HomeMy WebLinkAboutDecision & Letter
May 20, 2020
SENT BY EMAIL TO ALL PARTIES OF RECORD
Maria Laura Musso‐Escudé, WSDOT
Acoustics, Air Quality, and Energy Specialist
15700 Dayton Ave N
Shoreline, WA 98011
Subject: Hearing Examiner’s Final Decision
RE: I‐405 Renton to Bellevue ‐ LUA‐20‐000058
Dear Ms. Musso‐Escudé:
Enclosed please find the Hearing Examiner’s Final Decision dated May 19, 2020. Also, this document is
immediately available on our website:
If you go to: Rentonwa.gov; “How do I”; Hearing Examiner (under Contact); “Decisions”; “Land
Use Decision”. The Decisions are filed by year and then alphabetical order by project name.
I can be reached at (425) 430‐6510 or jseth@rentonwa.gov. Thank you.
Sincerely,
Jason A. Seth, CMC
City Clerk
cc: Hearing Examiner
Clark Close Senior Planner
Jennifer Henning, Planning Director
Vanessa Dolbee, Current Planning Manager
Brianne Bannwarth, Development Engineering Manager
Craig Burnell, Building Official
Jennifer Cisneros, Planning Technician
Julia Medzegian, City Council Liaison
Parties of Record (6)
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BEFORE THE HEARING EXAMINER FOR THE CITY OF RENTON
RE: I-405 Renton to Bellevue - Project-Wide
Borings
Noise Variance
LUA20-000058, V-H
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FINAL DECISION
Summary
The Washington State Department of Transportation (“WSDOT”) has applied for a noise variance
from RMC 8-7-2 to drill 120-foot-deep soil borings at 30 locations between mile post 3.2 and 7.1 of
I-405 to gather geotechnical information for the widening and addition of a toll lane to I-405. Each
boring is anticipated to take between one (1) and two (2) nights per location and the entire project will
take a total of an estimated 65 nonconsecutive nights. The variance is requested to extend from the
date of variance approval through September 30, 2020. The variance is approved subject to conditions.
Testimony
Clark Close, Senior City of Renton Planner, summarized the proposal. Mr. Clark confirmed that
WSDOT had proposed ten as opposed to eleven noise mitigation measures as referenced in the
recommended conditions of approval, that one of the 11 was requested by the City. Mr. Clark noted
that staff did not find all of the mitigation measures identified in RMC 8-7-8D4 necessary given the
scope of the project and the prior working history with WSDOT. WSDOT and the City have worked
on the implementation of several noise variances in the past, and the code enforcement measures from
RCW 8-7-8D4 that have not been recommended were found unnecessary to ensure that the noise
impacts of the proposal are effectively mitigated. Mr. Clark noted that WSDOT will be requesting a
more significant noise variance for the next phases of the I-405 project and at that time the City is more
likely to recommend more of the mitigation measures from RMC 8-7-8D4. Mr. Clark noted that the
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City meets with WSDOT bimonthly and already has inspectors in the field so there is already a close
working relationship on the project. Mr. Clark confirmed that the project would not be retroactive and
is limited to future work. Drill borings have been shut down up to this point due to the Governor’s
proclamation in response to the pandemic. In Mr. Clark’s experience, there have been no complaints
about WSDOT noise from past projects or code enforcement issues.
Laura Musso-Escude, WSDOT representative, in response to examiner questions, noted that she came
to the conclusion that residents would not perceive the project noise as louder than background freeway
noise due to topography and structures located between the project site and the residences. She stated
that her analysis was based upon the location of each home affected by the proposal. She noted that the
borings are in clusters up to three and some homes may be exposed to the noise of a maximum of two
borings. At a maximum of two nights of work per boring, this means that the greatest number of nights
that any one home would be exposed to boring noise would be four. Ms. Musso-Escude noted that
some boring work was done in March by May Creek and WSDOT did not receive any complaints and
no one has ever had to have been placed in a hotel.
