HomeMy WebLinkAboutERC_Report_RMC_Title_IV_Docket_17C_FinalDEPARTMENT OF COMMUNITY
AND ECONOMIC DEVELOPMENT
ERC Report 2022 Docket #17, Group C
ENVIRONMENTAL REVIEW COMMITTEE REPORT
ERC MEETING DATE: September 12, 2022
Project Name: 2022 Docket #17, Group C
Project Number: LUA22-000296, ECF
Project Manager: Angie Mathias, Long Range Planning Manager
Owner: City of Renton
Applicant: City of Renton
Contact: Angie Mathias, 425-430-6576
Project Location: All docket items are citywide.
Project Summary: The applicant is requesting Environmental (SEPA) Review to review for the following
non-project items:
#D-220 Flood Regulations The purpose of the proposed code amendments is to revise
RMC 4-3-050, Critical Areas Regulations, to comply with 2021 updates to the FEMA
National Flood Insurance Program (NFIP) Community Rating System (CRS) program
requirements.
#D-221 Smoking Clubs or Lounges Consider permissibility of smoking clubs and/or
lounges for the purpose of smoking tobacco products in the City of Renton. Review of
applicable Washington State and King County Department of Public Health standards.
Marijuana consumption lounges or “cannabis cafes” are currently not allowed in
Washington State and shall not be a consideration.
#D-222 Submittal Requirements Amendments The purpose of this proposed
amendment is to update land use permit application submittal requirements to
include additional submittal items for modifications and short plat applications in
order to improve future permit submittal packages. In addition, the amendment seek
to ensure that land use applications include project proposals which are reasonably
consistent with development regulations, without project characteristics which would
necessitate major amendments for compliance with code.
#D-223 Citywide Minimum Standards for Multifamily Housing Staff recommend
amending some of the requirements for multifamily housing and adjusting the
maximum building height in the CD zone.
#D-224 Parking Requirements for Converted Uses Staff recommend adoption of
provisions that would require conversion of affordable housing to market rate would
require compliance with the parking standards for market rate multifamily housing.
Also, staff recommend requiring the same for commercial properties in the Downtown
if they convert to residential.
#D-225 Warehousing and Distribution Facilities Staff recommends adopting some
new definitions to better define these types of uses and establishing some additional
requirements for them.
Exist. Bldg. Area SF: N/A Proposed New Bldg. Area (footprint):
Proposed New Bldg. Area (gross):
N/A
N/A
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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
#D-220 Flood Regulations Staff recommends that code be amended in order to comply with 2021 updates to FEMA
National Flood Insurance Program (NFIP) Community Rating System (CRS) program requirements. The Community
Rating System is used by the NFIP to determine flood insurance premium discounts for participating communities.
Discounts are determined by the community’s level of compliance to CRS standards. Renton currently has a
community rating of 5, which provides a discount of up to 25% on flood insurance premiums for Renton residents.
FEMA requires communities to adopt and enforce at least a one-foot (1’) freeboard requirement, including machinery
and equipment. Freeboard is the minimum vertical distance between the 100-year flood elevation and the elevation
of the building feature or equipment being regulated. The 100-year flood elevations (also called base flood elevations)
are identified in the FEMA Flood Insurance Rate Maps. While Renton Municipal Code currently specifies a one -foot
(1’) freeboard requirement for finished floors, the code must be amended to remove options that allow devel opers
to avoid needing to provide one foot of freeboard for machinery, equipment, and manufactured homes.
The proposed amendments include:
• Removal of the option to waterproof mechanical equipment and utilities in commercial and residential
construction to require providing one foot of freeboard.
• Removal of the option of supporting and anchoring manufactured homes to resist flotation, collapse, and
lateral movement, to require constructing them with one-foot (1’) of freeboard for the floor of the
manufactured home.
• Removal of the option to flood proof non-residential structures, utility, and sanitary facilities to require
installing them with one-foot (1’) of freeboard.
• Addition of requirement to provide one-foot (1‘) of freeboard for ductwork to stated utilities required to be
elevated.
• Addition of requirement to provide one-foot (1’) of freeboard for mechanical equipment, ductwork, and
utilities.
• Addition of requirement to provide attached garages to structures required to be constructed with one-foot
(1’) of freeboard.
#D-222 Smoking Clubs and Hookah Lounges: Staff receives inquiries about establishing Hookah lounges in Renton
fairly regularly. This docket item reviewed State law and recommends adopting regulations specifying smoking clubs
and hookah lounges are not allowed in the City. In review of RCW 70.160 (Smoking in Public Places) and KCCBOH Title
19 (Tobacco Products, Electronic Smoking Devices and Unapproved Nicotine Delivery Products) all public places and
places of employment prohibit smoking. The definition of “open to the public” and related provisions adopted by in
CKCBOH 19.03.040(E) assert that most businesses are likely open to the public, and therefore tobacco consumption
would not be permitted. To that end, a business is open to the public if any of the following are true:
- The business promotes itself through advertising to the public;
- The business posts signs indicating it is open to the public;
- The business is affiliated with a commercial business that sells tobacco products; and/or
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- The business permits entry to people who do not meet selective, restrictive, and limited criteria for entry.
