranging from approximately 8 to 15
feet (8-15’), rather than a uniform buffer with additional setback. According to
the applicant, the deviation accommodates existing fences and vegetation,
preserves important tree cover, and allows the athletic fields to function at
regulation size. Staff finds that the combination of existing fencing and
vegetation provides an appropriate visual transition. Staff supports the
deviation, with the expectation that supplemental planting be added where
feasible to strengthen screening along residential edges.
Overall, as modified through the PUD, the proposed setbacks meet the intent of
the CD standards by balancing pedestrian orientation, emergency access,
functional athletic programming, and compatibility with surrounding residential
uses. Final conformance would be verified with civil and building permit review.
Compliant if
Modified per
the PUD
Regulations
Maximum Building Height: The maximum building height permitted is 150 feet,
except when abutting a residential zone, then the maximum height is 20 feet
more than the maximum height allowed in the abutting residential zone. Heights
may exceed the maximum height with a Hearing Examiner conditional use
permit.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 16 of 70
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Staff Comment: In the CD zone, the maximum building height is 150 feet (150’);
however, where a CD-zoned site abuts a residentially zoned lot, the maximum
permitted height is limited to 20 feet (20’) above the maximum allowed height of
the abutting residential zone. The subject site abuts R -8 zoning along the
northwest corner, where the maximum height is 24 feet (24’). Accordingly, the
maximum allowed height on the portions of the school property abutting an R-8
zoned property is 44 feet (44’) unless otherwise modified.
The applicant requests a PUD deviation to allow the primary school building to
reach a total height of approximately 65 feet (65’) to the top of the mechanical
penthouse, with an average building height of approximately 48 feet (48’). The
applicant explains that additional height is necessary to accommodate modern
instructional program needs, interior commons spaces, and mechanical
systems while maintaining a compact three-story footprint that reduces overall
site coverage, preserves open space, and allows the building to cluster toward
internal campus areas rather than spread closer to residential edges. The
stepped massing, modulation, and placement of taller elements are
intentionally oriented away from the most sensitive edges and paired with
landscaping and buffers to help soften visual impact.
Athletic field lighting is proposed at heights ranging from approximately 46 feet
(46’) to 77 feet (77’). Pole locations were intentionally sited to minimize light spill,
retain existing trees, maintain regulatory athletic field dimensions, and comply
with FAA airspace constraints due to proximity to the Renton Municipal Airport.
A submitted photometric analysis demonstrates that off-site glare and light
trespass are controlled to levels consistent with City standards, and the poles
are oriented toward the interior of the campus rather than toward adjacent
residential or commercial lots (Exhibit 16).
Staff finds that the requested building and lighting heights are functionally
necessary for the school program and that the combination of building
placement, modulation, buffering, and lighting controls mitigates potential
visual and compatibility impacts associated with exceeding the 44-foot (44’)
height limit. Staff supports the deviation because it achieves a more efficient site
design, concentrates height toward the campus core near the intersection of S
2nd St and Logan Ave S, and remains compatible with surrounding development
patterns while meeting the broader purposes of the CD zone.
The subject site is located within the Airport Influence Area associated with the
Renton Municipal Airport (RNT) and is therefore subject to federal height review
under Federal Aviation Regulations (FAR) Part 77, “Objects Affecting Navigable
Airspace.” Part 77 establishes imaginary airspace surfaces around airports,
including the Horizontal Surface, which generally extends outward from the
airport at a constant elevation above the established airport elevation, and
serves to limit the height of structures that may pose navigational hazards. The
Renton Municipal Airport overlay requires that development within this area
demonstrate compatibility with airport operations, including compliance with
Part 77 height restrictions.
The applicant submitted an FAA Form 7460 Notice of Proposed Construction,
and the Federal Aviation Administration completed an Aeronautical Study for the
high school building improvements and associated structures (Exhibit 23). As
documented in the FAA’s Determination of No Hazard to Air Navigation, the FAA
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 17 of 70
SR_Renton High School_HEX Report_260106_FINAL
evaluated the proposed maximum structure height of approximately 64 feet AGL
and compared it against applicable Part 77 surfaces, including the Horizontal
Surface applicable to the site. The FAA concluded that the proposed project
does not constitute a hazard to air navigation, subject to standard conditions.
These conditions include marking and lighting of the building consistent with
FAA Advisory Circular 70/7460-1, as well as filing FAA Form 7460-2 prior to and
upon completion of construction. The determination also specifies that
temporary construction equipment exceeding evaluated heights must be
separately reviewed.
The FAA determination confirms that the building height does not penetrate the
Part 77 Horizontal Surface in a manner that would create a navigational hazard,
and therefore complies with the applicable federal airspace height limitations.
The determination also notes that the site will continue to be exposed to routine
aircraft activity and associated aviation noise due to its proximity to the airport,
but that such exposure does not alter the height determination. Based on the
FAA’s review and determination, staff finds that the project satisfies airport-
related height and airspace safety requirements, provided the applicant
complies with all FAA conditions contained in Exhibit 23.
Final conformance with approved height limits would be verified at building
permit review.
✓
Special Development Standards – Upper Story Setbacks: None, unless
adjacent to and facing a residentially zoned lot or if the facade contains living
room windows – then 10 ft. for the second story and 15 ft. for all upper stories.
Staff Comment: The building mass is intentionally concentrated toward the
interior and primary street frontages, with the primary building proposed over
800 feet (800’) from the abutting residentially zoned lots along S Tobin St. In
addition, large intervening areas including athletic fields, plazas, landscaped
buffers, and circulation, create separation greater than what would otherwise be
required through a strict upper-story step-back requirement. Staff finds this
approach meets the intent of the upper -story transition standard while
maintaining campus functionality.
Complaint if
Modified per
the PUD
Regulations
Landscaping: The City’s landscape regulations (RMC 4-4-070) require a 10-foot
landscape strip along all public street frontages. Additional minimum planting
strip widths between the curb and sidewalk are established according to the
street development standards of RMC 4-6-060. Street trees and, at a minimum,
groundcover, are to be located in this area when present. Spacing standards
shall be as stipulated by the Department of Community and Economic
Development, provided there shall be a minimum of one street tree plant ed per
address. Any additional undeveloped right-of-way areas shall be landscaped
unless otherwise determined by the Administrator.
All surface parking shall have a perimeter landscaping screen at least 10 feet in
width as measured from the street right-of-way. Surface parking lots with 15 or
more spaces shall provide interior parking lot landscaping.
Projects abutting less intensive zones and use are required to provide a
landscape buffer. When a commercial zoned lot or use is abutting a residential
zone, a 15-foot-wide partially sight-obscuring landscaped visual barrier, or 10-
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 18 of 70
SR_Renton High School_HEX Report_260106_FINAL
foot-wide fully sight-obscuring landscaped visual barrier, is required along the
common property line.
Pervious areas, with the exception of critical areas, shall have landscape
treatment. Landscaping may include hardscape such as decorative paving, rock
outcroppings, fountains, plant containers, etc.
Staff Comment: The applicant submitted Conceptual Landscape Plans (Exhibit
6) and an accompanying narrative demonstrating a layered approach to
landscaping that serves multiple purposes including campus identity, screening
and buffering, circulation definition, and enhancement of key gathering and
recreation areas. Landscaping is distributed throughout the site, rather than
concentrated in only a few areas, and is intentionally used to soften the scale of
the building and athletic facilities while maintaining visibility and safety
appropriate for a school environment.
Along the public street frontages, landscaping functions as both a unifying
streetscape element and a transition between public sidewalks and the school
campus. Street trees, shrubs, and groundcover are proposed along Logan Ave S,
Airport Way, and S 2nd St, generally consistent with City spacing and layering
expectations, while avoiding conflicts with utilities, lighting, and sight-distance
requirements. Where frontage improvements require wider sidewalks or curb
relocations, planting zones shift inward onto school property but continue to
read as part of the streetscape edge. The design reflects the PUD emphasis on
integration with the surrounding neighborhood and avoids creating long
expanses of unrelieved pavement along the block faces.
Landscaping is also strategically used to buffer adjacent residential areas,
particularly along the west and northwest edges where the campus abuts R-8
zoned properties. In these locations, the plan incorporates existing mature
vegetation where feasible and supplements it with new evergreen and
deciduous trees, layered shrub plantings, and understory groundcovers to form
a continuous visual screen. Tree species were selected in order to ensure they
do not impact airport operations at maturity. The buffer width varies (generally 8
to 15 feet), but the plant palette is designed to mature into a dense, partially
sight-obscuring edge while still allowing periodic visibility for safety. Staff notes
that while the buffer does not consistently achieve the full 15-foot (15’) width
prescribed by standard CD regulations, the combination of existing vegetation
retention, added trees, and the low-intensity nature of the practice field use
provides a functional and context-appropriate transition. Therefore, staff
supports the applicant’s request for a PUD modification to allow for a reduced
buffer along the residential zoned lots abutting the site.
Within the interior of the campus, landscaping organizes space and enhances
usability. Pedestrian plazas abutting Logan Ave S and along S 2nd St, interior
student courtyards, and the primary building entry areas along S 2nd St include
decorative paving, planters, canopy trees, and integrated seating to create
comfortable gathering places. Plantings are arranged to frame views and
provide shade while avoiding obstruction of surveillance or conflicts with
student circulation. The library facade abutting Logan Ave S intentionally opens
toward a “forested” landscape element with shade and evergreen trees,
reinforcing the quiet character of that program space and providing a strong
visual and environmental connection between indoor learning areas and
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 19 of 70
SR_Renton High School_HEX Report_260106_FINAL
outdoor green space. Landscaping is also proposed in the various surface
parking lots on the site, including both interior and perimeter landscape areas.
Compliance with the parking lot landscaping requirements would be verified at
the time of formal building permit application review.
Around the athletic fields, landscaping plays a secondary but important
supportive role. Trees and shrubs are placed at the outer edges of fencing to
soften the field perimeter and reduce light spill perception while maintaining
clear zones required for field operations and safety. The plan balances screening
needs with the practicalities of turf maintenance, spectator movement, and
emergency access. Where light poles and walkways coincide, low shrubs and
groundcover species are used to prevent conflicts wi th pole bases and wiring
while still creating a softened, finished appearance.
Landscaping in the Logan Ave S, Airport Way, and S 2nd St ROWs is designed to
complement frontage improvements and provide a cohesive streetscape
around the campus. Small street trees, low shrubs, and groundcover are
proposed along the primary frontages, with species selected for durability,
drought tolerance, and compatibility with existing utilities and sight-distance
requirements. Street tree species were not indicated and are expected to be
selected prior to permit application. Planting areas are coordinated with
sidewalks, lighting, and pedestrian crossings to ensure clear visibility and safe
movement. Along Airport Way, plant height and spacing respond to FAA and
safety constraints while still providing visual softening and continuity of the tree
canopy. Where wider planting strips exist, layered landscaping creates
additional buffering between the roadway and school activity areas.
On site, landscaping is integrated with stormwater management features where
feasible, adding ecological function alongside aesthetic value. Planted swales
and rain-tolerant groundcovers are positioned in select drainage areas,
consistent with Low Impact Development. These features help reduce runoff
while contributing to overall campus greening. Overall, staff finds that the
landscape concept is thoughtful, functional, and consistent with the intent of
RMC 4-4-070 to provide site-wide greening, neighborhood compatibility, and
visual relief from buildings and paved areas. The plan effectively balances
screening, safety, and maintenance considerations appropriate for a high
school campus, while also supporting the PUD objective of treating the site as a
unified design rather than separate zoning segments.
A detailed landscape and irrigation plan will be required at civil construction
permit submittal and shall include final plant species, spacing, sizes, irrigation
details, fence/wall coordination, sight-distance protection, and any revisions
needed to ensure long-term screening success adjacent to residential
properties. A final detailed landscape plan will be reviewed and approved by the
Current Planning Project Manager in accordance with RMC 4-4-070 prior to civil
permit issuance.
Tree Retention: The City’s adopted Tree Retention and Land Clearing
Regulations (RMC 4-4-130) require the retention of 30 percent of trees in a
commercial development. Tree credit requirements shall apply at a minimum
rate of thirty (30) credits per net acre based on values for existing or new trees
as provided in RMC 4-4-130H.1.b.v.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 20 of 70
SR_Renton High School_HEX Report_260106_FINAL
Complaint if
Modified per
the PUD
Regulations
and if
Condition of
Approval is
Met
Significant trees shall be retained in the following priority order:
Priority One: Landmark trees; significant trees that form a continuous canopy;
significant trees on slopes greater than twenty percent (20%); significant trees
adjacent to critical areas and their associated buffers; and significant trees over
sixty feet (60') in height or greater than eighteen inches (18”) caliper.
Priority Two: Healthy tree groupings whose associated undergrowth can be
preserved; other significant native evergreen or deciduous trees; and other
significant non-native trees.
Priority Three: Alders and cottonwoods shall be retained when all other trees
have been evaluated for retention and are not able to be retained, unless the
alders and/ or cottonwoods are used as part of an approved enhancement
project within a critical area or its buffer.
Staff Comment: The applicant submitted a Tree Retention/Land Clearing Plan
(Arborist Report) prepared by Atlas Technical Consultants LLC, dated
September 4, 2025 (Exhibit 12). The report evaluates trees located within and
immediately adjacent to the project site. The report identifies 212 significant
trees, of which 29 meet the definition of landmark trees based on size and
species. Species represented on the site include a mix of native conifers and
deciduous trees, as well as several ornamental species commonly associated
with prior urban development. Notable species include Douglas fir, European
hornbeam, shore pine, Western red cedar, and London plane.
The arborist evaluated each tree for health, structure, and feasibility of retention
considering the proposed grading, utility connections, athletic field layout, and
building placement. As described in the report, retention feasibility is
constrained by several overlapping factors including substantial regrading
necessary to create level building and playfield areas; retaining wall placement
near existing tree root zones; conflicts with underground utilities, walkways, and
stormwater infrastructure; proximity to required fire access and pedestrian
circulation routes; and declining health or structural defects in several existing
trees.
Based on this analysis, the arborist concludes that retention opportunities are
extremely limited, and the plan proposes the retention of 28 trees primarily
located along the S 2nd St frontage, the Airport Way frontage, and along the north
and west edges of the site near the proposed athletic fields. Where removal is
proposed near property boundaries, the plan intentionally preserves off -site
trees and supplements them with new buffer plantings to maintain screening for
adjacent residential properties.
Under RMC 4-4-130, the project is required to retain a minimum of 30 percent
(30%) of significant trees, excluding those located in future right-of-way
dedication, those deemed hazardous, or those within critical areas. Based on a
developable site area of 33.2 acres, a minimum of 1,008 (33.6 x 30 = 1,008) tree
credits are required and a minimum retention of approximately 64 trees is
required (212 x 0.3 = 64). Based on a total of 28 retained trees, the applicant is
proposing a retention rate of approximately 13.2 percent (13.2%) (28 / 212 =
13.2%). The 28 trees proposed for retention total approximately 197 tree credits,
or 811 less than required by code.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 21 of 70
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The combination of the school building footprint, athletic fields, associated
circulation, utilities, grading, and FAA and athletic-field safety constraints limits
opportunities to retain trees in place or accommodate full on-site replacement.
As a result, the required canopy cannot feasibly be achieved entirely on site
without compromising essential school functions and previously established
circulation and safety objectives. To ensure appropriate mitigation for the credit
shortfall, staff supports allowing tree replacement requirements to be met
through a combination of approaches, including, in order of preference: on-site
planting where feasible, off-site planting on other Renton School District
properties within the City, and payment of fee-in-lieu to the City’s Urban Forestry
Program. Off-site planting has the potential to provide meaningful
neighborhood-level canopy benefits, enhance walkability and shade on school
campuses, and add ecological value in locations where students and
community members directly experience the improvement. Off-site planting
locations and species would be reviewed for consistency with RMC 4 -4-130,
long-term survivability, and maintenance responsibility. Where remaining tree
credits cannot reasonably be planted on City or school properties, the balance
would be satisfied through fee-in-lieu, calculated using the market value of trees
and installation costs, as determined by the City. Staff finds that this blended
mitigation approach achieves the intent of Renton’s tree retenti on standards by
providing long-term canopy replacement, while recognizing the operational and
design constraints unique to a large, multi-field school campus. Therefore, staff
recommends as a condition of approval, the applicant shall mitigate the deficit
in required tree credits in the following order of preference: (1) tree planting on -
site to the maximum extent feasible; (2) tree planting on other Renton School
District properties located within the City of Renton; and (3) payment of fee-in-
lieu for any remaining credits that cannot reasonably be accommodated through
on-site or off-site planting. Prior to civil construction permit issuance, the
applicant shall submit a Tree Credit Mitigation Plan identifying proposed planting
locations, tree species and sizes, total credit values, installation and
maintenance responsibilities, and the number of remaining credits (if any) to be
satisfied by fee-in-lieu. Off-site planting locations shall be reviewed and
approved by the Current Planning Project Manager, and any remaining fee-in-
lieu amount shall be paid in full prior to issuance of the Temporary Certificate of
Occupancy.
The applicant proposes a comprehensive replanting plan that distributes new
trees throughout the campus, including the residential buffer areas, pedestrian
plazas, field perimeters, and along public frontages. Replacement trees include
a mix of large-canopy native conifers, deciduous shade trees, and climate-
tolerant species, consistent with the City’s preferred tree list and spacing
guidance. At maturity, this planting strategy would restore and, in several
locations, increase canopy coverage compared with existing fragmented tree
conditions. Staff finds that this approach is consistent with the intent of RMC 4 -
4-130, which is to maintain long-term canopy, mitigate visual impacts, and
improve environmental function, while also recognizing the operational space
needs of an active school campus.
During construction, trees on adjacent properties must be protected consistent
with RMC 4-4-130H.9-10, including installation of six-foot (6’) chain-link tree
protection fencing at the dripline (or as otherwise recommended by the arborist),
prohibition of construction storage within fenced areas, protection from grade
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 22 of 70
SR_Renton High School_HEX Report_260106_FINAL
changes, and periodic arborist monitoring. Final tree protection notes and
details shall be included on the civil construction plans.
`✓
Parking: Parking regulations for Senior high schools: public, parochial and
private require a minimum and maximum of 1.0 per employee plus 1.0 space for
every 10 students enrolled. In addition, if buses for the private transportation of
children are kept at the school, 1.0 off-street parking space shall be provided for
each bus of a size sufficient to park each bus.
Standard parking stall dimensions are 8 feet by 20 feet, parallel stall spaces are
20-feet by 8-feet, and compact stall dimensions are 8 ½ feet by 16 feet.
