HomeMy WebLinkAboutECF_NEPA_Evaluation_190315_v1.pdf 1
Categorically Excluded Not Subject to
(CENST) Section 58.5 Documentation,
Planned Action Concurrence Review
Renton Sunset Terrace Redevelopment | Homestead Willow Crest Townhomes
Prepared by: BERK Consulting, Inc. on behalf of Homestead Community Land Trust | February 2019
1 Background
1.1 SUNSET AREA COMMUNITY AND SUNSET TERRACE REDEVELOPMENT
The City of Renton, along with the Renton Housing Authority (RHA ), and other public, private, and
nonprofit agencies and developers, is redeveloping the Sunset Terrace public housing community plus
some peripheral sites that have been master planned for redevelopment along with Sunset Terrace for
a total of about 12.7 acres. See Exhibit 1. The master plan envisions a mixed-use, mixed-income
community with park and library and other civic and commercial uses. Mixed-use sites will have both
market rate and affordable rental housing in multi-story, multi-family townhomes and apartments,
along with commercial and retail space.
In order to meet National Environmental Policy Act (NEPA) and State Environmental Policy Act (SEPA)
requirements, the City of Renton issued the Draft Environmental Impact Statement (DEIS) for the City of
Renton Sunset Area Community Planned Action on December 17, 2010 and the Final Environmental Impact
Statement (FEIS) for the City of Renton Sunset Area Community Planned Action on April 1, 2011.1 The City
served as the Responsible Entity (RE) for NEPA compliance, and the lead agency for SEPA compliance.
The Sunset Terrace Master Site Plan Area was also the subject of subsequent revaluations/addenda in
2014 and 2016 when additional dwellings, alternative building locations, height, and street
reclassifications were considered in the Sunset Terrace area. The Master Site Plan is illustrated below.
1.2 HOMESTEAD WILLOW CREST PROPOSAL
Twelve Townhomes called Homestead Willow Crest are proposed on a vacant parcel at 1132 Edmonds
Ave NE (site 18 within the Master Site Plan). It has been studied in the above environmental documents
for a variety of densities, most recently in 2016 for 68 apartment units. Homestead Community Land Trust
is seeking SHOP federal funds and wishes to initiate NEPA review for a 12-unit townhome development.
See Exhibit 2 and Exhibit 3.
1 CH2MHill and ICF International. 2011. Sunset Area Community Planned Action NEPA/SEPA Environmental Impact Statement. Final. April.
(ICF 00593.10.) Bellevue and Seattle, WA. Prepared for City of Renton and the Renton Housing Authority, Renton, WA.
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 2
Exhibit 1. Sunset Terrace Master Site Plan 2016
Source: Mithun, City of Renton 2016
Exhibit 2. Homestead Willow Crest Townhomes Plan
Source: Third Place Design 2019.
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 3
Exhibit 3. Homestead Willow Crest Site Plan
Source: Third Place Design 2018.
Per the City’s request to the applicant, the site plan illustrates that a multi-family development west of the
townhomes on the balance of the vacant site is feasible conceptually. See Exhibit 4. This document does
not evaluate the multifamily housing to the west, focusing on the townhomes proposal.
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 4
Exhibit 4. Homestead Willow Crest Site Plan Phase I (under review)
Conceptual Future Multifamily Phase II (not part of review)
Source: Third Place Design 2019.
This CENST Documentation, Planned Action Concurrence Review addresses the Homestead Willow Crest
proposal, demonstrating it is in the range of the prior alternatives and environmental documents
identified above. Information provided to BERK Consulting, Inc. included:
▪ Homestead Willow Crest Townhomes, Site Plan, Third Place Design, January 7, 2019
▪ Homestead Willow Crest Townhomes Plans and Elevations, Third Place Design, November 7, 2018
▪ Sunset Crest Townhomes (now Homestead Willow Crest) Trip Generation Study, November 30, 2018
▪ Personal Communication, December 13, 2018; Brent Chastain, Third Place Design, to Lisa Grueter,
BERK Consulting, Inc. regarding impervious surface calculations for Homestead Willow Crest
Townhomes
▪ Personal Communication, December 14, 2018, Philippa Nye, Ally Community Development, to Lisa
Grueter, regarding Homestead Willow Crest Townhomes proposal and adjacent property
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 5
2 CENST Documentation, Planned Action Concurrence
Review Analysis
2.1 LAND USE AND AESTHETICS
The 2016 Reevaluation included the subject site (#18) as part of a Master Site Plan, and the concept
assumed an “Edmonds Apartments” development with a greater number of dwelling units, higher density,
greater height, and more extensive impervious footprint. Homestead Willow Crest proposes less
residential development with 12 townhomes and a lower height than previously studied; it does not
exceed development levels studied during 2011-2016. Design standards would apply.
