HomeMy WebLinkAboutSR_ERC_Report_Quasi-Judicial_Appeals_180806.pdfDEPARTMENT OF COMMUNITY
AND ECONOMIC DEVELOPMENT
ERC Report: Quasi‐Judicial Appeal Regulations LUA18‐000492, ECF
ENVIRONMENTAL REVIEW COMMITTEE REPORT
ERC MEETING DATE: August 6, 2018
Project Name: Quasi‐Judicial Appeal Regulations
Owner: City of Renton
Applicant: City of Renton
Contact: Leslie Clark, Senior Assistant City Attorney
File Number: LUA18‐000492, ECF
Project Manager: Leslie Clark, Senior Assistant City Attorney
Project Summary: The applicant is requesting Environmental (SEPA) Review for amendments to
the Renton Municipal Code (1) to expressly allow the City Council to render a
quasi‐judicial appeal decision that affirms the underlying decision without
substantive review, if necessary to avoid an undue burden on the City due to
the complexity of the particular quasi‐judicial appeal; and (2) to clarify the
environmental appeals process in RMC 4‐9‐070.R. These regulations would be
citywide.
Project Location: Citywide
Exist. Bldg. Area SF: N/A Proposed New Bldg. Area
(footprint):
Proposed New Bldg. Area (gross):
N/A
N/A
Site Area: N/A Total Building Area GSF: N/A
STAFF
RECOMMENDATION:
Staff Recommends that the Environmental Review Committee issue a
Determination of Non‐Significance (DNS).
PART ONE: PROJECT DESCRIPTION / BACKGROUND
This proposed amendment to the Renton Municipal Code addresses two issues relating to quasi‐judicial
appeals: (1) updating the pathway for quasi‐judicial appeals by expressly allowing the City Council to
render a quasi‐judicial appeal decision that affirms the underlying decision without substantive review, if
necessary to avoid an undue burden on the City due to the complexity of the particular quasi‐judicial
appeal and (2) resolving an ambiguity caused by the language of RMC 4‐9‐070.R (regarding environmental
appeals).
Issue 1: Updating the pathway for quasi‐judicial appeals
Currently, RMC 4‐8‐080 designates that many land use decisions rendered by the Hearing Examiner
are appealable to the City Council in a quasi‐judicial appeal. This pathway can create burdens on
and risks to the City and the City Council. This is particularly true for complex appeals with multiple
parties of record or multiple associated permits, that cross jurisdictional boundaries, and/or that
implicate treaty rights.
City of Renton Department of Community & Economic Development Environmental Review Committee Report
QUASI‐JUDICIAL APPEAL REGULATIONS LUA18‐000492, ECF
Report of August 6, 2018 Page 2 of 3
ERC Report: Quasi‐Judicial Appeal Regulations LUA18‐000492, ECF
Proposed Text Amendments to Code
Staff recommends amending the appeal provisions of the Renton Municipal Code to update the
pathway for quasi‐judicial appeals by expressly allowing the City Council to render a decision
affirming the underlying decision without substantive review, if necessary to avoid an undue
burden on the City.
Issue 2: Resolving the ambiguity in RMC 4‐9‐070.R
The language of RMC 4‐9‐070.R designates the Hearing Examiner as the appellate body when a
project or action is “granted, conditioned, or denied on the basis of [the State Environmental Policy
Act] by a nonelected official...” This language creates three ambiguities: (1) The Hearing Examiner
hears certain SEPA appeal issues, but per RMC 4‐8‐080, for some project types the Hearing
Examiner is also the underlying decision maker; (2) although the Hearing Examiner hears certain
SEPA appeal issues, per RMC 4‐8‐080, for some project types the City Council hears the other
appeal issues on the same proposal; and (3) the code language is unclear whether the provisions
apply to both SEPA procedural appeals and SEPA substantive appeals.
Proposed Text Amendments to Code
Staff recommends amending RMC 4‐9‐070.R to (1) provide that where the Hearing Examiner is the
decision maker, the Hearing Examiner is not also the appellate body (which will also avoid the
circumstance in which the Hearing Examiner decides some appeal issues while the City Council the
decides the other appeal issues on the same proposal) and (2) clarify that quasi‐judicial appeals are
available only for SEPA substantive appeals; SEPA procedural appeals will instead be directed to
superior court.
PART TWO: ENVIRONMENTAL REVIEW
In compliance with RCW 43.21C.240, the following environmental (SEPA) review addresses only those
project impacts that are not adequately addressed under existing development standards and
environmental regulations.
A. Environmental Threshold Recommendation
Based on analysis of probable impacts from the proposal, staff recommends that the Responsible
Officials:
Issue a DNS with a 14‐day Appeal Period.
B. Mitigation Measures
None.
C. Exhibits
None.
D. Environmental Impacts
There are no environmental impacts that are anticipated to occur in conjunction with the proposal.
City of Renton Department of Community & Economic Development Environmental Review Committee Report
QUASI‐JUDICIAL APPEAL REGULATIONS LUA18‐000492, ECF
Report of August 6, 2018 Page 3 of 3
ERC Report: Quasi‐Judicial Appeal Regulations LUA18‐000492, ECF
E. Comments of Reviewing Departments
The proposal will be circulated to City Department Division Reviewers and appropriate agencies.
All substantive comments will be provided to the Responsible Officials for their consideration and
possible recommendation that the comments be incorporated as “Advisory Notes to Applicant.”
Environmental Determination Appeal Process: Comments and Appeals of the environmental
determination must be filed in writing on or before 5:00 PM on August 24, 2018.
Renton Municipal Code Section 4‐8‐110.B governs appeals to the Hearing Examiner. Appeals must be filed
in writing at the City Clerk’s office along with the required fee. Additional information regarding the
appeal process may be obtained from the City Clerk’s Office, Renton City Hall ‐ 7th Floor, 1055 S. Grady
Way, Renton WA 98057.