Compact parking spaces shall not account for more than 30-percent of the total
number of spaces.
Accessible parking shall be provided per the requirements of the Washington
State Barrier Free Standards as adopted by the City of Renton.
Staff Comment: Under RMC 4-4-080F.10.e, parking for high schools is
calculated at one (1) space per employee plus one (1) space for every ten (10)
students enrolled. Based on an estimated 1,600 students (160 spaces) and
approximately 150 full- and part-time staff (150 spaces), the required parking for
the school component is 310 stalls. Because four (4) small buses would be kept
on-site, four (4) bus parking spaces are also required. Parking for the district
administrative offices located in the 1930s building is calculated at one (1)
space per 1,000 square feet of gross floor area. With approximately 76,000
square feet of office use, a total of 76 spaces would ordinarily be required;
however, no minimum is required for commercial uses in the CD zone, resulting
in a code range of zero (0) to 76 possible required spaces. Finally, parking for the
outdoor and indoor athletic and assembly facilities is calculated at one (1) space
for every four (4) fixed spectator seats or one (1) space per 1,000 square feet of
assembly space, whichever is greater. With 551 fixed spectator seats, the
athletic facilities require 138 parking spaces. When all applicable uses are
considered together, the combined parking obligation for the site ranges from
approximately 448 to 524 off-street stalls (depending on whether district office
parking is counted at the high end of the optional range ). The proposal provides
476 striped vehicle spaces, plus an additional 48 convertible event spaces,
resulting in a total functional capacity of 524 stalls and demonstrating
compliance with the City’s parking standards for joint-use facilities.
The applicant proposes to provide on-site parking that is distributed across
functional areas of the campus to clearly separate staff parking, student parking,
visitor/event use, and bus operations. The student parking lot contains
approximately 275 striped spaces, located west of the main academic building
and oriented to support daily student use while retaining internal pedestrian
connections to campus destinations. A dedicated staff parking area with 179
stalls is provided in proximity to building entries to accommodate faculty and
administrative employees. An additional 22 spaces are located within the
internal drive loop on S 2nd St, functioning as short-term or convertible spaces
that can be flexibly managed depending on event or operational needs. Se veral
small parking clusters are also provided for maintenance and operational
vehicles.
Parallel parking spaces are proposed along the frontage near the existing IPAC
building, supporting administrative and short-term visitor needs and dispersing
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 23 of 70
SR_Renton High School_HEX Report_260106_FINAL
peak demand during events. Although this area constitutes surface parking, it is
integrated into the right-of-way frontage design with sidewalks and landscaping
and does not place parking between the building and the street, consistent with
the intent of the development standards.
Bus parking and operations are accommodated separately from general
vehicular parking. The site plan identifies 21 bus loading bays along Logan Ave S
for drop-off and pick-up movements only, along with four (4) dedicated on-site
bus parking spaces for small buses. These bus facilities are physically separated
from student pedestrian paths and general vehicular traffic to improve
circulation safety and reduce potential conflicts.
Overall, the project provides 476 parking stalls (including student, staff, and
administrative parking). When the 48 convertible stalls associated with the
internal drive loop and managed spaces are included, the total available supply
increases to 524 spaces. Therefore, the proposal satisfies the minimum
requirement while remaining within the maximum allowable range for
institutional school uses. The applicant’s transportation analysis confirms that
on-site capacity will accommodate daily and special-event parking demands
without resulting in significant spillover to neighboring streets. Final striping,
ADA compliance, and signage would be reviewed and approved with the civil
construction permit.
`Compliance
Not Yet
Demonstrated
Bicycle Parking: The number of bicycle parking spaces shall be equal to ten
percent (10%) of the number of required off-street vehicle parking spaces; for
uses in the CD zone that do not require off-street vehicle parking, the number of
bicycle parking spaces shall be equivalent to ten percent (10%) of off-street
vehicle parking spaces required for the same use located outside of the CD
zone. Each space is required to meet the bicycle parking standards per RMC 4-
4-080F.11.c.
Staff Comment: Bicycle parking is provided consistent with RMC 4-4-080, which
requires bicycle facilities equal to ten percent (10%) of the required vehicle
parking, or 45 stalls (10% of 448 stalls = 44.8). The applicant proposes a
combination of short-term and long-term bicycle racks placed in strategic
locations across the site to support both daily commuting and recreational use.
Short-term racks are located near primary student and visitor entries and
adjacent to outdoor gathering spaces, allowing convenient bicycle access
without conflicting with pedestrian circulation. These racks are visible, well -lit,
and located within active areas of the site, which improves security and
encourages use. Long-term bicycle parking is proposed closer to staff access
points and within secure zones of the campus, providing sheltered options for
employees and students who may bike regularly. By integrating bicycle facilities
into pedestrian plazas rather than isolated service areas, the project supports
the Comprehensive Plan’s emphasis on multimodal transportation and Safe
Routes to School objectives. Staff finds that the proposed bicycle parking
locations and quantities are appropriate for the size of the campus and would
encourage non-vehicular trips by students, staff, and visitors.
All racks are required to meet dimensional standards for spacing, support, and
maneuvering area, allowing bicycles to be locked by frame and wheel.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 24 of 70
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Placement avoids conflicts with required landscaping, sight-distance triangles,
ADA routes, and emergency access.
Final bicycle parking details including total number of spaces, rack
specifications, and weather-protection features would be confirmed at the time
of building and civil permit review to ensure full compliance with RMC 4-4-
080F.11.
Compliant if
Modified
through PUD
Regulations
Fences and Retaining Walls: A maximum of eight feet (8') anywhere on the lot
provided the fence, retaining wall or hedge does not stand in or in front of any
required landscaping or pose a traffic vision hazard.
There shall be a minimum three-foot (3') landscaped setback at the base of
retaining walls abutting public rights-of-way.
Staff Comment: The proposal includes a combination of security fencing,
ornamental fencing, athletic field fencing, and site retaining walls associated
with grading transitions and program areas. Along Airport Way and Logan Ave S,
the applicant proposes outfield fencing associated with the athletic fields
consisting of black-coated chain-link with wind screening at a height of
approximately eight feet (8’), located about five (5’) feet from the property line.
These fences are intended to provide player safety, accommodate regulation
play space, and withstand impacts typical of athletic use. The applicant is
requesting a PUD deviation because the proposed height exceeds the 48-inch
(48”) height limit otherwise applicable within 15 feet (15’) of secondary front
yards (along Airport Way). The applicant states that the increased fence height
is an operational necessity tied to sports safety and field layout, while still
maintaining adequate setbacks, landscaping, and visual openness toward the
street environment.
In addition, ornamental metal fencing is proposed in select pedestrian-oriented
areas, including a six-foot (6’) tall fence along Shattuck Ave S, Logan Ave S, and
Lake Ave S street frontages, with setbacks ranging from approximately 7.5 to 20
feet (7.5-20’), depending on the area. One (1) segment of ornamental fencing in
front of the library reaches eight feet (8’) in height and is intentionally designed
as part of the landscaped “forested” feature intended to frame quiet outdoor
study space. This feature functions as both a safety perimeter and a design
element reinforcing the campus’s civic character.
Interior property line fencing adjacent to residential areas would largely retain
existing fences and vegetation, consistent with the applicant’s stated goal of
minimizing disturbance while maximizing available field area. Retaining walls
across the site are generally limited in height and used to address grade
transitions; the geotechnical report anticipates retaining walls at or under four
feet (4’) in height where feasible, with design parameters provided for any
locations requiring additional wall height above four feet (4’). Retaining walls are
primarily proposed behind the existing 1931 administrative building near the
staff parking lot.
Staff finds that the combination of ornamental fencing, strategic screening,
safety considerations at athletic fields, and limited retaining wall use meets the
functional needs of the campus while maintaining compliance with design intent
for urban civic campuses. The requested fence-height deviations are
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 25 of 70
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appropriately reviewed under the PUD process, where operational necessity,
safety, and visual treatment can be balanced against strict code standards.
Compliant if
Modified
through PUD
Regulations
Refuse and Recycling: A Per RMC 4-4-090, office, educational and institutional
developments require a minimum of two (2) square feet per every one thousand
(1,000) square feet of building gross floor area be provided for recyclables
deposit areas and a minimum of four (4) square feet per one thousand (1,000)
square feet of building gross floor area shall be provided for refuse deposit
areas. A total minimum area of one hundred (100) square feet shall be provided
for recycling and refuse deposit areas.
Refuse, recyclables, and compostables deposit areas and collection points
associated with nonresidential uses shall not be located within fifty feet (50') of
a lot zoned residential, except by approval through the site development plan
review process, or through the modification process if exempt from site
development plan review.
Enclosures for outdoor refuse, recyclables, or compostables deposit
areas/collection points and separate buildings used primarily to contain a
refuse, recyclables, or compostables deposit area/collection point shall have
gate openings at least twelve feet (12') wide for haulers. In addition, the gate
opening for any separate building or other roofed structure used primarily as a
refuse, recyclables, or compostables deposit area/collection point shall have a
vertical clearance of at least eleven feet (11'), but no more than fourteen feet
(14').
Staff Comment: Based on the proposal for a total of 403,610 square feet of gross
floor area, 2,422 square feet of refuse and recycle area is required to be provided
(403,610 / 1000 x 6 = 2,422). The proposal includes two (2) areas, including 405
square foot area and a 2,639 sq. ft. area, both of which are direclty north of the
existing IPAC building, which complies with the area dedication requirements.
The enclosures are located adjacent to the staff parking lot in a central location
to all on-site buildings and complies with the 50-foot (50’) separation from
residential lots. The proposed refuse and recycling area is intended to support
daily school operations, kitchen functions, and service deliveries. Consistent
with RMC standards for enclosed service yards, the main refuse enclosure is
fully screened on all sides with masonry walls, metal gates, and a roof. The
applicant is requesting a PUD deviation to allow wall heights ranging from 11 feet
to 12 feet (11’–12’) and gate heights between approximately 10.5 feet and 11 feet
(10.5’ and 11’), which exceed the typical six-foot (6’) screening requirement.
Gate widths are proposed at approximately eight feet (8’) each, and vertical
clearance within the enclosure ranges from approximately 10.5 feet to 11.5 feet
(10.5’ – 11.5’), which starts at less than the standard vertical clearance of at
least 11 feet (11') but is no more than 14 feet (14').
According to the applicant, the increased wall height is intended to provide
effective screening from nearby residential properties, support the adjacent
mechanical yard, and better shield students from truck operations. The reduced
roof height and modified gate clearances respond to the site’s scale, limited
truck frequency, and operational reality that dumpsters will be manually moved
in and out for service. The applicant notes that refuse service typically occurs
twice per week, with limited on-site truck activity, and that staff-controlled
access improves safety and reduces conflicts with student circulation. Staff
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 26 of 70
SR_Renton High School_HEX Report_260106_FINAL
supports approval of a PUD deviation to allow for taller wall heights around the
enclosure and a smaller vertical clearance than typically required.
The smaller refuse and recycling enclosure is located in proximity to the culinary
kitchen, cafeteria, server, and receiving area (loading docks) for functional
efficiency, while still being screened from public streets and buffered from
pedestrian pathways. The larger warehouse refuse and recycling enclosure is
proposed between a generator area to the west and a transformer area to the
east (Exhibits 3, 5, 6, and 10). Landscaping is provided between the surface
parking and the refuse and recycling/utility enclosure areas, consistent with
service yard screening standards.
Staff finds that the proposed refuse and recycling location meets operational
needs, enhances safety, and provides screening that exceeds baseline
aesthetic expectations for large institutional service areas. The deviations
requested are best evaluated under the PUD framework, where functional
necessity and long-term campus design quality may be balanced.
Compliant if
Condition of
Approval is
Met
Screening: All onsite surface mounted utility equipment shall be screened from
public view. Screening shall consist of equipment cabinets enclosing the utility
equipment, solid fencing or a wall of a height at least as high as the equipment
it screens, or a landscaped visual barrier allowing for reasonable access to
equipment. Equipment cabinets, fencing, and walls shall be made of materials
and/or colors compatible with building materials. All operating equipment
located on the roof of any building shall be enclosed so as to be screened from
public view.
Staff Comment: Screening throughout the project incorporates a layered
strategy of vegetation, fencing, building modulation, and integrated service
enclosures. Utility equipment, garbage and recycling facilities, and mechanical
yards are fully enclosed and screened on all sides using masonry walls and
secured gates, consistent with RMC expectations for urban civic facilities.
Chain-link fencing is limited to athletic field fencing only and is coated and
supplemented with landscape treatments where visible from public streets.
Screening is also incorporated into campus -wide site design through the
strategic use of tree plantings, the “forested” library courtyard, building
modulation, and avoidance of large blank walls on public -facing facades.
Retaining walls visible from public streets include architectural treatment
consistent with Design District guidelines, helping ensure that utilitarian
features integrate into the broader civic design vocabulary.
Overall, while staff finds that screening techniques reduce the visual impacts of
service functions, athletic infrastructure, and utility features while strengthening
the project’s civic and pedestrian orientation, some areas were difficult to
analyze, and staff was unable to determine whether all equipment was properly
screened. Therefore, staff recommends, as a condition of approval, the
applicant shall submit a surface mounted utility plan that includes cross-section
details with the civil construction permit application. The applicant shall work
with franchise utilities to ensure, as practical, utility boxes are located out of
public ROW view, active common open spaces, and they shall not displace
required landscaping areas. The plan shall provide and id entify screening
measures consistent with the overall design of the development. The surface
mounted utility plan shall be reviewed and approved by the Current Planning
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 27 of 70
SR_Renton High School_HEX Report_260106_FINAL
Project Manager prior to permit issuance. In addition, staff recommends as a
condition of approval, that the applicant be required to submit a rooftop
equipment exhibit with the elevation plans associated with the building permit
application. The exhibit shall provide cross section details and identify proposed
rooftop screening that is integral and complementary to the architecture of the
buildings. The exhibit shall be reviewed and approved by the Current Planning
Project Manager.
N/A
Planned Action Ordinance and Master Plan Consistency:
Staff Comment: Not applicable. The subject property is not located in a Planned
Action Ordinance area and no Master Plan for the site is in effect .
21. PUD Applicability Standards: Pursuant to RMC 4-9-150B, any applicant seeking to permit
development which is not limited by the strict application of the City’s zoning, parking, street, and
subdivision regulations in a comprehensive manner shall be subject to applicability standards. The
following table contains project elements intended to comply with applicability standards, as
outlined in RMC 4-9-150B:
Compliance PUD Applicability Criteria and Analysis
Compliant
if all
Conditions
of Approval
are Met
In approving a planned urban development, the City may modify any of the
standards of RMC 4-2, RMC 4-3-100, chapter 4-4 RMC, RMC 4-6-060, and
chapter 4-7 RMC. All modifications shall be considered simultaneously as part
of the planned urban development.
Staff Comment: All standards requested to be modified are contained within
FOFs 20 and 25. Specific modifications are noted in FOF 17.
Compliant
if
Conditions
of Approval
are Met
An applicant may request additional modifications from the requirements of the
Renton Municipal Code. Approval for modifications, other than those specifically
described in subsection RMC 4-9-150B.2.a, shall be approved prior to submittal
of a preliminary planned urban development plan.
Staff Comment: All eligible modifications are outlined above under FOF 17. Staff
is in support of all requested modifications if all conditions of approval are met.
✓
A planned urban development may not authorize uses that are inconsistent with
those uses allowed by the underlying zone, or overlay district, or other location
restriction in RMC Title 4, including, but not limited to: RMC 4-2-010 to 4-2-080,
4-3-010 to 4-3-040, 4-3-090, 4-3-095, and 4-4-010.
Staff Comment: Pursuant to RMC 4-2-060 Zoning Use Table, K-12 educational
institutions are permitted in the R-8, CA, and CD zones with an approved
Conditional Use Permit. See FOF 27 for Conditional Use Permit analysis.
N/A
The number of dwelling units shall not exceed the density allowances of the
applicable base or overlay zone or bonus criteria in chapter 4-2 or 4-9 RMC;
however, averaging density across a site with multiple zoning classifications may
be allowed if approved by the Community and Economic Development
Administrator.
Staff Comment: Not applicable. No dwelling units are proposed.
22. PUD Decision Criteria Analysis: Pursuant to RMC 4-9-150D, each planned urban development
shall demonstrate compliance with the Planned Urban Development decision criteria. The following
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 28 of 70
SR_Renton High School_HEX Report_260106_FINAL
table contains project elements intended to comply with the Planned Urban Development decision
criteria, as outlined in RMC 4-9-150D:
Compliance PUD Decision Criteria and Analysis
✓
Demonstration of Compliance and Superiority Required: Applicants must
demonstrate that a proposed development is in compliance with the purposes of
this Section and with the Comprehensive Plan, that the proposed development
will be superior to that which would result without a planned urban development,
and that the development will not be unduly detrimental to surrounding
properties.
Staff Comment: If the conditions of approval are met, the applicant will have
demonstrated compliance with the Planned Urban Development regulations and
the Comprehensive Plan. The applicant will also have demonstrated that the
development is superior to that which would occur under standard zoning
requirements and that the requested deviations will not be detrimental to
surrounding properties. The use of the PUD provisions for the Renton High School
Replacement and Site Expansion Project allows for an integrated, campus-scale
design solution that balances building orientation, pedestrian movement,
circulation, safety, and site programming in a way that would not be achievable
under strict application of the development standards.
The proposed project replaces an aging and functionally outdated high school
campus with a modernized facility that continues to serve the same student
population while better supporting academic, athletic, and community needs.
Unlike a new school built in an unserved area, t his project reinforces the historic
role of Renton High School within the downtown and surrounding neighborhoods,
while improving safety, accessibility, and environmental performance. The PUD
enables a site design that orients buildings, plazas, and primary entries toward
surrounding streets and public spaces, consistent with Comprehensive Plan
Policy LU-52, which calls for buildings to face streets or common areas rather
than parking lots. The project also incorporates pedestrian pathways, plazas,
landscaping, and outdoor gathering areas that create clear edges, entries, and
identifiable public spaces, consistent with Policy LU -51 and Goal LU-FF, which
emphasize human-scale design and enhancement of community identity.
Without the flexibility provided through the PUD, the campus would be
constrained by multiple zoning districts, frontage standards, and dimensional
requirements that would fragment circulation and reduce opportunities for
cohesive open space and safety-focused campus organization. The PUD allows
coordinated placement of the new high school building, renovation of the 1930
historic structure, and arrangement of athletic facilities in a manner that supports
secure internal circulation, improved pedestrian connectivity, and clear
hierarchy of vehicular and bus movements. These features result in a more
functional and unified campus than would otherwise occur.