The City of Renton has requested the applicant provide a concept for the remaining undeveloped site to
ensure it is feasible to develop; this CENST Documentation, Planned Action Concurrence Review for
Homestead Willow Crest does not address that portion of the site. It is possible that the balance of the
site will develop and would undergo its own review for NEPA/SEPA purposes.
Exhibit 5. Edmonds Apartment Assumptions 2016 Reevaluation and
Homestead Willow Crest Townhomes Proposal
FEATURE Edmonds Apartment
Concept 2016
Reevaluation
Homestead Willow
Crest Townhomes
2018 CENST
Documentation,
Planned Action
Concurrence Review
Share Of 2016
Development
Assumptions
Zone CV CV Same zone
Acres 1.73 0.59 34% of site acres
Assumed Units 68 12 18% of assumed units
Proposed Units Per Net Acre 40 20.45 Less density per net acre
Minimum Density Units Per Net
Acre
20 20 Achieves more than
minimum density
Maximum Density Units Per
Net Acre
80 80 Less than maximum zoning
Height in feet 50 37.5 Lesser in height
Parking Spaces 112 21 19% of assumed spaces
Conceptual Plan – Share of
Impervious Area square feet
39,200 18,882 48% of prior conceptual
plan impervious area;
cumulatively with other
development, results are in
range of EIS alternatives.
See Attachment A.
Assumed Pollutant Generating
Impervious Surfaces for Site
3,200 9,601 For this site, the PGIS is
greater than prior site
assumptions but
cumulatively with other
development is still in
range of EIS alternatives.
See Attachment A.
Source: Third Place Design; BERK 2018.
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 6
2.2 WATER RESOURCES / IMPERVIOUS SURFACES
Water resources was a key topic in the EIS; an accounting of effective impervious area was tracked
particularly for the NEPA analysis.
As shown in Exhibit 5, the proposal would generate less total impervious surface assumed for the site;
cumulatively with other Master Site Plan development, it would not exceed the prior range of impervious
area calculated for the EIS Alternatives. Homestead Willow Crest would also contribute PGIS area, but
cumulative results would be in the range of the prior EIS alternatives per Attachment A.
On the adjacent Glenwood Townhomes site to the east, approximately 900 square feet of the existing
pervious paving in parking lot will be removed and replaced with pervious paving or planting area to
allow the shared access drive to cut through that area to the Homestead Willow Crest development. The
Homestead Willow Crest development is not proposed to include pervious paving. However, Homestead
Willow Crest does not exceed the total impervious surface assumptions for the Edmonds Apartment
concept and cumulatively results are within the range of impervious surface assumption for the Master
Site Plan area.
City stormwater standards and plans would apply per ROD mitigation measures. See Attachment C.
If there is a future proposal on the western portion of the site, the City would review its compliance with
water resources requirements including the impervious analysis.
2.3 NATURAL ENVIRONMENT AND RESOURCES
(EARTH, AIR QUALITY/ENERGY, PLANTS AND ANIMALS)
The Homestead Willow Crest Townhomes site does not appear to have mapped critical areas. It would
contribute an incremental amount of greenhouse gas emissions and energy use but not exceed
assumptions in the 2011 EIS and subsequent Reevaluations. See Attachment C for ROD mitigation
measures.
2.4 CULTURAL RESOURCES
Through the 2011 NEPA process, a cultural resources survey was conducted on Site 18 (the proposal site)
and no archaeological resources or historic resources were found on the property.
Agency notifications and procedures were addressed at that time as documented in the 2011 Record of
Decision and 2014/2016 Revised Records of Decision. Inadvertent discovery mitigation measures would
apply.
