HomeMy WebLinkAboutExhibit_3__Street_Modification_Request_Justification_Letter
May 19, 2026
City of Renton
Community Development Department
1055 S Grady Way
Renton, WA 98057
Subject: Kennydale Gateway Modification Request
Core Project No. 19030
Dear Project Planner/Reviewer,
We would like to request a street standards modification for the Kennydale Gateway project. The project
requests an exemption from RMC 4-6-090 for underground installation of utility lines. This code
requirement involves the undergrounding of all onsite and fronting overhead lines and poles, other than
the existing electric transmission systems of voltage 55 KV or more. Onsite overhead power will be
undergrounded, however the project requests a modification specifically regarding the overhead power
along the frontage of the project site in Lake Washington Blvd N.
Per City of Renton, the following information needs to be provided in order to approve the requested
modification:
a) Substantially implements the policy direction of the policies and objectives of the
Comprehensive Plan Land Use Element and the Community Design Element and the
proposed modification is the minimum adjustment necessary to implement these policies
and objectives;
The existing utility corridor includes high-voltage overhead electrical facilities that will remain in place.
As a result, requiring the project to underground only the lower-tier facilities would not remove the
primary overhead utility presence, would not eliminate the poles, and would provide limited incremental
community design benefit.
The modification is also the minimum adjustment necessary. The applicant is not requesting a broad
waiver from utility coordination, frontage improvements, public safety requirements, or future utility
accommodation. The request is limited to relief from undergrounding existing overhead facilities in a
constrained corridor where substantial overhead electrical infrastructure will remain in place. This
approach preserves the function of the existing utility system, avoids unnecessary disturbance, and
remains consistent with Comprehensive Plan policies.
b) Will meet the objectives and safety, function, appearance, environmental protection and
maintainability intended by the Code requirements, based upon sound engineering
judgement;
The proposed modification will meet the objectives of the Code based on sound engineering judgment.
From a safety and functional standpoint, the existing utility facilities will remain subject to the utility
purveyor’s design, clearance, access, and maintenance requirements. The project will not create a new
Docusign Envelope ID: 3E81CC6C-CBC3-815C-8106-039098F7FAFB
May 19, 2026 City of Renton Page 2
unsafe condition, reduce required clearances, or interfere with the continued operation and maintenance
of the existing electrical and communication facilities.
From an appearance standpoint, the modification does not change the visual condition intended to be
addressed by undergrounding because the dominant overhead elements, including the existing poles and
high-voltage overhead conductors, will remain. Partial undergrounding of lower-tier facilities would not
result in removal of the overhead utility corridor and therefore would not achieve the primary visual
objective associated with undergrounding.
From an environmental protection and maintainability standpoint, avoiding unnecessary undergrounding
reduces trenching, pavement disturbance, utility conflicts, construction duration, and potential impacts to
existing underground infrastructure. Maintaining the existing overhead configuration is therefore a
practical and maintainable solution for this location.
c) Will not be injurious to other property(ies) in the vicinity;
The requested modification will not be injurious to properties in the vicinity. The existing overhead utility
facilities are already established in the corridor, and the modification would maintain the existing utility
configuration rather than introduce a new use or new physical encumbrance on adjacent properties.
Existing utility access, maintenance obligations, and safety clearances will remain controlled by the utility
purveyor and applicable standards.
Because the high-voltage facilities and supporting pole infrastructure will remain overhead regardless of
this request, requiring partial undergrounding would not eliminate the overhead condition for neighboring
properties. Allowing the modification also avoids additional construction disturbance, trenching, and
temporary impacts to adjacent properties, access, and existing utilities.
d) Conforms to the intent and purpose of the Code;
The requested modification conforms to the intent and purpose of the Code. The modification is
consistent with the Code’s intent because it avoids imposing costly and disruptive undergrounding where
the primary overhead utility condition will remain and where the resulting public benefit would be
minimal.
e) Can be shown to be justified and required for the use and situation intended; and
The modification is justified and required for the specific use and situation intended. The project frontage
contains an existing multi-tier overhead utility corridor with high-voltage electrical facilities on the upper
tier, distribution-level electrical facilities on the middle tier, and communication facilities on the lower
tier. The high-voltage facilities are not proposed to be undergrounded and will remain overhead.
Therefore, full removal of poles and overhead utility infrastructure is not feasible as part of this project.
Requiring the project to underground only a portion of the overhead facilities would create a
disproportionate burden without achieving the intended result of removing overhead utility infrastructure
from the corridor. The request is therefore justified by the physical utility condition, the continued
presence of high-voltage overhead facilities, and the limited benefit of partial undergrounding.
f) Will not create adverse impacts to other property(ies) in the vicinity.
Docusign Envelope ID: 3E81CC6C-CBC3-815C-8106-039098F7FAFB
May 19, 2026 City of Renton Page 3
The requested modification will not create adverse impacts to properties in the vicinity. The modification
maintains the existing overhead utility condition and does not introduce new utility impacts, new access
restrictions, or new safety hazards to adjacent properties. The modification would also reduce temporary
adverse impacts by avoiding unnecessary trenching, utility conflicts, and construction activity associated
with partial undergrounding.
We look forward to hearing from you regarding this request for street standard modifications.
Sincerely,
CORE DESIGN, INC.
Daniel J. Larson
Project Manager
Docusign Envelope ID: 3E81CC6C-CBC3-815C-8106-039098F7FAFB