Bill Adams, WSDOT project manager, elaborated that the boring sites in clusters are still 100 feet
apart. Mr. Adams confirmed that congestion is very poor on I-405 and that the proposal is necessary
to reduce that congestion. He also clarified that the proposed I-405 widening is primarily necessary to
accommodate a toll lane. There will also be auxiliary lane additions that will help with the merging of
traffic. The project also involves seismic retrofits of existing bridges.
Jean, a neighbor, stated she lives on the east side of I-405 near Exit 5. She appreciates the public
hearing and the information provided addressed her concerns with the project.
Exhibits
The nine exhibits identified at page 2 of the Staff Report were admitted into the record during the
hearing. In addition, the staff power point was admitted as Exhibit 10, City of Renton COR maps of
the site as Ex. 11 and Google Maps of the site as Ex. 12.
FINDINGS OF FACT
Procedural:
1. Applicant. WSDOT, Laura Musso-Escude, 15700 Dayton Ave N, Shoreline, WA 98011
2. Hearing. A virtual hearing was held on the subject application on May 19, 2020 at 11:00 am in
the City of Renton, Zoom Meeting ID No. 841 8307 8741.
Substantive:
3. Project Description. (“WSDOT”) has applied for a noise variance from RMC 8-7-2 to drill 120-
foot deep soil borings at 30 locations between mile post 3.2 and 7.1 of I-405 to gather geotechnical
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information for the widening and addition of a toll lane to I-405. Each boring is anticipated to take
between one (1) and two (2) nights per location and the entire project will take a total of an estimated
65 nonconsecutive nights between the hours of 10 pm and 7 am. Construction noise would come from
construction equipment performing site preparation and drilling work tasks. The variance is requested
to extend from the date of variance approval through September 30, 2020.
Noise levels resulting from project construction activities are expected to generate peak noise
levels of 61 to 82 dBA heard at 50 feet from the source of the noise. These sound levels are expecte d
to diminish to a range of 51 to 66 decibels at a distance of 300 feet from the source of the noise. A
variance from RMC 8-7-2 is necessary in order to conduct the night time work, as maximum
permissible environmental noise levels (per WAC 173-60-040, incorporated by reference in RMC 8-
7) limit extended periods of noise from 10:00 pm to 7:00 am to levels between 45 dBA and 60 dBA,
with exceedances of 5 to 15 dBA permitted for periods of 1.5 to 15 minutes in any one-hour period
(WAC 173-60-040). The noisiest pieces of equipment that will be utilized includes 1-ton pickup
trucks/flat beds, excavators, chainsaws, and auger drills. Exhibit 7 identifies the maximum noise levels
proposed/associated with this equipment.
4. Neighborhood Characteristics. The drilling will occur within hearing distances of areas abutting
I-405 in Renton that are zoned residential, industrial and commercial. The most directly affected
properties are identified in the aerial photograph admitted as Ex. 3.
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5. Adverse Impacts. The noise generated by the proposal will be mitigated as much as reasonably
practicable and should not substantially adversely affect any single residential occupant. The most
nights that any one residence will be exposed to noise exceeding nighttime standards will be four and
WSDOT contends that with its proposed mitigation the noise levels will not be perceived as
significantly more than the existing background noise of I-405. WSDOT will provide advance notice
to affected property owners of the construction work along with a complaint number should the noise
still be a problem. In a worst case, WSDOT will provide hotel accommodations if no other noise
prevention mitigation proves effective.
The reason that WSDOT concluded that potentially affected residents should not perceive an
appreciable increase in freeway background noise is because of distance from the proposed drilling to
the residences and intervening structures and topography. WSDOT contends that the sound generated
from the construction work will decrease by 6-dBA with every doubling of the distance from a
stationary noise source. For example, a noise level of 70 dBA measured at 50 feet would be 64 dBA at
100 feet, 58 dBA at 200 feet and 52 dBA at 400 feet. In addition, noise also decreases if an object
interferes with the receiver’s line of sight to the noise source. Therefore, residents along the I-405
Corridor would perceive construction sounds at various decibel levels due to varying distances,
topography (berms or elevations changes), and other features (noise wall) that break the line of sight.