2.5 TRANSPORTATION
It is estimated that 12 townhome units would generate approximately 88 vehicle trips over the course of
a typical weekday including 5 trips during the weekday AM peak hour and 7 trips during the weekday
PM peak hour. See Attachment B. The larger Edmonds Apartment development would have generated
greater trips, which were already addressed in the 2011 EIS and 2014 Reevaluation. No impacts
beyond the prior analysis is anticipated. The development would be required to meet City access
standards and provide for transportation impact fees.
The small number of trips would be deducted from the City’s traffic trip bank in the SEPA Planned Action
Ordinance.
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 7
2.6 NOISE AND ENVIRONMENTAL HEALTH
The site is located away from SR 900 where there is more traffic related noise. Environmental health
hazards were not identified in the 2011 EIS for the property, and standard protocols for development
would apply per Attachment C.
2.7 PARKS AND RECREATION, PUBLIC SERVICES, AND UTILITIES
The development levels on the Homestead Willow Crest would not exceed prior development levels for
the Edmonds Apartments concept. There would be some demand for parks and recreation, public
services, and utilities, and ROD mitigation measures would apply. See Attachment C.
2.8 SOCIOECONOMICS AND ENVIRONMENTAL JUSTICE
The Homestead Willow Crest Townhomes offer affordable ownership housing on a site planned and
considered for residential uses. No impacts are anticipated.
2.9 SUMMARY
Based on this CENST Documentation, Planned Action Concurrence Review, the Homestead Willow Crest
Townhomes fits in the range of the prior environmental review conducted for the Sunset Area and Sunset
Terrace Redevelopment.
Upon the City of Renton’s Responsible Entity determination, this document supports a CENST under 24 CFR
58.35(b) (7): Approval of supplemental assistance (including insurance or guarantee) to a project
previously approved under this part, if the approval is made by the same responsible entity that
conducted the environmental review on the original project and re-evaluation of the environmental
findings is not required under § 58.47.
Pending the City or Renton’s Responsible Official determination, this document could support a Planned
Action SEPA review under WAC 197-11 and the City’s SEPA rules, demonstrating the proposal was
addressed in the cumulative analysis of the EIS and subsequent addenda issued in 2014 and 2016.
Preparer
________________________________
Lisa Grueter, AICP, Principal, BERK Consulting, Inc.
Date: February 11, 2019
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 8
Attachments
Attachment A: Impervious Analysis – Revised with Homestead Willow Crest Development
The CENST Documentation, Planned Action Concurrence Review 2019 analysis demonstrates impervious
surface results that are less than 2011 EIS Alternatives and similar to Reevaluation 2016 results, and
there is no change to the range or scope of effects previously considered.
*Note: This 2019 Review updates assumptions for Homestead Willow Crest Townhomes as part of Site 18; the analysis
assumes some impervious area would be added on the remaining vacant portion of Site 18 similar to the conceptual site plan
for Phase II; however Phase II is subject to future NEPA review as appropriate by the Responsible Entity.
