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RE: Do I need a SEPA?
From ECY RE SEPA HELP <sepahelp@ECY.WA.GOV>
Date Wed 2/11/2026 3:13 PM
To Gabriella Golzarian <GGolzarian@rentonwa.gov>
Hi Gabriella,
Thanks for reaching out to SEPA help. Based on the information you shared, it seems like the SEPA
exemption in WAC 197-11-800(24)(h) could be applicable to this tree pruning project located in a public
park. However, when applying your exemptions, you have to read them in the context of WAC 197-11-
305. So if any aspect of the proposal doesn’t fit under one of the exemptions, then it will not be exempt.
Also, if the trees are located in a designated critical area, you’ll need to check Renton’s adopted SEPA
procedures and confirm this isn’t one of the exemptions that the City has selected as not being
applicable in critical areas (see WAC 197-11-908, and below). It looks like the City’s SEPA procedures are
in Section 4-9-070 – see H. (3.), Inapplicable Exemptions.
(24) Natural resources management. In addition to the other exemptions contained in this
section, the following natural resources management activities shall be exempt:
(a) Issuance of new grazing leases covering a section of land or less; and issuance of all grazing
leases for land that has been subject to a grazing lease within the previous 10 years.
(b) Licenses or approvals to remove firewood.
(c) Issuance of agricultural leases covering 160 contiguous acres or less.
(d) Issuance of leases for Christmas tree harvesting or brush picking.
(e) Issuance of leases for school sites.
(f) Issuance of leases for, and placement of, mooring buoys designed to serve pleasure craft.
(g) Development of recreational sites not specifically designed for all-terrain vehicles and not
including more than 12 campsites.
(h) Periodic use of chemical or mechanical means to maintain public park and recreational land:
Provided, That chemicals used are approved by the Washington state department of agriculture
and applied by licensed personnel. This exemption shall not apply to the use of chemicals within
watersheds that are controlled for the purpose of drinking water quality.
(i) Issuance of rights of way, easements and use permits to use existing roads in nonresidential
areas.
(j) Establishment of natural area preserves to be used for scientific research and education and
for the protection of rare flora and fauna, under the procedures of chapter 79.70 RCW.
WAC 197-11-305
Categorical exemptions.
(1) If a proposal fits within any of the provisions in Part Nine of these rules, the proposal shall be
categorically exempt from threshold determination requirements (WAC 197-11-720) except as
follows:
(a) The proposal is not exempt under WAC 197-11-908, critical areas.
(b) The proposal is a segment of a proposal that includes:
(i) A series of actions, physically or functionally related to each other, some of which are
categorically exempt and some of which are not; or
(ii) A series of exempt actions that are physically or functionally related to each other, and that
together may have a probable significant adverse environmental impact in the judgment of an
agency with jurisdiction. If so, that agency shall be the lead agency, unless the agencies with
jurisdiction agree that another agency should be the lead agency. Agencies may petition the
department of ecology to resolve disputes (WAC 197-11-946).
For such proposals, the agency or applicant may proceed with the exempt aspects of the
proposals, prior to conducting environmental review, if the requirements of WAC 197-11-070 are
met.
(2) An agency is not required to document that a proposal is categorically exempt. Agencies may
note on an application that a proposal is categorically exempt or place such a determination in
agency files.
WAC 197-11-908
Critical areas.
(1) Each county/city may select certain categorical exemptions that do not apply in one or more
critical areas designated in a critical areas ordinance adopted under GMA (RCW 36.70A.060). The
selection of exemptions that will not apply may be made from the following subsections of
WAC 197-11-800: (1), (2)(a) through (h), (3), (5), (6)(a), (13)(c), (23)(a) through (g), and (24)(c),
(e), (g), (h).
The scope of environmental review of actions within these areas shall be limited to:
(a) Documenting whether the proposal is consistent with the requirements of the critical areas
ordinance; and
(b) Evaluating potentially significant impacts on the critical area resources not adequately
addressed by GMA planning documents and development regulations, if any, including any
additional mitigation measures needed to protect the critical areas in order to achieve
consistency with SEPA and other applicable environmental review laws.
All other categorical exemptions apply whether or not the proposal will be located within a
critical area. Exemptions selected by an agency under this section shall be listed in the agency's
SEPA procedures (WAC 197-11-906).
(2) Proposals that will be located within critical areas are to be treated no differently than other
proposals under this chapter, except as stated in the prior subsection. A threshold determination
shall be made for all such actions, and an EIS shall not be automatically required for a proposal
merely because it is proposed for location in a critical area.
Let me know if you have any additional questions.
Thank you,
Kristy Hollinger (she/her)
Planner | SEPA Environmental Review
WA Department of Ecology
564-250-0620
300 Desmond Drive SE, Lacey, WA 98503
From: Gabriella Golzarian <GGolzarian@rentonwa.gov>
Sent: Tuesday, February 10, 2026 2:27 PM
To: ECY RE SEPA HELP <sepahelp@ECY.WA.GOV>
Subject: Do I need a SEPA?
External Email
Hello,
I am looking to prune some large black cottonwoods on the bank of the cedar river in downtown renton. I am
currently working on my HPA and I wonder if I need a SEPA as well.
Thank you!
Gabriella Golzarian
Interim Urban Forestry Manager
Phone: 425-430-6698 Email: GGolzarian@RentonWA.gov