For example, sound attenuation for residents of Renton Hills and May Creek could perceive a lower
level of noise due to homes being located behind an embankment or behind a structure that would not
have a direct line of sight.
Noise levels projected for this project have been estimated to be between 61 to 82 dBA heard
at 50 feet. Night-time background traffic noise levels on I-405 average 73 dBA at 50 feet from the
nearest travel lane during daytime so including a nighttime reduction factor of 5 dBA the background
I-405 noise should be 68 dBA. When distance is incorporated into the assessment as well as topography
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and the proposed mitigation measures, WSDOT estimates that the nearest residences will not notice
the night-time work taking place at the site investigation sites.
WSDOT posted and mailed a notice to residents within 300 feet of the project corridor. No
public comments have been received. The borings will be conducted by Flatiron-Lane Joint Venture
(FLJV), the design builder awarded the contract for the project.
WSDOT has proposed several noise mitigation measures to lower the risk of any noise “spikes”
that could be noticed by residents. WSDOT proposed mitigation is as follows:
1. Truck tailgate banging is prohibited. All trucks shall be secured to prevent excessive
noise from banging.
2. All trucks performing export haul shall have well maintained bed liners as inspected
and approved by the Engineer.
3. All trucks shall be equipped with broadband ambient sensing back up alarms.
4. Temporary noise shields shall be installed to the extent necessary and feasible.
5. WSDOT/FLJV personnel will be updated and receive training on the conditions
imposed by this variance.
6. WSDOT will provide a WSDOT/FLJV complaint number as well as a list of designated
contact persons to potentially affected residents for the purpose of forwarding
complaints. As identified in the staff report, to ensure that complaints or issues
submitted by residents are adequately addressed, as necessary the contractor along with
WSDOT will work on alternative mitigation measures to stop the disruption.
7. WSDOT/FLJV will send notice of the proposed work in substantially the form of
Exhibit 8 by US mail to residents within 300 feet of the drilling sites at least ten (10)
days prior to the commencement of night-time work. This notification will include the
type of work, as well as a phone number and email address to request more information
or to express complaints or concerns.
8. WSDOT/FLJV will provide ear plugs and/or White Noise machines upon request if
during the notification process the residents requires them.
9. WSDOT/FLJV will respond to any notified resident if during the notification process
the residents requires special accommodations.
10. WSDOT/FLJV will implement night-time noise monitoring if complaints are received.
Staff concurs that the applicant has proposed effective mitigation measures that would limit the impacts
on the EDNA properties. Staff recommends two additional mitigation measures as follows:
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11. A summary of any noise-related complaints received and the response provided shall be
provided to the City’s project manager within five (5) days of receiving the complaint.
12. WSDOT shall maintain a current schedule of night-time work on its website that is
specific enough to provide notice to adjoining residents of when night-time work may
be heard from their properties.
In addition, this Decision adds the following requirements:
13. For any future mailings of Ex. 8, the notice shall be clarified to identify that the phone
number and email address listed in the notice can be used to express concerns or
complaints.
14. The special accommodation referenced in WSDOT proposed Condition No. 9 shall
include hotel accommodations. WSDOT will have the option of providing alternative
mitigation if the alternative mitigation would be as or more effective.
As addressed in Conclusion of Law No. 6, RMC 8-7-8(D)(4) includes some suggested
mitigation measures that have not been recommended in the staff report. The omitted mitigation
measures are code enforcement tools designed to facilitate staff oversight of compliance with noise
mitigation measures, such as cash security for inspections, staff access to the project site and the right
to revoke the variance upon noncompliance. Staff testified at the hearing that they have worked with
WSDOT on several other projects involving noise variances and that they have not found the code
enforcement tools necessary. Given this testimony, the mitigation measures from RMC 8-7-8D4
omitted from the staff recommendation are not found necessary to further minimize impacts and
therefore will not be imposed by this Decision.