The requested modifications primarily relate to parking and circulation
placement, fencing height, and landscaping transitions, all of which are
integrated into an overall design strategy intended to improve student safety,
operational efficiency, and neighborhood compatibility. The development is
located within an existing school site surrounded by a mix of commercial,
institutional, and residential uses. The redevelopment maintains school use in
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 29 of 70
SR_Renton High School_HEX Report_260106_FINAL
this location, improves visual quality along S 2nd St and Logan Ave S, and
provides enhanced pedestrian connections while buffering athletic activities
where feasible. For these reasons, the proposed project represents a superior
design outcome when compared to development under strict application of the
code, and the requested deviations are not anticipated to be unduly detrimental
to surrounding properties.
Public Benefit Required: Applicants shall demonstrate that a proposed development will
provide specifically identified benefits that clearly outweigh any adverse impacts or undesirable
effects of the proposed planned urban development, particularly those adverse and undesirable
impacts to surrounding properties, and that the proposed development will provide one or more
of the following benefits than would result from the development of the subject site without the
proposed planned urban development:
Staff Comment: The proposed Renton High School Replacement Project provides several public
benefits that exceed what could reasonably be provided through conventional development
under standard zoning regulations. As a public educational facility, the project supports long -
term community investment, academic achievement, and equitable access to learning
opportunities for current and future students. The redevelopment replaces outdated facilities
with modernized classrooms, career-technical education spaces, science labs, arts and athletic
facilities, and support services designed to meet contemporary educational needs. These
improvements contribute directly to community well-being and help implement the City’s
adopted goals related to quality public services, neighborhood vitality, and downtown
reinvestment.
The PUD allows a comprehensive campus design that improves circulation, safety, and
connectivity beyond what would otherwise occur. The project includes a clear separation of bus
traffic, general vehicular access, and pedestrian movement; enhanced frontage improvements
and pedestrian crossings; and reconfigured site access that reduces conflicts between vehicles
and pedestrians. These design features promote safer walking and biking routes for students and
the larger community. The campus also incorporates plazas, outdoor gathering areas,
landscaping, and improved athletic and recreational facilities that can support school functions
as well as community events and youth programs, thereby extending the public benefit beyond
the school day.
The project retains and rehabilitates the historic 1930 Renton High School building, preserving
an important cultural and architectural landmark that contributes to the City’s identity. The
preservation effort, combined with new construction designed to complement the surrounding
urban context, strengthens neighborhood character, and supports Comprehensive Plan policies
related to design quality and sense of place. Additionally, the project consolidates fragmented
parcels, improves stormwater management, and upgrades utilities and infrastructure in ways
that would not be triggered by maintaining the existing campus in its current condition.
Taken together, these educational, cultural, safety, and infrastructure benefits clearly outweigh
potential adverse impacts associated with construction activity, lighting, traffic, and site
redevelopment. The PUD mechanism allows these benefits to be realized while managing and
mitigating impacts through site design, phasing, and conditions of approval. As such, the
proposal is expected to provide a higher level of public benefit than development of the site under
strict zoning standards without a planned urban development.
N/A a. Critical Areas: Protects critical areas that would not be protected otherwise
to the same degree as without a planned urban development.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 30 of 70
SR_Renton High School_HEX Report_260106_FINAL
N/A
b. Natural Features: Preserves, enhances, or rehabilitates natural features of
the subject property, such as significant woodlands, native vegetation,
topography, or noncritical area wildlife habitats, not otherwise required by
other City regulations.
✓
c. Public Facilities: Provides public facilities that could not be required by the
City for development of the subject property without a planned urban
development.
Staff Comment: The Renton High School Replacement and Site Expansion
project provides multiple public facilities and infrastructure improvements that
would not otherwise be required through conventional development. As part of
the redevelopment, the applicant is replacing and upgrading existing utility
systems, including the replacement of an existing six-inch (6”) water main with a
new 12-inch (12”) main designed to current City standards, and installation of
stormwater treatment facilities serving surrounding streets. The project also
provides extensive frontage and transportation improvements, including new
sidewalks, streetscape enhancements, and roadway upgrades along Airport
Way, Logan Ave S, Shattuck Ave S, and Lake Ave S. Along S 2nd St, the applicant
is dedicating between approximately eight and twenty-four feet (8 – 24’) of ROW
to allow the City to complete future reconstruction consistent with adopted
capital plans, a dedication that would not be required absent the planned
campus redevelopment.
In addition to infrastructure upgrades, the rebuilt campus itself functions as a
significant civic facility designed to serve both students and the broader
community. The project includes modernized academic spaces, indoor athletic
courts, and new competitive-level outdoor recreation facilities, including
baseball, softball, and multipurpose fields. Consistent with District practice and
community expectations, many of these facilities will be available for permitted
community use outside of school hours, inclu ding tennis courts, pickleball
courts, and half-court basketball areas. Portions of the existing western fields will
be converted for track and field practice use only, without lighting or spectator
seating, to remain compatible with the Renton Municipal Airport Runway
Protection Zone. Collectively, these utility upgrades, transportation
improvements, recreational amenities, and long-term educational facilities
represent public benefits that would not be achievable under the strict
application of standard development regulations without the PUD.
✓
d. Use of Sustainable Development Techniques: Design which results in a
sustainable development; such as LEED certification, energy efficiency, use
of alternative energy resources, low impact development techniques beyond
that required by the Surface Water Design Manual, etc.
Staff Comment: The proposed redevelopment incorporates sustainable building
and site design practices that exceed minimum code requirements and support
long-term energy efficiency and resource conservation. The new high school is
designed to comply with the Washington State Clean Buildings Performance
Standards and incorporates high-efficiency air-to-water heat pumps for heating
and cooling, dedicated outdoor air ventilation systems with enhanced heat
recovery, and heat pump water heaters. The building will be equipped with Energy
Star–rated equipment, LED lighting with daylighting and occupancy controls, and
a control system programmed to minimize mechanical energy consumption
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 31 of 70
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while maintaining comfort. The project also includes provisions for on -site
renewable energy through rooftop solar readiness, permanent classroom
shading to reduce heat gain, and energy metering to monitor ongoing building
performance. Additional sustainability measures include low-emitting interior
finishes, an integrated pest management program, food -waste reduction
strategies, and electric-vehicle charging infrastructure. Collectively, these
measures contribute to a more efficient, lower-carbon campus and represent a
meaningful application of sustainable development techniques consistent with
the intent of the PUD regulations.
✓
e. Overall Design: Provides a planned urban development design that is
superior to the design that would result from development of the subject
property without a planned urban development. A superior design may
include the following:
i. Open Space/Recreation:
(a) Provides increased open space or recreational facilities beyond standard
code requirements and considered equivalent to features that would offset park
mitigation fees in Resolution 3082; and
(b) Provides a quality environment through either passive or active recreation
facilities and attractive common areas, including accessibility to buildings from
parking areas and public walkways; or
Staff Comment: The project provides a comprehensive system of outdoor
recreation and gathering spaces that exceeds what would otherwise be required
through standard development regulations. The campus includes multiple
competitive-level athletic facilities, including baseball, softball, and
multipurpose fields, indoor courts, and associated spectator and concessions
areas. These facilities are designed for both school programming and public use
outside school hours through permitted community access. Two (2) pedestrian
plazas — one (1) at the primary entry and one (1) north of the classroom building
— establish identifiable gathering areas that function as extensions of the
academic environment while supporting informal community use. The project
also provides enhanced sidewalks, including a widened 12-foot (12’) pedestrian
corridor in key locations along S 2nd St and Logan Ave S, improving comfort and
accessibility for students and the public. Together, these features create active
and passive open spaces that support both educational and community needs
and represent a level of recreational investment not typically required absent the
PUD.
ii. Circulation/Screening: Provides superior circulation patterns or location or
screening of parking facilities; or
Staff Comment: The proposed circulation system represents a superior
configuration compared to conventional development patterns. The PUD allows
coordinated reconfiguration of driveways, removal of redundant access points,
and consolidation of internal circulation that improves safety and clarity of
movement. Vehicular entries are placed to maximize sight distance and reduce
turning conflicts, while pedestrian routes are prioritized and aligned with primary
building entrances. Bus loading is relocated to Logan Ave S to minimize internal
conflicts and improve route efficiency, while student drop-off areas are expanded
and separated from staff and service access. Strategic use of gated access points
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 32 of 70
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provides additional capacity for event traffic without introducing through -traffic
during school hours. Parking areas are broken into smaller groupings and
screened with landscaping that achieves full ground coverage, reducing visual
prominence and softening edges along adjacent streets. Collectively, these
measures create safer pedestrian conditions, improved site legibility, and more
efficient circulation than would likely result without the flexibility afforded by the
PUD.
iii. Landscaping/Screening: Provides superior landscaping, buffering, or
screening in or around the proposed planned urban development; or
Staff Comment: The proposed landscaping plan provides enhanced buffering,
tree coverage, and site character that exceed a strictly code-conforming
approach. Landscaping has been intentionally designed to incorporate native
and culturally appropriate plant species, respond to airport safety constraints,
and avoid vegetation types that attract wildlife. The project exceeds interior and
perimeter parking lot landscape requirements in most areas and integrates
shade trees, groundcovers, and shrubs in a manner that reinforces pede strian
routes and frames key building entries. Twenty-eight significant trees are retained
where feasible, and new street trees are provided along perimeter streets at
regular spacing, contributing to long-term canopy growth. Plazas and gathering
areas incorporate interpretive paving patterns, seating, and feature plantings to
create distinct public spaces that respond to the school’s history and context.
Overall, the landscaping strategy enhances visual quality, supports user comfort,
and helps transition the campus to surrounding neighborhoods, resulting in a
superior outcome compared to a conventional code-minimum design.
iv. Site and Building Design: Provides superior architectural design, placement,
relationship or orientation of structures, or use of solar energy; or
Staff Comment: The project demonstrates superior site and architectural design
enabled by the flexibility of the PUD. The new high school building is oriented
toward the downtown core and primary street frontages, reinforcing the campus
as a civic presence while maintaining compatibility with the preserved 1930s
building and IPAC. The site is organized to separate bus, staff, and student
circulation, reducing conflicts and improving safety. A variety of gathering spaces ,
including an internal courtyard, student plaza, and exterior terraces, provide
opportunities for informal learning and community interaction. Building materials
and forms have been selected to complement retained structures while
incorporating contemporary design elements, transparency, and natural light.
The architectural composition integrates brick, metal panel systems, and glazing
arranged to reflect internal program elements and establish rhythm and human
scale. Athletic fields, plazas, and entry features are coordinated into the broader
site design, resulting in a cohesive campus environment. These elements
collectively reflect a higher design standard than would reasonably occur without
PUD flexibility.
v. Alleys: Provides alleys for proposed detached or attached units with individual,
private ground related entries.
Staff Comment: Not applicable. No alleys are proposed.
✓ Building and Site Design:
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 33 of 70
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i. Perimeter: Size, scale, mass, character and architectural design along the
planned urban development perimeter provide a suitable transition to adjacent
or abutting lower density/intensity zones. Materials shall reduce the potential for
light and glare.
Staff Comment: The size, scale, and character of the proposed high school
redevelopment provide an appropriate transition to surrounding uses while
reinforcing the civic identity of the campus. The three-story classroom building is
intentionally scaled to complement the massing of the retained 1930s building
and the IKEA Performing Arts Center, creating a cohesive institutional setting.
Although larger than some older structures in the vicinity, the building height and
bulk are compatible with newer development patterns downtown, including the
six-story municipal parking garage located at the southeast corner of Logan Ave
S and S 2nd St. Campus design is also influenced by Federal Aviation
Administration (FAA) height limitations, which constrain building elevations and
athletic field structures near Airport Way and help moderate overall mass.
Athletic facilities, including baseball and softball fields, are oriented toward
Airport Way where there are no residential uses, and where nearby land uses
consist primarily of airport operations and commercial/light -industrial activities.
Netting, fencing, lighting controls, and new sidewalks and street trees along this
frontage reduce visual and operational impacts. Ligh ting analyses demonstrate
minimal off-site light spill. Along S 2nd St and Lake Ave S, upgraded frontage
improvements, landscaping, and a prominent entry plaza provide a clearly
defined, pedestrian-scaled campus edge. Durable exterior materials and non-
reflective finishes are incorporated to minimize glare and ensure visual
compatibility with adjacent properties. Overall, the perimeter treatment results
in an appropriate transition to adjoining commercial, institutional, and residential
areas.
ii. Interior Design: Promotes a coordinated site and building design. Buildings in
groups should be related by coordinated materials and roof styles, but contrast
should be provided throughout a site by the use of varied materials, architectural
detailing, building orientation or housing type; e.g., single family, townhouses,
flats, etc.
Staff Comment: The internal building and site design promotes a coordinated
campus environment that integrates new facilities with the existing 1930s
building and IPAC. The new academic building is organized to maintain functional
connections among learning spaces, performance facilities, and outdoor areas
while creating clear circulation routes for students and staff. Interior program
areas are oriented to maximize daylight, outward views, and visual connection to
landscaped courtyards and plazas, supporting a healthy learning environment.
Parking for staff and visitors is located to the south and west of the building, with
access and circulation designed to limit conflicts with pedestrian movement. The
site layout emphasizes separation of different travel modes while preserving
intuitive connections between buildings and open spaces. Architecture,
materials, and forms are coordinated to provide consistency across campus,
while allowing the historic structure to remain visually prominent. Collectively,
the interior campus design reflects a unified, functionally coordinated
development consistent with the intent of the PUD regulations.
✓ Circulation:
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 34 of 70
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i. Provides sufficient streets and pedestrian facilities. The planned urban
development shall have sufficient pedestrian and vehicle access commensurate
with the location, size and density of the proposed development. All public and
private streets shall accommodate emergency vehicle access and the traffic
demand created by the development as documented in a traffic and circulation
report approved by the City. Vehicle access shall not be unduly detrimental to
adjacent areas.
ii. Promotes safety through sufficient sight distance, separation of vehicles from
pedestrians, limited driveways on busy streets, avoidance of difficult turning
patterns, and minimization of steep gradients.
iii. Provision of a system of walkways which tie residential areas to recreational
areas, transit, public walkways, schools, and commercial activities.
iv. Provides safe, efficient access for emergency vehicles.
Staff Comment: The proposed redevelopment provides pedestrian and vehicle
access commensurate with the size and institutional nature of the campus and
improves circulation compared to existing conditions. The reconfiguration of site
access reduces the number of driveways on S 2nd St, consolidates student and
event parking into clearly organized lots, and relocates s chool-bus loading to a
curb-side zone on Logan Ave S, which reduces turning conflicts and
accommodates district bus routing patterns. The rebuilt segment of S Tobin St, to
be vacated and incorporated into the campus, functions as an internal fire lane
and limited-access drive, providing east–west connectivity for emergency
vehicles while discouraging cut-through traffic. Pedestrian improvements
include new sidewalks along all perimeter frontages, with widened pedestrian
corridors along Logan Ave S and S 2nd St, as well as internal walkways connecting
the main building, plazas, athletic fields, and parking areas. Internal pathways are
designed to provide direct, legible routes while separating pedestrian travel from
vehicle movements where feasible.
The circulation plan promotes safety by dispersing access points to avoid
queuing, eliminating driveways on Airport Way, and placing loading zones at the
perimeter rather than within central campus areas. Vehicle speeds along internal
segments of S Tobin St are moderated through narrower right-of-way design and
adjacent parking treatments, while proposed curb extensions and crossings on
Logan Ave S improve visibility for pedestrians and bus operations. Walkways
connect instructional areas with recreational facilities, transit, and public
sidewalks, strengthening campus integration with the surrounding neighborhood.
The Transportation Technical Report, prepared by Heffron Transportation Inc,
dated September 16, 2025, evaluated campus operations at a planned
enrollment of up to approximately 1,600 students. The rebuilt and expanded
campus is estimated to generate a net increase of about 410 average daily trips,
including approximately 114 additional AM peak-hour trips (6:45–7:45 a.m.) and
72 additional PM peak-hour trips (1:45–2:45 p.m.). These incremental increases
are distributed across multiple access points and surrounding arterials and, with
the proposed access reconfiguration and frontage improvements, are expected
to be accommodated without creating capacity or safety deficiencies on
adjacent streets. No vehicle access is proposed on Airport Way, further reducing
potential conflicts with fast-moving arterial traffic.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 35 of 70
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Emergency access has been coordinated with the City and Renton Regional Fire
Authority. The reconstructed S Tobin St fire lane, gated secondary access points,
and clear apparatus routes provide multiple points of entry to interior areas of the
site. Overall, the circulation system provides safe, efficient, and coordinated
access consistent with the intent of the PUD regulations and is not anticipated to
be unduly detrimental to surrounding areas.
Staff received one public comment related to transportation (Exhibit 28). The
comment questioned the Traffic Impact Analysis (TIA), asserting that it may
overstate traffic formerly using S Tobin Street and noting that the street is
primarily used as a cut-through route rather than local access. The commenter
requested a new traffic study reflecting existing conditions and potential
congestion shifts to Airport Way if Tobin is vacated. Staff reviewed the concern
and the TIA, which evaluated existing and future operations using standard
methods and modeled network changes, including the Tobin vacation. The
analysis concluded that nearby intersections, including Airport Way, would
continue to operate at acceptable levels with project traffic. Because the study is
based on roadway function, intersection performance, and modeled demand,
rather than historic neighborhood trip patterns, staff finds the TIA remains valid
and does not recommend requiring a new study. The comment has been entered
into the record and was considered in staff’s analysis.
The proposal has passed the City’s Traffic Concurrency Test per RMC 4 -6-070D
(Exhibit 22), which is based upon a test of the citywide Transportation Plan,
consideration of growth levels included in the LOS-tested Transportation Plan,
payment of Transportation Impact Fees, and application of site-specific
mitigation.
✓
Infrastructure and Services: Provides utility services, emergency services, and
other improvements, existing and proposed, which are sufficient to serve the
development.
Staff Comment: Adequate infrastructure and essential public services are
available to serve the proposed redevelopment, and the project includes
upgrades that would improve system performance for the broader area.
Domestic water and fire protection would be provided through the City’s system,
including replacement of an existing six-inch (6”) water line with a new twelve-
inch (12”) main designed to current standards. Sanitary sewer service would
connect to existing City infrastructure with on -site extensions and upgrades as
necessary to meet projected campus demand. Stormwater would be managed
through a combination of new collection, treatment, and flow-control facilities
consistent with the City’s adopted stormwater manual, with additional treatment
provided along adjacent streets. Police, fire, and emergency medical services are
available to the site, and emergency access routes have been coordinated
through the reconfigured S Tobin St fire lane and secondary gated access points.