FEIS Alternative 3 Land Cover Analysis
Location
Total
Area
(acres)
Total
Impervious
Area
(acres)
Total
Pervious
Area
(acres)
Total
PGIS
(acres)
Total
Untreated
PGIS
(acres)
Effective
Impervious
(acres)
Potential Replacement Sites 3.06 2.28 0.78 0.62 0.26 2.14
Potential Sunset Terrace Redevelopment
Subarea 12.64 7.04 6.02 2.43 0 4.22
Total 15.70 9.32 6.8 3.05 0.26 6.36
FEIS Preferred Alternative Land Cover Analysis
Location
Total
Area
(acres)
Total
Impervious
Area
(acres)
Total
Pervious
Area
(acres)
Total
PGIS
(acres)
Total
Untreated
PGIS
(acres)
Effective
Impervious
(acres)
Potential Replacement Sites 3.06 2.57 0.49 0.41 0 2.39
Potential Sunset Terrace Redevelopment
Subarea 12.64 6.1 6.54 1.7 0 3.66
Total 15.70 8.67 7.03 2.11 0 6.15
Preliminary Land Cover Analysis Master Plan and Related Sites – Reevaluation 2015-16 Land Cover Analysis
Location Total Area
(acres)
Total
Impervious
Area (acres)
Total
Pervious
Area
(acres)
Total PGIS
(acres)
Total
Untreated
PGIS (acres)
Effective
Impervious
(acres)
Potential Replacement Sites 4.14 1.14 3.00 0.29 0.26 0.68
Potential Sunset Terrace Redevelopment
Subarea 12.73 7.03 5.70 1.27 0 4.22
Total 16.87 8.17 8.71 1.57 0.26 4.90
Preliminary Land Cover Analysis Master Plan and Related Sites – 2019 CENST Review Land Cover Analysis
Location Total Area
(acres)
Total
Impervious
Area (acres)
Total
Pervious
Area
(acres)
Total PGIS
(acres)
Total
Untreated
PGIS (acres)
Effective
Impervious
(acres)*
Potential Replacement Sites 4.14 1.14 3.00 0.29 0.26 0.68
Potential Sunset Terrace Redevelopment
Subarea 12.73 7.03 5.70 1.38 0 4.22
Total 16.87 8.17 8.71 1.67 0.26 4.90
*Includes rest of Edmonds Apartment site.
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 9
CENST Documentation Impervious Area Comparison: 2019
Comparison of Homestead Willow
Crest Townhomes to:
Total
Area
(acres)
Total
Impervious
Area
(acres)
Total
Pervious
Area
(acres)
Total
PGIS
(acres)
Total
Untreated
PGIS (acres)
Effective
Impervious
(acres)
2015-16 Evaluation - - - 0.10 - -
2011 Final EIS Preferred 1.17 -0.50 1.68 -0.44 0.26 -1.25
2011 Final EIS Alternative 3 1.17 -1.15 1.91 -1.38 0.00 -1.46
As shown in Exhibit 5, the proposal would generate less total impervious surface assumed for the site;
cumulatively with other Master Site Plan development, it would not exceed the prior range of impervious
area calculated for the EIS Alternatives. Homestead Willow Crest would also contribute PGIS area, but
cumulative results would be substantially less than the Final EIS alternatives and would not be outside the
range or scope studied.
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 10
Attachment B: Transportation Evaluation
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 11
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 12
Attachment C: Record of Decision – Excerpt of Mitigation Measures
The Record of Decision (ROD) under NEPA and the Planned Action Ordinance under SEPA apply identical
mitigation measures. References to “planned actions” apply to Proposals under NEPA.
Earth
On the Homestead Willow Crest Portion of Site 18, there are no mapped geologic hazards. The need to
address City critical areas ordinances will be determined by the City in permit review. The following
mitigation measures included in the Record of Decision (ROD) appear applicable to the development.
▪ Apply erosion-control best management practices (BMPs), as described in Appendix D of the City of
Renton Amendments to the King County Surface Water Design Manual.
▪ Planned Action applicants shall identify in their applications the source of earth material to be used
in construction and shall consider earth material reuse and provide information to the City regarding
why earth material reuse is not feasible if it is not proposed. The City may condition the planned
action application to provide for earth material reuse where feasible.
Air Quality
As part of the cumulative development studied in the 2011 EIS and subsequent reevaluations, the
Homestead Willow Crest Townhomes would be subject to Air Quality/Greenhouse Gas (GHG) mitigation
measures listed in the ROD and the SEPA Planned Action Ordinance. These include:
▪ Construction contractors will be required to implement air quality control plans and BMPs listed in the
ROD.
▪ Planned Action applicants for residential developments shall provide information regarding the
feasibility and applicability of indoor air quality measures. The City may condition Planned Action
applications to incorporate feasible indoor air quality measures.
▪ The City shall require development applicants to consider the reduction measures shown in [ROD]
Exhibit B, Section 2, Table 62 for their projects, and as part of their application explain what
reduction measures are included and why other measures found in the table are not included or are
not applicable. The City may condition Planned Action applications to incorporate feasible GHG
reduction measures.
Water Resources
The primary mitigation measure is to comply with the City’s surface water standards and Sunset Area
Surface Water Master Plan (CH2M HILL, 2011).