6. Practical Difficulties and Special Circumstances. The variance is necessary to avoid daytime
I-405 closures that would cause significant traffic congestion that would likely spill over onto City
streets.
According to the WSDOT, I-405 is a major part of the Puget Sound Transportation system and
carries 132,000 AADT (Average Annual Daily Traffic.). Current congestion on I-405 is severe and
by many regarded as untenable. The I-405 Renton to Bellevue widening and Express Toll Lanes project
will reduce that congestion. The proposed borings are necessary to design critical improvements for
the project, such as bridges, noise walls, interchanges, drainage structures, fish passages, retaining
walls, etc.. No alternative locations are possible.
WSDOT maintains that daytime closures, full or partial, to perform this work would have the
potential to worsen the already congested I-405 corridor. Furthermore if frustrated I-405 users
encounter daytime closures, there is a high risk that traffic would overflow onto city arterials and local
streets increasing travel time of local residents, business and transit, and school bus drivers. In addition,
WSDOT has indicated that safety for drivers and construction workers improves when work is
conducted at night. The requested variance would enable the project to be completed without
exacerbating existing day time congestion.
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Conclusions of Law
1. Authority. Variances to RMC 8-7-2 in excess of two days in duration are subject to a public
hearing and Hearing Examiner review (RMC 8-7-8(A) and (C)).
2. Review Criteria. Variance criteria for variances to RMC 8-7-2 are governed by RMC 8-7-8(D).
RMC 8-7-8(D)(1): That the applicant suffers practical difficulties and unnecessary hardship and the
variance is necessary because of special circumstances applicable to the applicant’s property or
project, and that the strict application of this Chapter will deprive the subject property owner or
applicant of rights and privileges enjoyed by others.
3. The special circumstances are the proximity of I-405 to adjoining homes and the critical need
for night-time work to complete I-405 paving. City and WSDOT staff have concluded that closing off
sections of I-405 during daytime hours would severely and unacceptably increase congestion both in
the I-405 corridor and surrounding City streets. The geotechnical work is a necessary pre-requisite to
widening I-405, which is also critically important to reducing the severe congestion on I-405 during
daytime hours. Strict application of the City’s noise regulations would deprive WSDOT of the ability
to construct its development in a manner that is compatible with the interests of the surrounding
community. In this regard, strict adherence would deprive WSDOT of the rights other developers have
to construct their projects in an environmentally responsible manner.
RMC 8-7-8(D)(2): That the granting of the variance will not be materially detrimental to the public
health, welfare or safety, or unduly injurious to the property or improvements in the vicinity of the
location for which this variance is sought.
4. As determined in Finding of Fact No. 5, as conditioned and mitigated, the noise impacts are
mitigated to the extent reasonably practicable under the circumstances and will be of relatively short
duration. Ultimately, the mitigation measures require the applicant to provide hotel accommodations
if the noise proves too much for adjoining property owners. In this regard, beyond the temporary
inconvenience of relocation, the noise impacts are completely mitigated and as a result, the granting of
the variance would not be considered materially detrimental to the public welfare or injurious to
surrounding properties or improvements.
RMC 8-7-8(D)(3): That the variance sought is the minimum variance which will accomplish the
desired purpose.