Other utilities, including power, communications, and solid waste, are available
and would be extended and upgraded as part of construction. Overall, the project
is supported by sufficient infrastructure and services to accommodate the rebuilt
campus and meets this criterion.
✓ Clusters or Building Groups and Open Space: An appearance of openness
created by clustering, separation of building groups, and through the use of well-
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 36 of 70
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designed open space and landscaping, or a reduction in the amount of
impervious surfaces not otherwise required.
Staff Comment: The planned redevelopment emphasizes openness through the
distribution of building mass, integration of existing structures, and substantial
provision of athletic and recreational open space. The project consolidates
academic functions into a single new classroom building that is physically and
visually coordinated with the retained 1930s building and IPAC, allowing much of
the expanded campus to remain in active open space rather than additional
building coverage. The site expansion adds approximately ten (10)_acres to
accommodate competitive athletic fields, plazas, and landscaped gathering
areas comparable to other regional high schools. As a result, large portions of the
property are maintained as permeable or recreational surfaces, and the overall
impervious area is significantly less than what could occur if the site were
developed under conventional zoning for more intensive commercial or
residential use. The arrangement of buildings and open spaces creates a campus
environment with clear visual relief, usable outdoor amenities, and a sense of
openness consistent with the purpose of the PUD regulations.
✓
Privacy and Building Separation: Provides internal privacy between dwelling
units, and external privacy for adjacent and abutting dwelling units. Each
residential or mixed use development shall provide visual and acoustical privacy
for dwelling units and surrounding properties. Fences, insulation, walks, barriers,
and landscaping are used, as appropriate, for the protection and aesthetic
enhancement of the property, the privacy of site occupants and surrounding
properties, and for screening of storage, mechanical or other appropriate areas,
and for the reduction of noise. Windows are placed at such a height or location
or screened to provide sufficient privacy. Sufficient light and air are provided to
each dwelling unit.
Staff Comment: The project provides appropriate visual separation, noise
buffering, and screening given the institutional nature of the campus and the
limited number of nearby residential properties. No new dwelling units are
proposed as part of the redevelopment. The remaining off-site residential uses
are located primarily along Lake Ave S and the non-vacated portion of S Tobin St
at the northwest edge of the campus. In this area, the proposal reduces the
overall activity intensity by converting the existing spectator ballfields to a
practice-only track and field facility with no lighting and no spectator seating. The
large open-space buffer created by these athletic fields, combined with retained
and supplemental landscaping, provides a physical and visual separation
between school functions and adjacent homes.
Existing fencing and vegetation along residential edges would be retained where
feasible, and additional landscape buffers are proposed to enhance screening
and privacy. Parking areas, mechanical equipment, refuse facilities, and student
activity zones are located primarily within the interior of the site or along st reet
frontages that do not abut residential pr operties, and would be screened
consistent with applicable City standards. Mechanical equipment is primarily
housed within rooftop penthouses, and ground-level service areas are designed
to be enclosed or screened. Ornamental perimeter fencing is used selectively to
support campus safety while maintaining visibility along primary public frontages.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 37 of 70
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Building design along Logan Ave S and S 2nd St incorporates glazing, modulation,
and transparency consistent with urban design requirements while avoiding
direct adjacency to residential uses. Overall, the combination of building
placement, field orientation, buffering, and screening measures provi des
adequate light, air, and acoustical separation for surrounding properties and is
appropriate for a public-school campus.
✓
Building Orientation: Provides buildings oriented to enhance views from within
the site by taking advantage of topography, building location and style.
Staff Comment: The proposed building orientation takes advantage of the site’s
topography and urban context to enhance views and create an active, outward -
facing campus. The new classroom building is oriented primarily toward S 2nd St
and Logan Ave S, with generous glazing that frames views toward downtown
Renton and landscaped plazas while creating transparency and visual interest
along public frontages. This orientation reinforces the school’s civic presence
and supports a pedestrian-oriented streetscape consistent with the Urban
Design District standards. Internal courtyards and plazas provide additional
views to landscaped areas and athletic fields, allowing both interior learning
spaces and exterior gathering areas to benefit from open-space vistas rather than
being focused on parking or service functions. Overall, the building location and
orientation enhance visual connectivity, leverage site features, and contribute to
a well-organized campus layout.
✓
Parking Area Design: Provides parking areas that are complemented by
landscaping and not designed in long rows. The size of parking areas is minimized
in comparison to typical designs, and each area related to the group of buildings
served. The design provides for efficient us e of parking, and shared parking
facilities where appropriate.
Staff Comment: The project provides parking areas that are distributed,
screened, and integrated into the campus design rather than configured as large
uninterrupted expanses. Two (2) primary parking lots serve staff, visitors, and
event users, supplemented by strategically placed parallel and aisle-adjacent
stalls along internal drives. This arrangement allows the overall supply to meet
City requirements while minimizing the footprint of any single parking field and
reducing the need for additional maneuvering aisles. Pa rking is organized to
relate logically to the functions it serves, including proximity to the main entry,
IPAC, and athletic facilities, while maintaining separation from primary
pedestrian plazas and learning spaces.
Landscaping, shade trees, lighting, and internal pedestrian pathways are
incorporated consistent with RMC 4-4-080. Perimeter buffers and interior
landscaping provide visual relief and screening from surrounding streets and
adjacent uses. Parking areas located along internal drives help calm vehicle
speeds and create additional buffer between sidewalks and travel lanes. The
combination of distributed lots, landscaped screening, and efficient stall
placement results in parking areas that function effectively while supporting a
more pedestrian-focused campus environment.
✓ Phasing: Each phase of the proposed development contains the required parking
spaces, open space, recreation spaces, landscaping, and utilities necessary for
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 38 of 70
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creating and sustaining a desirable and stable environment, so that each phase,
together with previous phases, can stand alone.
Staff Comment: The Renton High School Replacement Project is designed to be
constructed in multiple coordinated phases, with each phase containing
sufficient parking, utilities, access, landscaping, and functional open space to
operate as a stable and safe environment. Initial work includes frontage
improvements, interim parking, and utility upgrades that allow the existing school
to continue operating while construction of the new building occurs on the
expanded campus area. The new high school building is then constructed and
brought online prior to demolition of most existing facilities, ensuring
uninterrupted educational service. Subsequent phases include demolition of
remaining buildings, redevelopment of athletic fields, completion of permanent
parking areas, and final site landscaping and circulation improvements.
At each stage, the project provides adequate emergency access, stormwater
management, pedestrian connections, and on-site parking proportionate to
operational needs. No portion of the project is dependent on unbuilt future
phases for essential services or functionality, and transitional measures are
incorporated to maintain safe student circulation and campus operations
throughout construction. As phased elements are completed, they integrate into
a unified campus framework that can stand alone during interim conditions and
ultimately function cohesively upon full build-out. Accordingly, the proposal
meets the phasing criterion.
23. PUD Development Standards: Pursuant to RMC 4-9-150D.4, each planned urban development
shall demonstrate compliance with the development standards for the Planned Urban Development
regulations. The following table contains project elements intended to comply with the development
standards of the Planned Urban Development regulations, as outlined in RMC 4-9-150E:
Compliance PUD Development Standard Analysis
1. COMMON OPEN SPACE STANDARD: Open space shall be concentrated in large usable areas
and may be designed to provide either active or passive recreation. Requirements for residential,
mixed use, commercial, and industrial developments are described below.
N/A
Standard: For residential developments open space must equal at least ten
percent (10%) of the development site’s gross land area.
Staff Comment: No residential units are proposed as part of the project.
Compliant if
Condition of
Approval is
Met
Standard: All buildings and developments with over thirty thousand (30,000)
square feet of nonresidential uses (excludes parking garage floorplate areas)
shall provide pedestrian-oriented space according to the following formula:
1% of the lot area + 1% of the building area = Minimum amount of pedestrian -
oriented space.
Staff Comment: The proposed campus redevelopment exceeds 30,000 square
feet of nonresidential floor area and is therefore required to provide pedestrian -
oriented space equal to one percent (1%) of the total lot area plus one percent
(1%) of the gross building area. Based on the overall campus size and the new
high school building, staff finds that the intent of this requirement is to create a
connected system of usable gathering spaces rather than a single, centralized
plaza. As shown on the Site Plan (Exhibit 3), floor plans (Exhibit 4), and
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 39 of 70
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conceptual landscape plans (Exhibit 6), the project incorporates several
pedestrian-oriented areas, including the primary entry plaza at S 2nd St and
Logan Ave S; the internal pedestrian promenade that connects the building to the
athletic complex; smaller outdoor gathering spaces and student courtyards
adjacent to building entries; and widened sidewalk areas along campus
frontages that integrate seating, hardscape, and landscaping. Together, these
elements create a functional network of outdoor areas that support student
arrival, informal gathering, circulation, and outdoor learning, consistent with the
intent of RMC 4-9-150.
The current submittal, however, does not clearly quantify the total square
footage of pedestrian-oriented space or demonstrate that all spaces counted
include the minimum required elements such as seating and lighting. To ensure
consistency and compliance with the standard, staff recommends, as a
condition of approval, that applicant submit a Pedestrian-Oriented Space Plan
with the civil construction permit submittal. The plan shall: (1) calculate the total
amount of pedestrian-oriented space required and provided; (2) clearly identify
on the site and landscape plans each area proposed to count toward the
requirement; and (3) demonstrate that every counted area includes all required
elements, including: accessible paved surfaces, average illumination of at least
four (4) foot-candles on the ground, and durable seating provided at a minimum
rate of three linear feet (3’) per sixty (60) square feet of plaza/open space. The
plan shall also include cut-sheets for proposed lighting and site furnishings. The
Pedestrian-Oriented Space Plan shall be reviewed and approved by the Current
Planning Project Manager prior to issuance of the civil construction permit.
✓
Standard: The location of public open space shall be considered in relation to
building orientation, sun and light exposure, and local micro -climatic conditions.
Staff Comment: Common open space areas on the redeveloped campus are
intentionally located to take advantage of prominent site features, building
entrances, and natural conditions. The primary gathering plaza is positioned at
the southeast corner of the building near the main entry at S 2nd St and Logan
Ave S, where it functions as both a student activity node and a welcoming
forecourt for visitors. Additional student courtyards and seating areas are
distributed along the building perimeter and internal pedestrian routes, creating
opportunities for informal gathering adjacent to classroom wings and
administrative entries. The large pedestrian promenade connecting the school
building to the athletic complex also leverages existing topography by
transitioning gently across the site while framing views toward both the
downtown core and the new athletic fields.
These spaces receive favorable solar exposure throughout the day, particularly
along the south and east frontages, while strategically placed trees and
landscape beds provide shade, seasonal interest, and visual buffering from
vehicular areas. Together, the layout of plazas, courtyards, and promenades
enhances usability, reinforces logical circulation patterns, and takes advantage
of surrounding architecture and landscape features consistent with PUD design
objectives.
N/A Standard: Common space areas in mixed use residential and attached
residential projects should be centrally located so they are near a majority of
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 40 of 70
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dwelling units, accessible and usable to residents, and visible from surrounding
units.
i. Common space areas should be located to take advantage of surrounding
features such as building entrances, significant landscaping, unique topography
or architecture, and solar exposure.
ii. In mixed use residential and attached residential projects children’s play
space should be centrally located, visible from the dwellings, and away from
hazardous areas like garbage dumpsters, drainage facilities, streets, and parking
areas.
Staff Comment: Not applicable. No residential uses are proposed.
24. Infrastructure and Services: Provides utility services, emergency services, and other
improvements, existing and proposed, which are sufficient to serve the development. The proposal
is compliant with the following development standards if all conditions of approval are met:
Compliance Infrastructure and Services Analysis
✓
Police and Fire: Police and Fire Prevention staff indicated that sufficient
resources exist to furnish services to the proposed development; if the applicant
provides Code required improvements and fees.
The preliminary fire flow requirement for the new high school building is 3,750
gallons per minute (gpm). Based on this flow, a minimum of four (4) fire hydrants
are required, including one (1) hydrant within 150 feet (150’) and three (3)
hydrants within 300 feet (300’) of the proposed building. At least one (1) hydrant
shall be installed within 50 feet (50’) of the Fire Department Connection (FDC) for
the fire sprinkler and standpipe systems. A looped fire water main is required
around the building because the required fire flow exceeds 2,500 gpm, and
hydrant spacing shall not exceed 300 feet (300’) on center. Any existing hydrants
credited toward coverage must comply with current City standards.
An approved automatic fire sprinkler and standpipe system and a fully automatic
fire alarm system shall be installed throughout the building. Separate fire permits
will be required for these systems, as well as for kitchen hood suppression
systems and any CO₂ beverage gas systems exceeding 100 pounds. Direct
exterior access shall be provided to the sprinkler equipment room.
Fire department apparatus access shall be provided within 150 feet (150’) of all
points on the building, with on-site fire lanes posted and maintained. Access
roadways shall be a minimum of 20 feet (20’) wide, fully paved, capable of
supporting a 30-ton vehicle with 75-psi point loading and shall provide turning
radii of 25 feet (25’) inside / 45 feet (45’) outside. Approved turnarounds shall be
provided where dead-end segments exceed 150 feet (150’).
All buildings shall comply with the City of Renton Emergency Radio Coverage
requirements. Testing at final inspection shall confirm minimum signal
performance for both inbound and outbound emergency communications.
Where coverage is insufficient, radio amplification equipment shall be installed
under a separate fire permit.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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A Fire Impact Fee applies to the project at a rate of $28.02 per student, calculated
based on the increase in student capacity, and shall be paid at the time of
building permit issuance.
✓
Storm Water: An adequate drainage system shall be provided for the proper
drainage of all surface water.
Staff Comment: The applicant submitted a Technical Information Report,
prepared by AHBL, Inc., dated September 2025, with the application (Exhibit 13).
The report analyzes existing conditions and proposed surface water collection
and distribution.
The site lies within the City’s Peak Rate Flow Control Standard Area (matching
existing conditions) and drains to the Black River Basin. The project proposes a
substantial increase in impervious surface due to new building area,
reconstructed parking, and athletic facilities; therefore, the project is subject to
full compliance with the 2022 City of Renton Surface Water Design Manual
(RSWDM).
Because more than 5,000 square feet of new plus replaced impervious surface
will be created, enhanced basic water quality treatment is required. The TIR
identifies a treatment strategy consisting of engineered water quality facilities
sized to treat runoff from new hardscape areas prior to discharge to the public
system. Flow control facilities are also proposed to detain stormwater and limit
post-development discharge rates to existing (pre-project) conditions, consistent
with Core Requirement #3. Conveyance improvements include new storm pipe
networks that collect runoff from roofs, paved areas, and athletic fields and route
it through approved Best Management Practices (BMPs) prior to connection to
the City system.
The engineering reviewer has determined that the conceptual stormwater
approach described in the TIR is feasible and, with final design detail, will meet
applicable City standards. Final sizing, configuration, and outlet control details
for all treatment and detention facilities will be reviewed with the civil
construction permit. The development will be subject to applicable Surface
Water System Development Charges (SDCs) at the time of permit issuance
(Exhibit 32).
Based on the submitted TIR and City review, staff finds that stormwater impacts
associated with the project can be adequately mitigated through compliance
with the adopted surface water regulations and implementation of the identified
BMPs and flow-control facilities.
A Construction Stormwater Permit from Department of Ecology is required due to
clearing and grading of the site exceeding one (1) acre. The applicant must obtain
the permit and provide proof prior to civil permit issuance.
✓
Water and Sanitary Sewer: This site is served by the City of Renton for water and
sewer service.
Staff Comment: A generalized utility plan, within the Civil Plans (Exhibit 5), was
submitted with the land use application showing the proposed extensions and
connections to the City’s public utility systems. Domestic and fire water service
would be provided by the City of Renton. Based on review by the engineering
reviewer and Fire Prevention staff, the preliminary fire flow demand for the
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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Report of January 13, 2026 Page 42 of 70
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proposed high school building is approximately 3,750 gallons per minute (gpm).
Because this demand exceeds 2,500 gpm, a looped water main is required to be
installed around the building to ensure redundancy and available fire flow.
Existing public mains in the vicinity include a 12-inch (12") water main in Logan
Ave S and an 8-inch (8") main in several of the adjoining streets, with capacity
available to serve the project subject to final design and modeling. New hydrants
would be installed consistent with spacing requirements and Fire Department
standards, including at least one (1) fire hydrant within 50 feet (50’) of the fire
department connection.
Sanitary sewer service would be provided by connection to the City’s public
gravity system located within surrounding rights-of-way. The site is served by
existing eight-inch (8") sewer mains that ultimately convey flows to the City’s
trunk system. The proposed school building and site program would connect to
this network through new on-site pipes that discharge to the public system at
approved locations. Sewer capacity is available; however, final pipe sizing,
slopes, and connection points would be verified during civil plan review.
The project would be subject to all applicable water and wastewater system
development charges (SDCs) and utility connection fees at the time of permit
issuance. With compliance with City standards and implementation of the
required looped water system and hydrant spacing, adequate water and sanitary
sewer utilities are available to serve the proposed development.
Compliant
if Condition
of Approval
is Met
Streets:
Staff Comment: The proposed campus circulation plan provides multiple points
of vehicular ingress and egress necessary to accommodate staff parking, student
pick-up/drop-off operations, deliveries, and Fire Department access. Driveways
are located to distribute site traffic and reduce conflicts at individual
intersections, while still meeting emergency vehicle turning and access
requirements. Consolidation of vehicle access points also limits interruptions to
pedestrian routes along the public frontage.
The Transportation Technical Report, prepared by Heffron Transportation Inc,
dated September 16, 2025, evaluated anticipated traffic operations at key study
intersections surrounding the campus (Exhibit 15). Based on the TTR, all study
intersections are expected to continue operating at acceptable levels of service
with project-generated traffic, and the proposed driveways will operate at LOS B
or better during peak periods. Accordingly, no intersection mitigation is warranted
beyond payment of required Transportation Impact Fees, which will be assessed
at the time of building permit issuance. The TTR also confirmed adequate sight
distance at the proposed driveways.
Logan Ave S (Minor Arterial):
Logan Ave S functions as a north–south minor arterial providing primary campus
identity and a key pedestrian gateway. Existing improvements generally include
curb, gutter, sidewalk, and marked crossings near the site frontage. The project
maintains Logan Ave S as the primary public-facing frontage, with building
orientation, student entries, and pedestrian circulation aligned toward the street.