The Sunset Area Surface Water Master Plan identifies that Edmonds Ave NE to the west would be a
“Green Collector Arterial,” which would include green infrastructure design and presumably less
impervious surfaces (e.g. rain gardens and pervious sidewalks).
2 Exhibit B has been amended in 2014 and 2016 with additional tables in the Land Capacity section and description of alternatives, but
subsequent tables were not properly renumbered. Table 6 is referenced in Exhibit B Section 2 applicable to Air Quality.
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 13
Plants and Animals
With implementation of proposed stormwater features or standards, no mitigation is required.
Energy
Energy conditions require consideration of trip-reduction measures and energy conservation measures,
similar to and related to Air Quality mitigation measures. The development contributes relatively few
trips and does not require a traffic impact analysis; applicable traffic impact fees would apply.
Compliance with Air Quality mitigation above would also address Energy.
▪ The City shall require development applicants to consider trip-reduction measures and energy
conservation, and as part of their application explain what reduction measures are included and
which ones are not included (based on [ROD] Exhibit B Tables 6 or Table 10). The City may condition
Planned Action applications to incorporate feasible trip reduction and energy conservation measures.
Noise
Construction noise requirements identified in the ROD apply and can be made conditions of approval.
These include:
▪ Locate stationary equipment away from receiving properties.
▪ Erect portable noise barriers around loud stationary equipment located near sensitive receivers.
▪ Limit construction activities to between 7:00 a.m. and 10:00 p.m. to avoid sensitive nighttime hours.
▪ Turn off idling construction equipment.
▪ Require contractors to rigorously maintain all equipment.
▪ Train construction crews to avoid unnecessarily loud actions (e.g., dropping bundles of rebar onto the
ground or dragging steel plates across pavement) near noise-sensitive areas.
ROD mitigation gives the City authority to condition use of double-paned windows or other treatments
per the Energy Code to reduce traffic noise. However, the site is located away from SR-900.
▪ Although traffic noise is exempt from City noise ordinance, based on site-specific considerations, the
City may at its discretion require the new development to install double-pane glass windows or other
building insulation measures using its authority under the Washington State Energy Code (RMC 4-5-
040).
Environmental Health
The proposal is required to provide hazardous materials awareness training, implement a contingency
plan to meet state laws, implement stormwater pollution prevention plan, etc. per the ROD.
▪ Since encountering unreported spills or unreported underground fuel tanks is a risk when performing
construction, contractors shall be required to provide hazardous materials awareness training to all
grading and excavation crews on how to identify any suspected contaminated soil or groundwater,
and how to alert supervisors in the event of suspected contaminated material. Signs of potential
contaminated soil include stained soil, odors, oily sheen, or the presence of debris.
February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 14
Land Use
Dust control and construction traffic management will be required and could be applied as conditions of
approval.
▪ Under all alternatives, the City shall require planned action applicants to implement appropriate
construction mitigation measures, including but not limited to dust control and construction traffic
management.
Socioeconomics
The proposal does not involve changes to SR 900 by WSDOT. The proposal does not involve public
housing tenant relocation. Thus, no measures apply.
Housing
Relocation assistance is not needed; the site is vacant. Other sites are available for Sunset Terrace
housing relocation assistance. The proposed development will offer affordable ownership housing
opportunities.
Environmental Justice
No measures apply.
Aesthetics
Per the ROD, future development occurring under any of the alternatives shall conform to the Renton
Municipal Code design standards, including but not limited to the following:
▪ Urban design standards contained in RMC 4-3-100,
▪ Residential Design and Open Space Standards contained in RMC 4-2-115, and
▪ Lighting Standards contained in RMC 4-4-075.
Historic/Cultural
The City must require compliance with inadvertent discovery per ROD Attachment B, page 62:
Attachment 1: Draft EIS, Cultural Resources Appendix J, Plan and Procedures for Dealing with the
Unanticipated Discovery.
Transportation
The development would be required to pay its fair share of transportation impact fees to address system
improvements needed for its contribution to growth in trips.
Construction mitigation measures would apply.
Parks and Recreation
City staff will confirm compliance with City open space standards and consistency with Park Impact Fee
requirements.
Utilities
The development will be required to implement water system and sewer system improvements per City
plans, codes, and specifications.