5. As outlined in Finding of Fact No. 5 and Conclusion of Law No. 4, the applicant has taken all
measures it reasonably can to reduce noise impacts. As noted in Finding of Fact No. 6, the proposed
work must be done in night to avoid significant congestion impacts during the day on both I-405 and
City streets. Since the Applicant has done everything it reasonably can to reduce noise impacts and
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there is no feasible alternative to do the work during daytime hours, the variance is considered to be
the minimum variance that accomplishes WSDOT’s objective of reducing I-405 congestion,
RMC 8-7-8(D)(4): That the variance contains such conditions deemed to be necessary to limit the
impact of the variance on the residence or property owners impacted by the variance. The variance
approval may be subject to conditions including, but not limited to, the following:
a. Implementation of a noise monitoring program;
b. Maximum noise levels;
c. Limitation on types of equipment and use of particular equipment;
d. Limitation on back-up beepers for equipment;
e. Required use of noise shields or barriers;
f. Restrictions to specific times and days;
g. Specific requirements for documentation of compliance with the noise variance
conditions;
h. Specific requirements for notification to nearby residents;
i. Required cash security to pay for inspection services to verify compliance;
j. Required access to the project by the City to verify compliance with the noise variance
conditions;
k. Specific program to allow for temporary hotel vouchers to effected residents;
l. Requirements for written verification that all workers understand the noise variance
conditions for the project; and
m. Provision allowing the City to immediately revoke the variance approval if the variance
conditions are violated.
6. All mitigation measures identified above have been incorporated into the conditions imposed
upon the variance request by this Decision except for g, i, j and m. The mitigation measures that have
not been adopted by this decision are code enforcement and inspection tools designed to facilitate staff
oversight of the project. Staff were specifically asked about these measures during the hearing and
responded that given their long working history with WSDOT on several other noise variances and the
limited scope of the project, they did not find the additional mitigation measures necessary. Deference
is given to staff on this issue and the measures are not imposed.
RMC 8-7-8(D)(5): The importance of the services provided by the facility creating the noise and the
other impacts caused to the public safety, health and welfare balanced against the harm to be suffered
by residents or property owners receiving the increased noise permitted under this variance.
7. As outlined in Finding of Fact No. 6, the need for the variance is critical to helping WSDOT
alleviate congestion in a significant transportation corridor and as outlined in Finding of Fact No. 5 the
impacts to affected residences are temporary and have been fully mitigated. On balance, the noise
impacts to affected residents cannot be avoided given the need for the project.
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RMC 8-7-8(D)(6): The availability of practicable alternative locations or methods for the proposed
use which will generate the noise.
8. As noted in Finding of Fact No. 6, the geotechnical work is necessary to evaluate soil stability
for structures that have to be included in the I-405 widening project. There is no other alternative
location these structures could be constructed.
RMC 8-7-8(D)(7): The extent by which the prescribed noise limitations will be exceeded by the
variance and the extent and duration of the variance.
9. The extent and duration of noise impacts do not appear to be significant. As noted in Finding
of Fact No. 5, noise levels produced by construction equipment is expected to range from 61 to 82 dBA
at a distance of 50 feet from the source of the noise. These sound levels are expected to diminish to a
range of 51 to 66 dBA at a distance of 300 feet from the source of the noise. The applicant is proposing
a total of 65 non-consecutive nights to complete the work (up to September 30, 2020). The greatest
number of nights that any one residence will be exposed to noise exceeding nighttime standards will
be four nights and WSDOT contends that with its proposed mitigation the noise levels will not be
perceived as significantly more than the existing background noise of I-405.
DECISION
The proposed variance is justified for the reasons identified in the Conclusions of Law above and is
thereby approved. Approval is subject to compliance with the 14 conditions of approval listed in
Finding of Fact No. 5.
DATED this 19th day of May, 2020.
City of Renton Hearing Examiner
Appeal Right and Valuation Notices
RMC 8-7-8(F) provides that the final decision of the Hearing Examiner is subject to appeal to the
Renton City Council. RMC 8-7-8(F) further requires appeals of the Hearing Examiner’s decision to
be filed within fourteen (14) calendar days from the date of the Hearing Examiner’s decision.
Additional information regarding the appeal process may be obtained from the City Clerk’s Office,
Renton City Hall – 7th floor, (425) 430-6510.
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Affected property owners may request a change in valuation for property tax purposes
notwithstanding any program of revaluation.