Frontage improvements emphasize pedestrian comfort and safety by widening
sidewalk areas, improving ADA access, and consolidating driveway movements
away from high pedestrian concentration points. Traffic associated with staff
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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Report of January 13, 2026 Page 43 of 70
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parking, student pick-up/drop-off, and service vehicles is distributed across the
campus rather than concentrated along Logan Ave S, maintaining the minor
arterial’s through-movement function.
The Transportation Impact Analysis (TIA) concludes that intersections along
Logan Ave S would continue to operate at acceptable Levels of Service with the
project, and no off-site mitigation is warranted. Transportation Impact Fees will
be paid to address systemwide capacity needs.
Airport Way (Minor Arterial):
Airport Way, located at the eastern edge of the broader circulation network
serving the campus area, operates as a minor arterial with regional connectivity.
While no direct vehicular access to the school property is proposed along Airport
Way, the TIA evaluates traffic redistribution through this corridor and finds that
increases attributable to the project remain within acceptable capacity
thresholds.
Because primary site access is directed to other frontages, Airport Way primarily
experiences pass-by and background traffic rather than additional driveway
conflict points. No frontage reconstruction beyond standard maintenance and
coordination with existing signal timing is required. Future coordination with
Public Works will occur if citywide signal timing or arterial corridor adjustments
are programmed, but no project-specific mitigation is triggered.
S 2nd St (Minor Arterial / Principal Frontage — Waiver Area / Planned Corridor
Improvements):
S 2nd St forms the primary southern frontage and functions as a minor arterial
corridor with planned multimodal enhancements. Standard frontage
requirements would typically include curb, gutter, planter strip, and sidewalk
reconstruction consistent with the City’s most current street section.
The applicant submitted a street improvement waiver request (see “South 2nd
Street Improvement Waiver Request,” Exhibit 21) based on the fact that S 2nd St
is already included in the City’s Transportation Improvement Program (TIP) for
comprehensive corridor reconstruction. Requiring full frontage improvements at
this time would likely result in redundant work and future demolition when the TIP
project proceeds.
Engineering staff reviewed the waiver and supports approval, subject to the
following concepts:
• Interim frontage conditions will be maintained in a safe and operable
state,
• Sidewalk connectivity, ADA access, and drainage remain functional, and
• The applicant coordinates design information with the city to avoid
conflicts with the future TIP project.
Staff finds the waiver reasonable, avoids unnecessary redevelopment costs, and
does not diminish pedestrian or vehicular safety.
S 3rd St (Neighborhood Access / School Access Corridor):
S 3rd St operates primarily as an access street supporting local circulation and
school-related traffic movements. Proposed improvements focus on organizing
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 44 of 70
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vehicle movements, consolidating access, and improving student pedestrian
crossings.
Driveways are limited and strategically located to support bus movements and
internal circulation while minimizing conflict points. Where crossings occur,
design elements such as curb bulbs, marked crosswalks, and shortened crossing
distances improve visibility and pedestrian safety.
Operations analysis in the TIA shows that movements along S 3rd Street and
connecting intersections will function at Level of Service B or better, and queuing
remains contained within internal circulation areas during peak school times.
Shattuck Ave S (Collector Arterial / Circulation Edge):
Shattuck Ave S functions as a collector street transitioning traffic between
arterials and local access streets. No new primary driveways are proposed on
this frontage. Instead, Shattuck Ave S continues to act as a circulation relief edge
and secondary pedestrian interface.
Street improvements emphasize sidewalk continuity and visual buffering
between vehicle areas and the public realm. Landscaping and frontage
enhancements reduce visual dominance of parking areas while preserving the
collector’s role in distributing local traffic.
Airport Way / Logan Ave S – Shattuck Ave S – S 3rd St System Interaction:
The combined network distributes traffic efficiently by segmenting student drop-
off, staff parking, and service vehicle activity. The TIA confirms that with this
distribution pattern:
• Nearby intersections operate within acceptable LOS thresholds,
• Driveway spacing minimizes conflict points, and
• No off-site roadway widening is triggered.
• Transportation Impact Fees will mitigate cumulative system-level
impacts.
S Tobin St (Partial Vacation Consideration):
A short segment of S Tobin St adjacent to the campus is under separate
consideration by the City Council for vacation. If vacated, this portion would be
incorporated into the campus circulation framework, eliminating a public
roadway with limited utilization, and improving internal safety by removing
unnecessary turning conflicts near student pedestrian paths.
Vacation is not required for project approval, but if granted, the area would be
converted to enhanced pedestrian circulation, landscape buffers, and controlled
access areas consistent with school security objectives.
Sight Distance, Safety, and Access Management:
The TIA identifies that proposed driveway locations meet city sight-distance
standards and do not introduce unsafe turning movements. Access points have
been minimized consistent with code, balancing emergency access, vehicular
circulation needs, and pedestrian safety.
Level of Service and Concurrency:
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 45 of 70
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The Transportation Technical Report indicates that the proposed modernization
and expansion would not materially increase traffic levels when compared to
existing site conditions. When accounting for demolition of former on-site
residential and commercial uses, the project is expected to generate an overall
decrease of approximately 610 daily vehicle trips. Peak-hour impacts are modest
as the site would see an increase of approximately 18 trips during the morning
arrival period, but a reduction of about 15 trips during the afternoon school-
dismissal period and a reduction of roughly 69 trips during the PM commuter
peak. These trip changes were evaluated at nearby intersections and were found
not to result in level-of-service deficiencies or warrant off-site mitigation. All
evaluated intersections continue to operate at acceptable LOS standards. The
project satisfies City concurrency requirements, and Transportation Impact Fees
will be paid at building permit issuance to offset systemwide impacts.
Temporary Construction Impacts:
Short-term construction traffic and lane restrictions are expected. Consistent
with previous school projects, staff recommends, as a condition of approval, the
applicant shall submit a construction outreach and traffic communication plan
to notify neighbors, road users, and affected agencies prior to major roadway
disruption.
25. Design District Review: Pursuant to RMC 4-9-150D.4, each Planned Urban Development must
demonstrate compliance with any applicable overlay design district unless a specific modification
has been requested and approved. The Renton High School campus includes properties within the
Center Downtown (CD) zone, Commercial Arterial (CA) zone, and Residential-8 (R-8) zone. Portions
of the site are therefore subject to different design frameworks, including Urban Design District A –
all areas zoned CD, Urban Design District D–all areas zoned CA, and for the R-8 parcels–the
Residential Design and Open Space Standards.
Strict application of all three (3) design frameworks would result in fragmented site design,
conflicting building frontage and transparency expectations, and inconsistent edge treatments
inappropriate for a unified civic campus. Through the PUD review, the applicant has requested that
the project be evaluated under a single set of design expectations. Consistent with the project’s
primary frontage along S 2nd St and Logan Ave S, and its functional role within the downtown fabric,
staff has applied the Urban Design District A standards as the controlling design overlay for the
overall campus. Applying one (1) district supports cohesive building massing, pedestrian-oriented
frontage design, and integration with anticipated future downtown growth, while still allowing the
city to evaluate building scale, transparency, and site edges in a comprehensive way.
Staff supports application of a unified Urban Design District A standard to the project, provided the
applicant complies with applicable development conditions and mitigation measures. The following
analysis evaluates key project elements for consistency with the Design District A standards and
guidelines in RMC 4-3-100E and the applicant’s submitted Design District A Checklist.
Compliance Design District Guideline and Standard Analysis
1. SITE DESIGN AND BUILDING LOCATION:
Intent: To ensure that buildings are located in relation to streets and other buildings so that the
Vision of the City of Renton can be realized for a high -density urban environment; so that
businesses enjoy visibility from public rights-of-way; and to encourage pedestrian activity.
a. Building Location and Orientation:
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 46 of 70
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Intent: To ensure visibility of businesses and to establish active, lively uses along sidewalks and
pedestrian pathways. To organize buildings for pedestrian use and so that natural light is available
to other structures and open space. To ensure an appropriate transition between buildings,
parking areas, and other land uses; and increase privacy for residential uses.
Guidelines: Developments shall enhance the mutual relationship of buildings with each other, as
well as with the roads, open space, and pedestrian amenities while working to create a pedestrian
oriented environment. Lots shall be configured to encourage variety and so that natural light is
available to buildings and open space. The privacy of individuals in residential uses shall be
provided for.
✓
Standard: The availability of natural light (both direct and reflected) and direct sun
exposure to nearby buildings and open space (except parking areas) shall be
considered when siting structures.
Staff Comment: The new high school building is located primarily along the S 2nd
St and Logan Ave S frontages, where it establishes a strong civic edge while
preserving substantial open areas to the west and northwest for athletics and
campus circulation. By concentrating the taller building mass along the more
urban frontages, the project maintains larger setbacks and open space transitions
near the remaining residential areas north and west of the site. Plazas, courtyards,
and open fields are positioned to receive natural light throughout the day, and
building modulation and orientation help limit shade impacts on pedestrian
spaces and nearby properties.
✓
Standard: Buildings shall be oriented to the street with clear connections to the
sidewalk.
Staff Comment: The main three-story building would be oriented toward S 2nd St
and Logan Ave S, with primary entries, glazing, and architectural emphasis facing
these public frontages. Multiple pedestrian entrances connect directly to existing
or upgraded sidewalks, including the main entry plaza at the corner of S 2nd St and
Logan Ave S and secondary entries aligned with pedestrian pathways extending
into the campus. These connections create clear and legible entries, reinforce the
school’s civic presence along the street, and support pedestrian movement
between the campus, downtown, and surrounding neighborhoods.
✓
Standard: The front entry of a building shall be oriented to the street or a
landscaped pedestrian-only courtyard.
Staff Comment: The primary school entry is clearly oriented toward S 2nd St and
Logan Ave S and is framed by a landscaped entry plaza that functions as a
pedestrian-focused gathering space. The plaza incorporates seating, paving
accents, and coordinated landscaping, establishing a defined and welcoming
entrance while maintaining visual transparency to the street. Additional student
entrances connect to internal pedestrian courts and pathways, further
emphasizing pedestrian orientation rather than vehicular access.
N/A
Standard: Buildings with residential uses located at the street level shall be:
a. Set back from the sidewalk a minimum of ten feet (10') and feature
substantial landscaping between the sidewalk and the building; or
b. Have the ground floor residential uses raised above street level for
residents’ privacy.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 47 of 70
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Staff Comment: There are no ground level residential units proposed for the
project.
b. Building Entries:
Intent: To make building entrances convenient to locate and easy to access, and ensure that
building entries further the pedestrian nature of the fronting sidewalk and the urban character of
the district.
Guidelines: Primary entries shall face the street, serve as a focal point, and allow space for social
interaction. All entries shall include features that make them easily identifiable while reflecting the
architectural character of the building. The primary entry shall be the most visually prominent
entry. Pedestrian access to the building from the sidewalk, parking lots, and/or other areas shall
be provided and shall enhance the overall quality of the pedestrian experience on the site.
✓
Standard: A primary entrance of each building shall be located on the facade
facing a street, shall be prominent, visible from the street, connected by a
walkway to the public sidewalk, and include human-scale elements.
Staff Comment: The primary entrance to the high school is located at the corner
of S 2nd St and Logan Ave S and is prominently oriented toward the public streets.
The main entry plaza provides a generous pedestrian gathering space with
landscaping, seating, and specialty paving that clearly directs visitors to the entry
doors. The entry canopy, glazing, and architectural framing elements help
establish the entry as a civic focal point. Secondary student entries are also
connected to internal walkway systems but are subord inate to the main street-
facing entrance.
✓
Standard: A primary entrance of each building shall be made visibly prominent by
incorporating architectural features such as a facade overhang, trellis, large entry
doors, and/or ornamental lighting.
Staff Comment: See analysis under Ground Level Details for discussion of
required enhancements.
✓
Standard Building entries from a street shall be clearly marked with canopies,
architectural elements, ornamental lighting, or landscaping and include weather
protection at least four and one-half feet (4-1/2') wide (illustration below).
Buildings that are taller than thirty feet (30') in height shall also ensure that the
weather protection is proportional to the distance above ground level.
Staff Comment: The primary entry incorporates a covered entry canopy integrated
into the building massing and extending over the plaza area, providing weather
protection and visual emphasis. The plaza incorporates landscaping and seating
elements, reinforcing the pedestrian-scale environment. Final lighting specifics
will be verified with the building permit to ensure proportionality to the building
height and compliance with the guideline requiring pedestrian-scale illumination.
✓
Standard: Building entries from a parking lot shall be subordinate to those related
to the street.
Staff Comment: Secondary entries located adjacent to on-site parking areas are
designed as functional access points but are clearly subordinate to the primary
street-facing entry in terms of size, architectural treatment, and overall visibility.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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Report of January 13, 2026 Page 48 of 70
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✓
Standard: Features such as entries, lobbies, and display windows shall be
oriented to a street or pedestrian-oriented space; otherwise, screening or
decorative features should be incorporated.
Staff Comment: Primary building entries of all existing and proposed buildings on
the campus are oriented toward S 2nd St and Logan Ave S. Secondary entrances
connect to internal pedestrian courtyards and walkways that function as
pedestrian-oriented spaces. No blank walls occur at key pedestrian locations;
architectural detailing and transparency provide visual interest and reinforce
campus security and visibility.
N/A
Standard: Multiple buildings on the same site shall direct views to building entries
by providing a continuous network of pedestrian paths and open spaces that
incorporate landscaping.
Staff Comment: The redevelopment consists of a single principal building
connected to the existing IPAC and 1931 administrative building as well as the
small maintenance, concessions, and storage buildings on the north side of the
site. Pedestrian circulation nevertheless directs movement clearly toward the
primary entrance via landscaped pathways and plazas.
N/A
Standard: Ground floor residential units that are directly accessible from the
street shall include entries from front yards to provide transition space from the
street or entries from an open space such as a courtyard or garden that is
accessible from the street.
Staff Comment: No ground-floor residential units are proposed.
c. Transition to Surrounding Development:
Intent: To shape redevelopment projects so that the character and value of Renton’s long -
established, existing neighborhoods are preserved.
Guidelines: Careful siting and design treatment shall be used to achieve a compatible transition
where new buildings differ from surrounding development in terms of building height, bulk and
scale.
✓
Standard: At least one of the following design elements shall be used to promote
a transition to surrounding uses:
1. Building proportions, including step-backs on upper levels in accordance
with the surrounding planned and existing land use forms; or
2. Building articulation to divide a larger architectural element into smaller
increments; or
3. Roof lines, roof pitches, and roof shapes designed to reduce apparent bulk
and transition with existing development.
Additionally, the Administrator may require increased setbacks at the side or rear
of a building in order to reduce the bulk and scale of larger buildings and/or so that
sunlight reaches adjacent and/or abutting yards.
Staff Comment: The proposed project balances the larger civic scale appropriate
for a regional public high school while maintaining compatibility with surrounding
neighborhoods and adjacent uses. The primary academic building ranges up to
three (3) stories whose mass is concentrated near S 2nd St and Logan Ave S,
locations characterized by wider arterials, commercial activity, and larger
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 49 of 70
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structures, including the existing IPAC and the multi-story municipal parking
garage across the intersection of Logan Ave S and S 2nd St. This siting strategy
places the greatest height and activity at the edges of the campus that can best
accommodate it, while stepping down intensity toward the west and north where
lower-scale residential and campus-support uses occur.
Along Lake Ave S and the western edge of the campus, existing residential
properties are buffered by large expanses of athletic fields, track facilities, and
landscaped areas. These open spaces create substantial building separation and
reduce visual bulk, ensuring a gentle transition from school facilities to nearby
homes. No new tall buildings are proposed in proximity to residential edges, and
the track field is intentionally designed for practice use only — without spectator
seating or lighting — further reducing potential visual and activity impacts.
Architecturally, the new high school employs modulation, facade articulation, and
varied roof forms to break down perceived massing. The building composition ties
visually to both the retained historic 1931 structure and the IPAC through
compatible materials, color palettes, and horizontal proportions. These design
techniques help integrate the new construction into the established campus
fabric while presenting a civic presence appropriate to its function.
Overall, through strategic building placement, significant open space buffers, and
architectural modulation, the project successfully transitions between the larger
institutional campus environment and adjacent residential and mixed-use areas,
preserving neighborhood scale and character.
d. Service Element Location and Design:
Intent: To reduce the potential negative impacts of service elements (i.e., waste receptacles,
loading docks) by locating service and loading areas away from high-volume pedestrian areas, and
screening them from view in high visibility areas.
Guidelines: Service elements shall be concentrated and located so that impacts to pedestrians
and other abutting uses are minimized. The impacts of service elements shall be mitigated with
landscaping and an enclosure with fencing that is made of quality materials. Se rvice areas not
adjacent to streets, pathways, or pedestrian-oriented spaces are encouraged to implement
vegetative screening in addition to or as part of service enclosures.
✓
Standard: Service elements shall be located and designed to minimize the
impacts on the pedestrian environment and adjacent uses. Service elements
shall be concentrated and located where they are accessible to service vehicles
and convenient for tenant use.
Staff Comment: Service and loading functions are generally located on the interior
portions of the campus, away from high‐activity pedestrian plazas and primary
building entrances along S 2nd St and Logan Ave S. Service areas are accessed
from internal drives designed to accommodate occasional truck movements
without disrupting daily student circulation patterns. Concentrating loading,
waste service, and support functions in limited locations minimizes conflicts with
student pathways and helps preserve the pedestrian character of the site’s main
frontage areas.
Complaint if
PUD
Standard: In addition to standard enclosure requirements, garbage, recycling
collection, and utility areas shall be enclosed on all sides, including the roof and
screened around their perimeter by a wall or fence and have self -closing doors.
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Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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modification
is approved
Staff Comment: Refuse and recycling facilities are proposed within dedicated
screened enclosures located in service areas that are not visible from primary
pedestrian spaces. These enclosures are fully enclosed and gated to comply with
RMC 4-4-095 (if requested PUD modification is approved) and are designed to
control views, odors, and access (Exhibit 10). The location within interior service
courts eliminates visibility from the surrounding streets and school plazas while
maintaining functional access for collection vehicles.
✓
Standard: Service enclosures shall be made of masonry, ornamental metal or
wood, or some combination of the three (3).
Staff Comment: The applicant’s Screening Plan (Exhibit 10) indicate that refuse
and service enclosures will utilize durable screening materials consistent with
City standards, including a solid fencing gate system and masonry compatible
with surrounding site features. Final material and enclosure details will be verified
during building and civil permit review to ensure compliance with the requirement
for masonry and/or ornamental quality materials.
✓
Standard: If the service area is adjacent to a street, pathway, or pedestrian -
oriented space, a landscaped planting strip, minimum 3 feet wide, shall be
located on 3 sides of such facility.
Staff Comment: Where service elements occur near internal walkways,
landscaping is incorporated to soften views and provide additional screening.
Most service areas are intentionally set back from major pedestrian corridors and
public streets; however, any locations that occur adjacent to walkways are
buffered with shrubs and groundcover consistent with this standard. Staff will
confirm final planting configurations at permit review to ensure that screening
landscaping is continuous and meets the minimum width requirement.
2. PARKING AND VEHICULAR ACCESS:
Intent: To provide safe, convenient access to the Urban Center and the Center Village; incorporate
various modes of transportation, including public mass transit, in order to reduce traffic volumes
and other impacts from vehicles; ensure sufficient parking is provided, while encouraging
creativity in reducing the impacts of parking areas; allow an active pedestrian environment by
maintaining contiguous street frontages, without parking lot siting along sidewalks and building
facades; minimize the visual impact of parking lots; and use access streets and parking to
maintain an urban edge to the district.
a. Surface Parking:
Intent: To maintain active pedestrian environments along streets by placing parking lots
primarily in back of buildings.
Guidelines: Surface parking shall be located and designed so as to reduce the visual impact of
the parking area and associated vehicles. Large areas of surface parking shall also be designed
to accommodate future infill development.
Complaint if
Modified per
the PUD
Regulations
Standard: Parking shall be located so that no surface parking is located between:
a. A building and the front property line; and/or
b. A building and the side property line (when on a corner lot).
Staff Comment: Surface parking on the campus is intentionally located behind or
internal to the site rather than between buildings and public streets. However, a
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 51 of 70
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limited number of parallel parking stalls are proposed along S 2nd St in front of the
existing IPAC and 1931 administrative building, providing curbside parking
convenience for short-term users and event attendees. Approximately 22 parallel
spaces are shown (Exhibit 5). According to the applicant, these stalls function as
managed on-street parking rather than a traditional parking lot and do not create
a large surface parking area between the building and the street. They are also
supported by widened sidewalks, landscaping, and pedestrian plazas that
maintain a strong pedestrian character along the frontage. Therefore, the
applicant has requested a PUD modification to allow limited parallel parking
between the buildings and the street (S 2nd St).
Staff supports the modification as the parallel stalls also serve a practical public-
benefit function by helping absorb event-related parking demand associated with
IPAC and high school assemblies, thereby reducing spillover into nearby
residential neighborhoods and minimizing unnecessary circulation through the
surrounding street network.
Overall, the project avoids the placement of expansive parking areas between
buildings and streets and maintains active frontages and pedestrian orientation
along S 2nd St and Logan Ave S. Therefore, the proposal meets the intent of this
standard with the PUD modification.
Complaint if
Modified per
the PUD
Regulations
Standard: Parking shall be located so that it is screened from surrounding streets
by buildings, landscaping, and/or gateway features as dictated by location.
Staff Comment: The applicant has requested a PUD modification to allow the
student parking lot along S 2nd St to have only partial landscape screening, relying
primarily on the street trees and the perimeter parking lot landscaping rather than
a continuous low screen. The applicant contends that the southeast portion of the
lot near S 2nd St requires a wider sidewalk and additional circulation space to
safely accommodate higher pedestrian volumes and to provide direct ADA
connections to the sidewalk. Introducing full-height screening in this location
would either constrict pedestrian movement or interfere with accessible stall
access.
In addition, the applicant notes that future City capital improvements along S 2nd
St would include new street trees and frontage enhancements that would further
soften views of the parking area over time. Along the remainder of the lot frontage,
perimeter landscaping, street trees, and grade transitions provide a softened
visual edge consistent with the overall frontage treatment for the campus.
Staff finds that the requested PUD modification meets the intent of the screening
standard by balancing visibility, pedestrian safety, ADA accessibility, and long-
term frontage improvements. Staff supports approval of the modification, subject
to final review of frontage landscaping and sidewalk design at the time of civil
construction permit review.
b. Structured Parking Garages:
Intent: To promote more efficient use of land needed for vehicle parking; encourage the use of
structured parking; physically and visually integrate parking garages with other uses; and reduce
the overall impact of parking garages.
Guidelines: Parking garages shall not dominate the streetscape; they shall be designed to be
complementary with adjacent and abutting buildings. They shall be sited to complement, not
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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Report of January 13, 2026 Page 52 of 70
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subordinate, pedestrian entries. Similar forms, materials, and/or details to the primary building(s)
should be used to enhance garages.
N/A
Standard: Parking structures shall provide space for ground floor commercial
uses along street frontages at a minimum of seventy five percent (75%) of the
building frontage width.
Staff Comment: Not applicable. No structured parking is proposed.
N/A
Standard: The entire facade must feature a pedestrian-oriented facade. The
Administrator of the Department of Community and Economic Development may
approve parking structures that do not feature a pedestrian orientation in limited
circumstances. If allowed, the structure shall be set back at least six feet (6') from
the sidewalk and feature substantial landscaping. This landscaping shall include
a combination of evergreen and deciduous trees, shrubs, and ground cover. This
setback shall be increased to ten feet (10') when abutting a primary arterial and/or
minor arterial.
Staff Comment: Not applicable. No structured parking is proposed.
N/A
Standard: Public facing facades shall be articulated by arches, lintels, masonry
trim, or other architectural elements and/or materials.
Staff Comment: Not applicable. No structured parking is proposed.
N/A
Standard: The entry to the parking garage shall be located away from the primary
street, to either the side or rear of the building.
Staff Comment: Not applicable. No structured parking is proposed.
N/A
Standard: Parking garages at grade shall include screening or be enclosed from
view with treatment such as walls, decorative grilles, trellis with landscaping, or a
combination of treatments.
Staff Comment: Not applicable. No structured parking is proposed.
N/A
Standard: The Administrator of the Department of Community and Economic
Development or designee may allow a reduced setback where the applicant can
successfully demonstrate that the landscaped area and/or other design
treatment meets the intent of these standards and guidelines. Possible
treatments to reduce the setback include landscaping components plus one or
more of the following integrated with the architectural design of the building:
a. Ornamental grillwork (other than vertical bars);
b. Decorative artwork;
c. Display windows;
d. Brick, tile, or stone;
e. Pre-cast decorative panels;
f. Vine-covered trellis;
g. Raised landscaping beds with decorative materials; or
h. Other treatments that meet the intent of this standard...
Staff Comment: Not applicable. No structured parking is proposed.
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Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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Report of January 13, 2026 Page 53 of 70
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c. Vehicular Access:
Intent: To maintain a contiguous and uninterrupted sidewalk by minimizing, consolidating, and/or
eliminating vehicular access off streets.
Guidelines: Vehicular access to parking garages and parking lots shall not impede or interrupt
pedestrian mobility. The impacts of curb cuts to pedestrian access on sidewalks shall be
minimized.
Complaint if
Modified per
the PUD
Regulations
Standard: Access to parking lots and garages shall be from alleys, when available.
If not available, access shall occur at side streets.
Staff Comment: No alleys serve the site. The applicant has submitted a PUD
modification request to allow primary access to the student parking lot from S 2nd
St, which is not classified as a side street. The applicant explains that the student
parking lot is located adjacent to the existing 1930s building and does not have
alley access. The lot is served by a driveway on S 2nd St, with a secondary access
on Lake Ave S. According to the applicant, this configuration provides safe and
separate circulation for students, isolates student parking from staff parking in the
site interior, and avoids conflicts with the bus loading area on Logan Ave S. The
location also offers convenient access to the main entry and academic areas
while minimizing cross-campus vehicle movement.
From a site-planning perspective, staff finds that the requested modification
reflects logical transportation hierarchy and campus operations. The driveway
spacing on S 2nd St is coordinated with internal circulation, and pedestrian routes
to campus entries remain direct and protected. The design also limits the number
of access points along higher-conflict streets and maintains separation between
student vehicles, staff vehicles, service vehicles, and buses.
Staff supports the requested PUD modification to allow access from S 2nd St,
subject to final engineering review to ensure sight distance, pedestrian safety, and
driveway spacing standards are met at the time of civil plan review.
✓
Standard: The number of driveways and curb cuts shall be minimized for
vehicular access purposes, so that pedestrian circulation along the sidewalk is
minimally impeded.
Staff Comment: Driveway locations are intentionally limited and strategically
placed to minimize curb cuts and maintain continuous pedestrian sidewalks
along the project frontages. The site plan identifies two (2) driveways on S 2nd St:
one serving the main student/event parking area and one serving the internal
automobile load/unload zone. A single driveway on Lake Ave S provides access to
the expanded parking lot on the west side of the campus. Access to the staff
parking area and bus zone is provided primarily from a driveway at the modified S
Tobin St/Shattuck Ave S intersection, with a secondary gated driveway at the
Logan Ave S/S Tobin St intersection used only during events or emergencies.
No vehicular access is provided from Airport Way, avoiding conflicts along this
fast-moving arterial. Several existing driveways serving the parcels proposed for
acquisition are removed as part of the project, further reducing driveway
frequency and eliminating informal curb cuts.
Furthermore, by consolidating access into a limited number of clearly defined
locations and separating primary pedestrian areas from vehicle movements, the
site design minimizes interruptions to sidewalks and maintains safe walking
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Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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Report of January 13, 2026 Page 54 of 70
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routes along S 2nd St, Logan Ave S, and Lake Ave S, consistent with the intent of
this standard.
3. PEDESTRIAN ENVIRONMENT:
Intent: To enhance the urban character of development by creating pedestrian networks and by
providing strong links from streets and drives to building entrances; make the pedestrian
environment safer and more convenient, comfortable, and pleasant to walk between businesses,
on sidewalks, to and from access points, and through parking lots; and promote the use of multi -
modal and public transportation systems in order to reduce other vehicular traffic.
a. Pedestrian Circulation:
Intent: To create a network of linkages for pedestrians to improve safety and convenience and
enhance the pedestrian environment.
Guidelines: The pedestrian environment shall be given priority and importance in the design of
projects. Sidewalks and/or pathways shall be provided and shall provide safe access to buildings
from parking areas. Providing pedestrian connections to abutting properties is an important
aspect of connectivity and encourages pedestrian activity and shall be considered. Pathways
shall be easily identifiable to pedestrians and drivers.
✓
Standard: A pedestrian circulation system of pathways that are clearly delineated
and connect buildings, open space, and parking areas with the sidewalk system
and abutting properties shall be provided.
a. Pathways shall be located so that there are clear sight lines, to increase
safety.
b. Pathways shall be an all-weather or appropriate permeable walking
surface material, unless the applicant can demonstrate that the proposed
surface is appropriate for the anticipated number of users and
complementary to the design of the development.
Staff Comment: The proposed site plan establishes a connected pedestrian
network linking the school building, plazas, athletic fields, and parking areas with
surrounding public sidewalks. Primary pedestrian access occurs along S 2nd St
and Logan Ave S, where widened sidewalks and plaza spaces provide direct
access to the main building entry. Internal walkways extend from these frontages
to staff and student parking areas, athletic fields, and gathering spaces. Pathways
are aligned to maintain open sight lines across plazas and courtyards, enhancing
safety and visibility.
Pedestrian routes utilize concrete sidewalks, plaza paving, and other durable
surface treatments appropriate for heavy school use. Connections also extend
north toward the athletic field complex and north toward Memorial Stadium,
reinforcing campus-wide walkability and functional access during both school
hours and community events.
✓
Standard: Pathways within parking areas shall be provided and differentiated by
material or texture (i.e., raised walkway, stamped concrete, or pavers) from
abutting paving materials. Permeable materials are encouraged. The pathways
shall be perpendicular to the applicable building facade and no greater than one
hundred fifty feet (150') apart.
Staff Comment: Internal parking lots incorporate clearly defined pedestrian
walkways that connect parking rows to building entries, athletic facilities, and
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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Report of January 13, 2026 Page 55 of 70
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perimeter sidewalks. These routes are visually distinguished from drive aisles
through changes in paving, striping, and landscape buffers, helping drivers
recognize pedestrian priority. Walkways are generally oriented perpendicular to
building frontages and are spaced to ensure convenient and frequent access
points across larger parking areas. Where feasible, paving enhancements and
landscape islands further define crossings and reinforce pedestrian visibility. The
proposed pathway system meets the intent of the guideline and generally meets
the spacing requirement.
✓
Standard: Sidewalks and pathways along the facades of buildings shall be of
sufficient width to accommodate anticipated numbers of users. Specifically:
a. Sidewalks and pathways along the facades of mixed use and retail
buildings 100 or more feet in width (measured along the facade) shall
provide sidewalks at least 12 feet in width. The walkway shall include an
8-foot minimum unobstructed walking surface.
b. Interior pathways shall be provided and shall vary in width to establish a
hierarchy. The widths shall be based on the intended number of users; to
be no smaller than five feet (5') and no greater than twelve feet (12').
Staff Comment: Sidewalks and pedestrian areas adjacent to the classroom
building and main entry plazas are sized to accommodate high volumes of
students during peak arrival, dismissal, and event times. Along Logan Ave S, a 12-
foot (12’) sidewalk is provided as part of a pedestrian-oriented frontage. Along S
2nd St, sidewalks are coordinated with future City roadway improvements and
supplemented by on-site plaza areas that expand usable pedestrian space.
Interior campus walkways vary in width depending on function and are designed
to support comfortable two-way pedestrian movement, queuing, and gathering.
N/A Standard: Mid-block connections between buildings shall be provided.
✓
Standard: Permeable pavement pedestrian circulation features shall be used
where feasible, consistent with the Surface Water Design Manual.
Staff Comment: The pedestrian network incorporates a mix of conventional
concrete and specialty paving. Areas of decorative pavement and plaza design are
coordinated with stormwater design to allow infiltration where feasible. Staff
would review and consider additional permeable pavement if proposed with the
civil construction permit application.
4. RECREATION AREAS AND COMMON OPEN SPACE:
Intent: To ensure that areas for both passive and active recreation are available to residents,
workers, and visitors and that these areas are of sufficient size for the intended activity and in
convenient locations. To create usable and inviting open space that is accessible to the public;
and to promote pedestrian activity on streets particularly at street corners .
Guidelines: Developments located at street intersections should provide pedestrian-oriented
space at the street corner to emphasize pedestrian activity (illustration below). Recreation and
common open space areas are integral aspects of quality development that encour age
pedestrians and users. These areas shall be provided in an amount that is adequate to be
functional and usable; they shall also be landscaped and located so that they are appealing to
users and pedestrians
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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Report of January 13, 2026 Page 56 of 70
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N/A
Standard: All mixed use residential and attached housing developments of ten
(10) or more dwelling units shall provide common opens space and/or recreation
areas.
Staff Comment: No residential uses are proposed.
Compliant if
Modified per
the PUD
Regulations
Standard: All buildings and developments with over thirty thousand (30,000)
square feet of nonresidential uses (excludes parking garage floorplate areas) shall
provide pedestrian-oriented space.
a. The pedestrian-oriented space shall be provided according to the
following formula: 1% of the site area + 1% of the gross building area, at
minimum.
b. The pedestrian-oriented space shall include all of the following:
i. Visual and pedestrian access (including barrier-free access) to the
abutting structures from the public right-of-way or a nonvehicular
courtyard; and
ii. Paved walking surfaces of either concrete or approved unit paving; and
iii. On-site or building-mounted lighting providing at least four (4) foot-
candles (average) on the ground; and
iv. At least three (3) lineal feet of seating area (bench, ledge, etc.) or one
individual seat per sixty (60) square feet of plaza area or open space.
c. The following areas shall not count as pedestrian-oriented space:
i. The minimum required walkway. However, where walkways are
widened or enhanced beyond minimum requirements, the area may
count as pedestrian-oriented space if the Administrator determines
such space meets the definition of pedestrian-oriented space.
ii. Areas that abut landscaped parking lots, chain link fences, blank
walls, and/or dumpsters or service areas.
d. Outdoor storage (shopping carts, potting soil bags, firewood, etc.) is
prohibited within pedestrian-oriented space.
Staff Comment: The proposed high school building exceeds 30,000 square feet
and incorporates multiple pedestrian-oriented spaces integrated into the campus
design. The primary pedestrian-oriented area is the entry plaza at S 2nd St and
Logan Ave S, which functions as the main student gathering and circulation space
and provides paved walking surfaces, barrier -free routes, lighting, and visual
access to the main building entrance. Additional pedestrian-scaled open spaces,
internal courtyards, and circulation nodes are distributed throughout the site,
reinforcing connectivity and daily campus use.
Based on total site and building area, the project is required to provide
approximately 17,813 square feet of pedestrian-oriented space and has provided
approximately 17,849 square feet, meeting the minimum square footage
requirement. However, the code also requires pedestrian-oriented spaces to
include three lineal feet (3’) of seating per 60 square feet, which results in a
requirement of approximately 297 seats or 892 linear feet (892’). The proposal
includes approximately 260 linear feet (260’) of seating and 17 individual seats,
which does not meet the quantitative seating standard.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 57 of 70
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The applicant has therefore submitted a PUD modification request to allow a
reduced amount of required seating. The applicant’s justification notes that the
entry plaza is primarily intended as a circulation and gathering space rather than
a lingering area, and that excessive seating would conflict with the operational
needs of a high-school environment where students are expected to transition
quickly to class or home. Additional seating opportunities are provided within
interior courtyards and controlled campus spaces more appropriate for
supervision and daily use.
Staff finds that the request is reasonable and consistent with the intent of the
pedestrian-oriented space standards, which focus on creating accessible, safe,
and functional areas supportive of public use. The plazas remain highly
pedestrian-focused, are well-integrated into the circulation network, and include
appropriate amenities without creating opportunities for unmanaged loitering
immediately adjacent to the primary campus entrance. Staff supports the
requested PUD modification, subject to final review of plaza detailing at civil and
building permit stages to ensure pedestrian comfort, durability of materials, and
adequate lighting.
N/A
Standard: Public plazas shall be provided at intersections identified in the
Commercial Arterial Zone Public Plaza Locations Map Airport Way/Renton Avenue
S.
Staff Comment: The site is not abutting an intersection identified for the inclusion
of a public plaza.
N/A
Standard: The plaza shall measure no less than one thousand (1,000) square feet
with a minimum dimension of twenty feet (20') on one side abutting the sidewalk.
Staff Comment: See comment above.
N/A
Standard: The public plaza must be landscaped consistent with RMC 4-4-070,
including at minimum street trees, decorative paving, pedestrian -scaled lighting,
and seating. Vegetated low impact development facilities may be used in the
plaza where feasible and designed consistent with the Surface Water Design
Manual. Such facilities shall count towards no more than fifty percent (50%) of the
plaza requirement.
Staff Comment: See comment above.
5. BUILDING ARCHITECTURAL DESIGN:
Intent: To encourage building design that is unique and urban in character, comfortable on a
human scale, and uses appropriate building materials that are suitable for the Pacific Northwest
climate. To discourage franchise retail architecture.
a. Building Character and Massing:
Intent: To ensure that buildings are not bland and visually appear to be at a human scale; and
ensure that all sides of a building, that can be seen by the public, are visually interesting.
Guidelines: Building facades shall be modulated and/or articulated to reduce the apparent size
of buildings, break up long blank walls, add visual interest, and enhance the character of the
neighborhood. Articulation, modulation, and their intervals should create a se nse of scale
important to residential buildings.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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Report of January 13, 2026 Page 58 of 70
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✓
Standard: All building facades shall include modulation or articulation at
intervals of no more than forty feet (40').
Staff Comment: The proposed building incorporates modulation at regular
intervals through a combination of recessed facade planes, projecting roof
elements, stepped massing at key corners, and large window groupings aligned
with classroom modules (Exhibits 7 and 8). Along the primary public frontages on
S 2nd St and Logan Ave S, the facade shifts back and forth in multi-story segments
tied to interior program blocks, avoiding long uninterrupted planes. Vertical
elements, including stair towers and recessed glazing bays, further break down
the perceived length of the building into smaller human-scaled components.
These features create rhythm along the building edges and visually reduce overall
mass consistent with the intent of this standard. Further compliance with the
standard would be verified at the time of formal building permit application review.
✓
Standard: Modulations shall be a minimum of two feet (2') deep, sixteen feet (16')
in height, and eight feet (8') in width.
Staff Comment: The submitted elevations (Exhibit 7) indicate modulation depths
of approximately two to four feet (2-4’)or greater, with corresponding heights that
extend at least one (1) full story and widths that exceed eight feet (8’). These
dimensions meet or exceed minimum criteria and are consistently applied across
all visible frontages. The result is a facade composition that reads as clustered
building forms rather than one (1) continuous mass. Further compliance with the
standard would be verified at the time of formal building permit application review.
✓
Standard: Buildings greater than one hundred sixty feet (160') in length shall
provide a variety of modulations and articulations to reduce the apparent bulk and
scale of the facade or provide an additional special feature such as a clock tower,
courtyard, fountain, or public gathering area.
Staff Comment: Multiple facades exceed 160 feet (160’); however, the building
incorporates a variety of modulation techniques together with prominent public
gathering features. The main entry plaza and outdoor gathering spaces along S 2nd
St create intentional breaks in mass and emphasize pedestrian activity. On the
courtyard-facing side, articulated entries, window groupings, and covered
walkways provide additional scale relief. These elements collectively minimize
the appearance of building bulk and satisfy the intent of providing variety along
longer elevations.
b. Ground Level Details:
Intent: To ensure that buildings are visually interesting and reinforce the intended human -scale
character of the pedestrian environment; and ensure that all sides of a building within near or
distant public view have visual interest.
Guidelines: The use of material variations such as colors, brick, shingles, stucco, and horizontal
wood siding is encouraged. The primary building entrance should be made visibly prominent by
incorporating architectural features such as a facade overhang, trellis, large entry doors, and/or
ornamental lighting (illustration below). Detail features should also be used, to include things
such as decorative entry paving, street furniture (benches, etc.), and/or public art.
✓ Standard: Human-scaled elements such as a lighting fixture, trellis, or other
landscape feature shall be provided along the facade’s ground floor.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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Report of January 13, 2026 Page 59 of 70
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Staff Comment: The ground floor incorporates numerous human-scale features,
including canopy-protected entries, pedestrian-scaled lighting, benches and
seating walls, textured paving, and landscaping integrated with stormwater
planters. Generous glazing along classroom and lobby areas provides visual
transparency and engagement with adjacent sidewalks and plazas. These
treatments reinforce a comfortable pedestrian environment at the base of the
building.
✓
Standard: Upper portions of building facades shall have clear windows with
visibility into and out of the building. However, screening may be applied to
provide shade and energy efficiency. The minimum amount of light transmittance
for windows shall be 50 percent.
Staff Comment: Upper-floor classroom windows utilize clear glazing with visible
mullions, providing outward views and sufficient daylight penetration. The
proposed glazing appears to exceed the minimum 50 percent (50%) light
transmittance threshold and contributes to the academic environment and
exterior building rhythm.
N/A Standard: Display windows shall be designed for frequent change of
merchandise, rather than permanent displays.
✓
Standard: Where windows or storefronts occur, they must principally contain
clear glazing.
Staff Comment: The Architectural Elevations (Exhibit 7) indicate clear tempered
glass along the facade.
✓
Standard: Tinted and dark glass, highly reflective (mirror-type) glass and film are
prohibited.
Staff Comment: No reflective mirror-type glazing is proposed (Exhibit 7). Limited
spandrel or screened glazing occurs only where internal functions require
concealment (e.g., structural or utility zones). Final confirmation will occur during
building permit review to ensure compliance with material specifications.
✓
Standard: Untreated blank walls visible from public streets, sidewalks, or interior
pedestrian pathways are prohibited. A wall (including building facades and
retaining walls) is considered a blank wall if:
a. It is a ground floor wall or portion of a ground floor wall over 6 feet in height,
has a horizontal length greater than 15 feet, and does not include a
window, door, building modulation or other architectural detailing; or
b. Any portion of a ground floor wall has a surface area of 400 square feet or
greater and does not include a window, door, building modulation or other
architectural detailing.
Staff Comment: The building design avoids blank walls on public-facing elevations
by incorporating modulation, material variation, windows, and recesses. Where
solid wall segments occur (primarily near service and athletic areas), they are
softened with landscaping, textured finishes, and potential art treatment
consistent with the Urban Design regulations. Where unavoidable structural walls
are located, specifically along Logan Ave S, an integrated brick design element is
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
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SR_Renton High School_HEX Report_260106_FINAL
proposed (Exhibit 6). These measures successfully mitigate visual monotony and
meet the intent of the guideline.
✓
Standard: If blank walls are required or unavoidable, blank walls shall be treated
with one or more of the following:
a. A planting bed at least five feet in width containing trees, shrubs,
evergreen ground cover, or vines adjacent to the blank wall;
b. Trellis or other vine supports with evergreen climbing vines;
c. Architectural detailing such as reveals, contrasting materials, or other
special detailing that meets the intent of this standard;
d. Artwork, such as bas-relief sculpture, mural, or similar; or
e. Seating area with special paving and seasonal planting.
Staff Comment: See discussion above.
✓
Standard: Where windows or storefronts occur, they must only contain clear
glazing. Tinted, dark, and highly reflective (mirror -type) glass and film are
prohibited.
Staff Comment: See discussion above.
Compliant
with Intent
and
Guidelines if
Condition of
Approval is
Met
Standard: Any facade visible to the public shall be comprised of at least seventy
five percent (75%) transparent windows and/or doors for at least the portion of the
ground floor facade that is between four feet (4') and eight feet (8') above ground
(as measured on the true elevation).
Staff Comment: Primary pedestrian facades along S 2nd St and Logan Ave S
include substantial clear glazing that exceeds 50 percent (50%) transparency
within the defined height zone, especially at the main lobby and classroom fronts.
Portions of secondary facades that interface with internal campus edges rely
more on solid wall areas due to interior program needs (e.g., gym and support
areas). In these locations, the applicant provides compensating features such as
material variation, integrated art opportunities, and landscaping to maintain
interest. Staff supports the approach; however, final transparency calculations
and treatment details shall be confirmed at building permit review.
✓
Standard: Opaque signage is only allowed on or in no more than ten percent (10%)
of the window space. Stenciled or other signage types that allow visibility into the
building are encouraged and do not count toward the ten percent (10%)
calculation of signage in windows.
Staff Comment: See discussion above.
c. Building Roof Lines:
Intent: To ensure that roof forms provide distinctive profiles and interest consistent with an urban
project and contribute to the visual continuity of the district.
Guidelines: Building roof lines shall be varied and include architectural elements to add visual
interest to the building.
Compliant
with Intent
Standard: Buildings shall use at least one of the following elements to create
varied and interesting roof profiles:
City of Renton Department of Community & Economic Development
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and
Guidelines
a. Extended parapets;
b. Feature elements projecting above parapets;
c. Projected cornices;
d. Pitched or sloped roofs
e. Buildings containing predominantly residential uses shall have pitched
roofs with a minimum slope of one to four (1:4) and shall have dormers or
interesting roof forms that break up the massiveness of an uninterrupted
sloping roof.
Staff Comment: The building features a combination of parapets, stepped roof
heights, and feature roof elements above major entries and program nodes. These
variations highlight circulation areas, break up long roof planes, and reinforce
wayfinding. Rooflines are coordinated with facade modulation, resulting in a
cohesive yet visually interesting skyline profile.
Compliant if
Condition of
Approval
under FOF
20,
Screening is
Met
Standard: Roof mounted mechanical equipment shall not be visible to
pedestrians.
Staff Comment: Mechanical systems are generally located within recessed roof
wells or interior penthouse areas. Based on current elevations, equipment is not
expected to be visible to pedestrians; however, specific screening details were not
fully documented. Compliance will be verified during building permit review and
mechanical screening shall be required where necessary. In addition, see
recommended condition of approval related to screening under FOF 20, Zoning
Development Standard Compliance: Screening.
d. Building Materials:
Intent: To ensure high standards of quality and effective maintenance over time; encourage the
use of materials that reduce the visual bulk of large buildings; and encourage the use of materials
that add visual interest to the neighborhood.
Guidelines: Building materials are an important and integral part of the architectural design of a
building that is attractive and of high quality. Material variation shall be used to create visual
appeal and eliminate monotony of facades. This shall occur on all facades in a consistent manner.
High quality materials shall be used. If materials like concrete or block walls are used they shall
be enhanced to create variation and enhance their visual appeal.
✓
Standard: All sides of buildings visible from a street, pathway, parking area, or
open space shall be finished on all sides with the same building materials,
detailing, and color scheme, or if different, with materials of the same quality.
Staff Comment: Material palettes remain consistent on all publicly visible
facades, including brick, vertical metal siding, a porcelain panel system at the
main entrance, glazing systems, and precast or cast-in-place concrete base
elements. Changes in color and texture are deliberate and align with modulation
breaks rather than appearing arbitrary. In addition, brick proposed on the new
building will be designed to match the color and style of the brick on the existing
IPAC and historic 1931 building.
✓ Standard: All buildings shall use material variations such as colors, brick or metal
banding, patterns or textural changes.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 62 of 70
SR_Renton High School_HEX Report_260106_FINAL
Staff Comment: See discussion above.
✓
Standard: Materials, individually or in combination, shall have texture, pattern,
and be detailed on all visible facades.
Staff Comment: See discussion above.
✓
Standard: Materials shall be durable, high quality, and consistent with more
traditional urban development, such as brick, integrally colored concrete
masonry, pre-finished metal, stone, steel, glass and cast-in-place concrete.
Staff Comment: Proposed materials are durable, low-maintenance, and
appropriate for long-term public facility use. Brick, metal, porcelain, and concrete
systems are suitable for the Pacific Northwest climate and integrate well with
other institutional buildings in the district.
✓
Standard: If concrete is used, walls shall be enhanced by techniques such as
texturing, reveals, and/or coloring with a concrete coating or admixture .
Staff Comment: There are no concrete walls designed for the project. Concrete is
limited to areas near the foundations and some architectural elements built into
the brickwork.
N/A
Standard: If concrete block walls are used, they shall be enhanced with integral
color, textured blocks and colored mortar, decorative bond pattern and/or shall
incorporate other masonry materials.
Staff Comment: No CMU blocks are proposed on the exterior of the building.
✓
Standard: All buildings shall use material variations such as colors, brick or metal
banding, patterns, or textural changes.
Staff Comment: See discussion above.
6. LIGHTING:
Intent: To ensure safety and security; provide adequate lighting levels in pedestrian areas such as
plazas, pedestrian walkways, parking areas, building entries, and other public places; and
increase the visual attractiveness of the area at all times of the day and night.
Guidelines: Lighting that improves pedestrian safety and also that creates visual interest in the
building and site during the evening hours shall be provided.
✓
Standard: Pedestrian-scale lighting shall be provided at primary and secondary
building entrances. Examples include sconces on building facades, awnings with
down-lighting and decorative street lighting.
Staff Comment: The applicant submitted a Photometric Plan with the application
(Exhibit 9). Pedestrian-scale lighting is incorporated at all major campus
entrances, including the main front entry plaza at S 2nd St/Logan Ave S and
secondary student and staff access points around the building perimeter. Wall-
mounted sconces, canopy down-lights, and pole-mounted pedestrian fixtures are
located to clearly identify entrances, illuminate circulation routes, and enhance
visibility at night without producing excessive glare. The proposed lighting
reinforces wayfinding and contributes to a safe and welcoming entry experience.
Final fixture specifications and placement will be confirmed at building permit
review to ensure consistent illumination across pedestrian gathering zones.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 63 of 70
SR_Renton High School_HEX Report_260106_FINAL
✓
Standard: Accent lighting shall also be provided on building facades (such as
sconces) and/or to illuminate other key elements of the site such as gateways,
specimen trees, other significant landscaping, water features, and/or artwork.
Staff Comment: Accent lighting is strategically located to highlight major
architectural elements such as the main entrance canopy, identified gathering
plazas, key landscape areas, and pedestrian pathways. Select up-lighting and
integrated bollard lighting along walkways emphasize campus circulation while
avoiding direct spillover onto adjacent rights -of-way or surrounding properties.
Specimen tree up-lighting and plaza feature lighting also contribute to nighttime
visual interest.
✓
Standard: Downlighting shall be used in all cases to assure safe pedestrian and
vehicular movement, unless alternative pedestrian scale lighting has been
approved administratively or is specifically listed as exempt from provisions
located in RMC 4-4-075, Lighting, Exterior On-Site (i.e., signage, governmental
flags, temporary holiday or decorative lighting, right-of-way-lighting, etc.).
Staff Comment: The project relies primarily on full cut-off, down-directed fixtures
to control glare, reduce light spill, and maintain comfortable and safe nighttime
visibility. Parking, walkways, and building entrances use shielded luminaires
designed to focus light downward and within intended use areas. The site
photometric study demonstrates that illumination levels taper appropriately
toward property edges, limiting off-site glare and maintaining compliance with
RMC 4-4-075. Where taller athletic field lighting is proposed elsewhere on
campus, those fixtures incorporate directional shielding and aiming controls to
further minimize spill and off-site light trespass, consistent with the Lighting Study
submitted with the land use application. Final compliance will be verified through
building and civil permit application review.
26. Critical Areas: Project sites which contain critical areas are required to comply with the Critical
Areas Regulations (RMC 4-3-050). The proposal is consistent with the Critical Areas Regulations, if
all conditions of approval are complied with:
Compliance Critical Areas Analysis
Compliant
if all
Conditions
of Approval
are Met
Geologically Hazardous Areas: Based upon the results of a geotechnical report
and/or independent review, conditions of approval for developments may include
buffers and/or setbacks from buffers. A standard 15-foot building setback is
required for all structures from Protected Slope areas.
A 50-foot buffer and 15-foot building setback are required from Very High
Landslide Hazard Areas.
Staff Comment: City mapping identifies the Renton High School campus as being
located within an area of high seismic hazard and with limited areas of mapped
potential landslide hazard associated primarily with localized grade changes and
historic fill conditions. As such, the applicant submitted a Subsurface Exploration,
Geologic Hazard, and Geotechnical Engineering Report, prepared by Associated
Earth Sciences, Inc., dated September 3, 2025 (Exhibit 14).
The majority of the campus consists of relatively gentle slopes and urban fill
underlain by native soils, with no very high landslide hazard areas or protected
slopes identified within the proposed building footprint or primary activity areas.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 64 of 70
SR_Renton High School_HEX Report_260106_FINAL
The geotechnical evaluation concludes that the proposed construction, including
new foundations, utilities, grading activities, and athletic field improvements, can
be safely supported provided the recommendations in the report are implemented.
Where improvements occur near steeper grade transitions or existing retaining
structures, the report provides construction controls to avoid destabilization,
including temporary shoring, equipment setbacks, and careful management of
stormwater during construction.
The geotechnical report does not recommend buffers or building setbacks beyond
those already incorporated into the campus layout and confirms that the standard
setback requirements associated with landslide hazard areas do not apply to the
proposed building locations. Seismic design shall follow current building code
requirements and the site-specific recommendations contained in the report.
Prior to issuance of the civil construction permit, the applicant shall submit a
supplemental geotechnical memorandum prepared by the project geotechnical
engineer confirming that the final grading plan, utility alignments, retaining wall
designs, and foundation systems are consistent with the assumptions and
recommendations of the approved Geotechnical Engineering Report. The
memorandum shall identify any additional construction recommendations,
temporary shoring needs, equipment setbacks, or stormwater controls warranted
by the final design. The memorandum shall be reviewed and approved by the
Current Planning Project Manager and Development Engineering Reviewer and
incorporated into the civil construction drawings. All geotechnical
recommendations shall be implemented during construction.
✓
Wellhead Protection Areas:
Staff Comment: According to COR Maps, the site is located within both the
Downtown Wellhead Protection Zones 1 and 2. The eastern portion of the site is
located in Zone 1 while the western portion of the site is located in Zone 2. Open
facilities and open conveyance systems in either zone may require a liner in
accordance with the 2022 Renton Surface Water Design Manual. No open facilities
or convenance systems are proposed and therefore the implementation of best
management practices (BMPs) for stormwater control is preferable. BMPs that rely
on infiltration are prohibited in the Wellhead Protection Zone 1 but are allowed in
Zone 2. The proposed mixed-use building does not typically represent a type of use
that would potentially harm the city’s groundwater. Fill is anticipated to be brought
on the site and therefore any offsite fill materials shall be from a verifiable source
in order to ensure it is clear of contaminants. The city’s grading and excavation
regulations require that when imported fill is in excess of 50 cubic yards within a
Wellhead Protection Zone, a source statement certified by a qualified professional
be provided or confirmation that the fill was obtained from a WSDOT approved
source.
27. Conditional Use Permit: K–12 educational institutions are allowed in the R-8, CD, and CA zoning
designations subject to approval of a Hearing Examiner Conditional Use Permit (CUP). Although the
site has historically operated as a high school campus (since 1911), there is no approved Conditional
Use Permit on record for the existing facility. In addition, the proposed project constitutes a
substantial expansion of the use, including changes to site configuration, building program, and
circulation patterns. Because the proposal results in more than a ten percent (10%) increase in the
developed area and intensification of the existing school campus, a new CUP is required. The
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 65 of 70
SR_Renton High School_HEX Report_260106_FINAL
following table contains project elements intended to comply with Conditional Use Permit decision
criteria as related to the request to establish the use, as outlined in RMC 4 -9-030D:
Compliance Conditional Use Permit Criteria and Analysis
Compliant
if
Conditions
of Approval
under FOF
20 and 22
are Met
a. Consistency with Plans and Regulations: The proposed use shall be
compatible with the general goals, objectives, policies and standards of the
Comprehensive Plan, the zoning regulations and any other plans, programs,
maps or ordinances of the City of Renton.
Staff Comment: See FOF 19: Comprehensive Plan Compliance, FOF 20: Zoning
Development Standard Compliance, and FOF 22: PUD Decision Criteria. The
continued operation of a public high school, together with associated athletic
fields and campus improvements, is consistent with the applicable land use
policies that support the maintenance and enhancement of public educational
facilities in established neighborhoods. The requested CUP formalizes a long -
standing use while ensuring the expanded facilities meet cur rent standards and
conditions of approval.
✓
b. Appropriate Location: The proposed location shall not result in the
detrimental overconcentration of a particular use within the City or within the
immediate area of the proposed use. The proposed location shall be suited for
the proposed use.
Staff Comment: The site remains appropriate for the high school use and does
not represent an over-concentration of similar uses, as no other schools are
located within the immediate area. The surrounding urban context already
functions around Renton High School, and the proposed work largely enhances
existing functions rather than introducing a new institutional use. The applicant
notes the campus location is the most viable opportunity to accommodate
needed educational and athletic programming within the school district, after
evaluating alternative siting constraints. Staff recognizes that improvements
support the continued role of the school as a community anchor within an area
served by robust transportation and civic infrastructure and concurs with the
applicant’s justification.
Compliant
if
Conditions
of Approval
under FOF
20 and 22
are Met
c. Effect on Adjacent Properties: The proposed use at the proposed location
shall not result in substantial or undue adverse effects on adjacent property.
Staff Comment: The proposal is not anticipated to result in substantial or undue
adverse effects on adjacent properties. The project represents an expansion and
modernization of an existing high school use that has historically operated at this
location, rather than the introduction of a new or more intense land use. The
applicant indicates that the improvements are primarily intended to upgrade and
reorganize facilities, particularly outdoor athletic programming, circulation, and
support spaces, rather than increase student enrollment. As a result, the
proposal is not expected to generate a substantial increase in daily traffic, noise,
or other operational impacts typically associated with a new or expanded school.
Most land use changes occur within the athletic field complex and supporting
infrastructure. Proposed improvements include upgraded field lighting designed
to meet current photometric standards and minimize off -site spill, enhanced
landscape buffers and fencing along sensitive edges, reconfigured on-site
parking to reduce dependence on on-street spaces, and stormwater system
upgrades that improve treatment and flow control compared to existing
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 66 of 70
SR_Renton High School_HEX Report_260106_FINAL
conditions. Setbacks, orientation of facilities, and new landscaping collectively
provide visual softening and separation from nearby residences and other
abutting uses.
The applicant’s materials indicate that field use continues to be limited to
practice and school-related programming, rather than spectator-oriented
competition facilities, which further limits the potential for evening peak noise
and traffic. Based on the submitted analyses and subject to the recommended
conditions of approval, staff concludes that the continued high school use , with
the proposed facility upgrades, is compatible with adjacent residential,
commercial, and public properties and will not result in substantial or undue
adverse effects.
✓
d. Compatibility: The proposed use shall be compatible with the scale and
character of the neighborhood.
Staff Comment: The renovated campus remains compatible with the scale and
character of the neighborhood. The new three-story academic building is
designed with modulation, transparency, pedestrian plazas, and landscaping to
reflect surrounding downtown development patterns while retaining the school’s
civic presence. Athletic field improvements along Airport Way include trees and
fencing to transition to surrounding uses. The applicant emphasizes internal
pedestrian connections, minimized conflicts with parking, and reten tion of the
school as a community landmark. Because the proposal does not introduce a
fundamentally different use, compatibility is further supported by continuity of
educational programming on an already institutional site.
✓
e. Parking: Adequate parking is, or will be made, available.
Staff Comment: Adequate parking will be provided. The applicant estimates
approximately 476 on-site parking spaces to support the high school, IPAC, and
district functions. Based on projected enrollment and staffing, code would
require approximately 310 high-school spaces, plus separate parking for the
IPAC theater. The campus design distributes parking to reduce spillover and
supports shared-parking efficiencies during off-peak events. The proposal also
includes pedestrian circulation enhancements to reduce conflicts and support
multimodal trips. The additional parking supply, combined with internal
circulation design, is anticipated to meet operational needs without creating
adverse neighborhood overflow.
✓
f. Traffic: The use shall ensure safe movement for vehicles and pedestrians and
shall mitigate potential effects on the surrounding area.
Staff Comment: The proposal maintains safe vehicular and pedestrian
circulation (Exhibits 15 and 32). The applicant’s traffic analysis shows that trip
increases associated with field and campus upgrades will not create failing
operations at surrounding intersections. Internal circulation separates service,
emergency, pedestrian, and general access where feasible. Improvements to
public sidewalks, street crossings, and the addition of internal connections
increase safety and wayfinding for both students and members of the public.
Because the overall use remains a high school, peak trip characteristics are
similar to existing conditions, and increases primarily relate to event and athletic
activity, which are intermittent and managed through site operations and event
programming.
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 67 of 70
SR_Renton High School_HEX Report_260106_FINAL
Compliant
if all SEPA
Modified
MDNS
Mitigation
Measures
are Met
g. Noise, Light and Glare: Potential noise, light and glare impacts from the
proposed use shall be evaluated and mitigated.
Staff Comment: Long-term noise sources such as student activities and periodic
evening sports events are consistent with existing conditions on a long -standing
school campus. Field lighting and site lighting are designed to be shielded,
downcast and aimed to the play area to minimize light spill. The school district’s
lighting is proposed to be turned off by 10:00 p.m. when in use during the darker
months of the year. The design and specification for exterior lighting would meet
all of the International Dark Sky “Principles for Responsible Outdoor Lighting .”
The Lighting Study (Exhibit 16) demonstrates spill illumination between 0 and
0.09 footcandles at the site edges, and athletic lighting remains below FAA height
thresholds. These methods are included as mitigation measures in the school
district’s MDNS (Exhibit 27) and recommended to be adopted in full as conditions
of approval. Therefore, staff finds that noise and light impacts are appropriately
minimized and mitigated.
Truck delivery noise impacts should be minimal as delivery access will be limited
to the Logan Ave S bus pick-up and drop-off lane on the east portion of the subject
site. The noise of school children playing or congregating outside will be an
impact limited during the school day.
The school building, parking lot, and grounds will be lit after dusk each evening
for safety purposes. RMC 4-4-075 provides standards that limit light trespass
such as parking lot pole height limitations of 22 feet (22’) with cut-off type
luminaire and building lights directed onto itself or the ground immediately
abutting it. Standards for design review and compliance with exterior lighting
standards will be reviewed with the building permit submittal.
✓
h. Landscaping: Landscaping shall be provided in all areas not occupied by
buildings, paving, or critical areas. Additional landscaping may be required to
buffer adjacent properties from potentially adverse effects of the proposed use.
Staff Comment: Landscaping is provided throughout the site in accordance with
City requirements and is strategically used to buffer sensitive edges, soften built
features, and enhance the pedestrian environment. The landscape plan s
emphasize native and drought-tolerant species that are well-suited to long-term
campus maintenance and stormwater performance. Enhanced buffers are
located along property lines shared with residential uses, around parking areas,
and along the perimeter of athletic fields to reduce views, improve privacy, and
help disperse noise.
Along Airport Way, where FAA airspace restrictions limit taller canopy trees, the
applicant has incorporated layered shrub and understory planting to maintain
screening while staying within allowable height limits; tree caliper and planting
density otherwise remain consistent with code intent. Landscaping is also
integrated with pedestrian plazas, pathways, and gathering spaces, providing
shade, wayfinding, and opportunities for informal seating.
Overall, the proposed landscape treatment contributes to visual cohesion
across the campus, strengthens transitions to surrounding neighborhoods, and
mitigates potential adverse effects associated with lighting, activity, and
circulation. With implementation of the final detailed landscape plans at civil
permit review, staff finds the proposal meets the CUP landscaping criterion. See
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 68 of 70
SR_Renton High School_HEX Report_260106_FINAL
FOF 20, Zoning Development Standards Compliance, Landscaping for additional
analysis.
I. CONCLUSIONS:
1. The subject site is located in the Error! Reference source not found. and Residential Medium
Density (RMD) Comprehensive Plan designation and complies with the goals and policies
established with this designation, see FOF 7 and FOF 19.
2. The subject site is located in the Error! Reference source not found., Center Downtown (CD), and
Residential- 8 zoning designations and complies with the zoning and development standards, unless
modified under the Planned Urban Development, established with this designation provided the
applicant complies with City Code and conditions of approval, see FOF 8 and FOF 20.
3. The proposed Planned Urban Development, Conditional Use Permit, and Lot Combination complies
with the PUD Applicability Standards provided the applicant complies with City Code and conditions
of approval, see FOF 21.
4. The proposed Planned Urban Development, Conditional Use Permit, and Lot Combination complies
with the PUD Decision Criteria provided the applicant complies with City Code and conditions of
approval, see FOF 22.
5. The proposed Planned Urban Development, Conditional Use Permit, and Lot Combination complies
with PUD Development Standards provided the applicant complies with City Code and conditions of
approval, see FOF 23.
6. The proposed Planned Urban Development, Conditional Use Permit, and Lot Combination complies
with the Urban Design District A standards provided the applicant complies with City Code and
conditions of approval, see FOF 25.
7. The proposed Planned Urban Development, Conditional Use Permit, and Lot Combination complies
with the Critical Areas Regulations provided the applicant complies with City Code and conditions
of approval, see FOF 26.
8. The proposed Conditional Use Permit complies with the Conditional Use Permit criteria as
established by City Code provided the applicant complies with City Code and conditions of approval,
see FOF 27.
9. There are adequate public services and facilities to accommodate the propos al, see FOF 24.
10. Key features of the proposal include comprehensive modernization and expansion of the existing
high school campus, focused primarily on upgraded athletic facilities, enhanced site circulation,
and improved campus functionality. The new building elements are designed as contemporary
additions that complement the existing campus architecture, incorporating durable exterior
materials such as brick, metal panel systems, and high -performance glazing. Building facades
include modulation, canopy features, and transparent storefront elements at key entries to create
an active, pedestrian-scaled frontage. The campus design organizes activity around a series of
connected plazas and outdoor gathering areas, including a primary entry plaza at S 2nd St and Logan
Ave S, secondary courtyard spaces adjacent to classroom and support areas, and pedestrian
promenades linking buildings to athletic facilities. These spaces feature paving contrasts, seat
walls, planters, and integrated lighting to support both daily circulation an d informal student
gathering. Landscaping is layered to frame plazas and walkways, provide shade, and soften the
transition to surrounding neighborhoods, while site furnishings and wayfinding elements reinforce a
cohesive campus identity. Together, the building enhancements, plazas, circulation improvements,
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 69 of 70
SR_Renton High School_HEX Report_260106_FINAL
and athletic facility upgrades create a more functional, welcoming, and resilient campus that
supports long-term educational and community needs while maintaining compatibility with
surrounding development.
J. RECOMMENDATION:
Staff recommends approval of the Renton High School Replacement and Site Expansion combined
Preliminary Planned Urban Development and Final Planned Urban Development and Conditional Use
Permit, File No. LUA25-000343, PUD, CU-H, LC as depicted in the Site Plan (Exhibit 3), subject to the
following conditions:
1. The applicant shall comply with the modified mitigation measures issued as part of the Mitigated
Determination of Nonsignificance (MDNS) issued by the Renton School District on December 2,
2025.
2. The applicant shall record a formal Lot Combination to ensure the proposed buildings are not built
across property lines. The lot combination shall include all high school campus parcels as part of
the project. The instrument shall be recorded prior to the issuance of Temporary Certificate of
Occupancy.
3. The applicant shall mitigate the deficit in required tree credits in the following order of preference:
(1) tree planting on-site to the maximum extent feasible; (2) tree planting on other Renton School
District properties located within the City of Renton; and (3) payment of fee-in-lieu for any remaining
credits that cannot reasonably be accommodated through on-site or off-site planting. Prior to civil
construction permit issuance, the applicant shall submit a Tree Credit Mitigation Plan identifying
proposed planting locations, tree species and sizes, total credit values, installation and
maintenance responsibilities, and the number of remaining credits (if any) to be satisfied by fee -in-
lieu. Off-site planting locations shall be reviewed and approved by the Current Planning Project
Manager, and any remaining fee-in-lieu amount shall be paid in full prior to issuance of the
Temporary Certificate of Occupancy.
4. The applicant shall submit a surface mounted utility plan that includes cross -section details with
the civil construction permit application. The applicant shall work with franchise utilities to ensure,
as practical, utility boxes are located out of public ROW view, active common open spaces, and they
shall not displace required landscaping areas. The plan shall provide and identify screening
measures consistent with the overall design of the development. The surface mounted utility plan
shall be reviewed and approved by the Current Planning Project Manager prior to permit issuance. In
addition, staff recommends, as a condition of approval, that the applicant be required to submit a
rooftop equipment exhibit with the elevation plans associated with the building permit application.
The exhibit shall provide cross section details and identify proposed rooftop screening that is integral
and complementary to the architecture of the buildings. The exhibit shall be reviewed and approved
by the Current Planning Project Manager.
5. The applicant shall submit a construction outreach and traffic communication plan to notify
neighbors, road users, and affected agencies prior to major roadway disruption.
6. The applicant shall submit a Pedestrian-Oriented Space Plan with the civil construction permit
submittal. The plan shall: (1) calculate the total amount of pedestrian -oriented space required and
provided; (2) clearly identify on the site and landscape plans each area proposed to count toward
the requirement; and (3) demonstrate that every counted area includes all required elements,
including: accessible paved surfaces, average illumination of at least four (4) foot -candles on the
ground, and durable seating provided at a minimum rate of three linear feet (3’) per sixty (60) square
feet of plaza/open space. The plan shall also include cut -sheets for proposed lighting and site
City of Renton Department of Community & Economic Development
Renton High School Replacement and Site Expansion
Staff Report to the Hearing Examiner
LUA25-000343, PUD, CU-H, LC
Report of January 13, 2026 Page 70 of 70
SR_Renton High School_HEX Report_260106_FINAL
furnishings. The Pedestrian-Oriented Space Plan shall be reviewed and approved by the Current
Planning Project Manager prior to issuance of the civil construction permit.
7. The applicant shall submit a supplemental geotechnical memorandum prepared by the project
geotechnical engineer confirming that the final grading plan, utility alignments, retaining wall
designs, and foundation systems are consistent with the assumptions and recommendations of the
approved Geotechnical Engineering Report. The memorandum shall identify any additional
construction recommendations, temporary shoring needs, equipment setbacks, or stormwater
controls warranted by the final design. The memorandum shall be reviewed and approved by the
Current Planning Project Manager and Development Engineering Reviewer and incorporated into the
civil construction drawings. All geotechnical recommendations shall be implemented during
construction.
CITY OF RENTON
DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT
STAFF REPORT TO THE HEARING EXAMINER
EXHIBITS
Project Name:
Renton High School Replacement and Site
Expansion
Land Use File Number:
LUA25-000343, PUD, CU-H, LC
Date of Hearing
January 13, 2026
Staff Contact
Alex Morganroth
Principal Planner
Project Contact
Lisa Klein
AHBL, Inc.
2215 N 30th St, Suite
200, Tacoma, WA
98403
Project Location
400 S 2nd St, Renton,
WA 98057 (APN
0007200060) and 42
acquired parcels
The following exhibits are included with the Staff Report to the Hearing Examiner:
Exhibit 1: Staff Report to the Hearing Examiner
Exhibit 2: Neighborhood Detail Map
Exhibit 3: Site Plan
Exhibit 4: Floor Plans
Exhibit 5: Civil Plans
Exhibit 6: Conceptual Landscape Plans
Exhibit 7: Architectural Elevations
Exhibit 8: Architectural Renderings
Exhibit 9: Photometrics Plan
Exhibit 10: Screening Plan
Exhibit 11: Tree Retention Plan
Exhibit 12: Tree Retention/Land Clearing Plan (Arborist Report), prepared by Atlas Technical
Consultants LLC, dated September 4, 2025
Exhibit 13: Technical Information Report, prepared by AHBL, dated September 2025
Exhibit 14: Subsurface Exploration, Geologic Hazard, and Geotechnical Engineering Report,
prepared by Associated Earth Sciences, Inc., dated September 3, 2025
Exhibit 15: Transportation Technical Report, prepared by Heffron Transportation Inc, dated
September 16, 2025
Exhibit 16: Lighting Study, prepared by Musco Sports Lighting, LLC, dated September 12, 2025
Exhibit 17: Tree Retention and Credit Worksheet
Exhibit 18: Construction Mitigation Description
Exhibit 19: Neighborhood Meeting Packet
Exhibit 20: Conditional Use Permit Justification, prepared by Applicant, dated September 16,
2025
SR_Renton High School_HEX Report_260106_FINAL
Exhibit 21: South 2nd Street Improvement Waiver Request, prepared by Applicant, dated
September 5, 2025
Exhibit 22: Transportation Concurrency Memo, prepared by Nathan Janders, dated December
11, 2025
Exhibit 23: Federal Aviation Administration (FAA) No Hazard to Air Navigation Determination
Letter, dated April 22, 2025
Exhibit 24: SEPA Environmental Checklist and MDNS Notice of Consultation, Checklist dated
September 12, 2025
Exhibit 25: SEPA Mitigated Determination of Non-Significance (MDNS), issued November 5, 2025
Exhibit 26: City of Renton SEPA Comment Letter, dated November 19, 2025
Exhibit 27: SEPA Modified Mitigated Determination of Non-Significance (MDNS), dated
December 2, 2025
Exhibit 28: Becker Public Comment Letter, received on December 9, 2025
Exhibit 29: King Public Comment Email, dated October 22, 2025
Exhibit 30: City Response Email to Becker Comment Letter, dated December 10, 2025
Exhibit 31: City Response Email to King Comment Email, dated October 27, 2025
Exhibit 32: Advisory Notes