Under these regulations, smoking is only allowed in limited circumstances where there are no employees or volunteers
directed to perform work by a business owner and when businesses are not open to the public.
Despite state and county regulation making it difficult to legally operate a hookah lounge, there are several
establishments in operation. Staff reviewed comments on online applications about hookah lounge activity in the City
of Kent, City of Seattle, and a location in unincorporated King County, and includes ho urs of operation, jurisdiction,
estimated years in operation, and includes patron comments sourced from Yelp. The comments selected reference
membership practices, wayfinding/signage, and customer service provided by employees, as it relates to state and
county regulations. Considering this review and comments received from King County Public Health it appears that
this type of activity circumvents rules and regulations and jeopardizes the health of anyone who works there and staff
recommends not allowing them in Renton.
#D-222 Submittal Requirements Amendments Staff recommends including the following submittal requirements for
modification applications:
• Utilities Plan – A utilities plan ensures the modification request does not conflict with existing or proposed
site utilities.
• Architectural Elevations – Architectural elevations provide staff and decision makers the ability to visualize
how the project would look and how the proposed modification would impact the design of the project.
• Floor Plans – Floor plans provide staff and decision makers the ability to visualize how the modification
request influences the proposed building layout, or if the proposed building layout contributes to the
circumstances which necessitate the modification request.
• Geotechnical Report – When applicable, a geotechnical report ensures the modification request would not
increase the threat of the geologic hazards to the abutting properties or adversely impact other critical areas.
In addition, the geotechnical report assists in the review and decision of modification requests related to
geologic hazards, as identified in RMC 4-3-050, Critical Areas Regulations.
• Wetland Assessment – When applicable, a wetland assessment ensures the modification request does not
conflict with the regulations for wetlands or wetland buffers on or near the subject property.
• Stream/Lake Study – When applicable, a Stream/Lake Study ensures the modification request does not
conflict with Critical Areas Regulations or with the Shoreline Master Program Regulations when streams or
Shorelines of the State are mapped on the project site.
• Flood Hazard Data – When applicable, flood hazard data ensures the modification request does not conflict
with standards and requirement for flood hazard areas, per RMC 4-3-050.
RMC 4-9-250 provides procedures and decision criteria for review of modification requests. Whenever there are
practical difficulties involved in carrying out the provisions of code, the Administrator may grant modifications for
individual cases provided that the applicant demonstrates that specific circumstances make the strict letter of the
code impractical, that the intent and purpose of the Comprehensive Plan is met, and that the modification is in
conformity with the intent and purpose of the code. Staff proposes to include the submittal requirements identified
above in order to ensure that staff receives all necessary information to verify compliance with the modification
decision criteria, and ensure compliance with code.
Staff also recommends including conceptual site plans for short plat applications. A conceptual landscape plan
provides staff and decision makers the ability to visualize how the short plat proposal and lot configuration will impact
compliance with landscaping requirements.
RMC 4-7-070 provides procedures and principles of acceptability for review of proposed short plats and requires that
short plat proposals create legal building sites which comply with all provisions of the City Zoning Code. Staff proposes
to include a conceptual landscape plan with the submittal requirements for short plats in order to verify that the
proposed short plat lot configuration, tract locations, or other site characteristics of proposed short plats do not
impact compliance with applicable landscaping requirements.
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#D-223 Citywide Minimum Standards for Multifamily Housing: In recent years, staff have reviewed proposed plans
for residential development in the CD Zone with dwelling units comparable to efficiency dwelling units. An efficiency
dwelling unit is typically regarded as a dwelling unit containing only a single habitable room other than a kitchen or
containing a total of less than five hundred (500) square feet of floor area.
The City’s recently adopted Housing Action Plan notes that larger hous eholds have difficulty finding appropriately
sized units with three or more bedrooms: “Additionally, only about 7% of units affordable at 50% AMI or below and
9% of units affordable at 50–80% have three or more bedrooms, suggesting that there may be challenges with the
availability of affordable housing for larger households, especially families with children.”
In an effort to realize the creation of attached dwelling units of varying sizes and bedroom counts, some cities have
adopted minimum standards. For example, Seattle requires apartment developments with four or more units to
provide at least one unit with two or more bedrooms and a minimum net unit area of 850 square feet for every four
units in the structure. They do allow one unit with three or more bedrooms and a minimum net unit area of 1,050
square feet to be provided in place of any two units required to include two bedrooms and a minimum net unit area
of 850 square feet.
Redmond requires affordable housing units to be as small as 500 square feet for a studio unit, 600 square feet for a
one-bedroom unit, 800 square feet for a two bedroom unit, or 1,000 square feet for a three bedroom unit. However,
the Administrator has the discretion not to approve proposals for smaller units based on the criteria that rooms within
the units provide adequate space for their intended use. The Renton Housing Authority has self-imposed minimum
dwelling unit sizes are studios 400 SF, 1 bd 600 SF, 2 bd 800 SF, 3 bd 1000 SF, 4 bd 1200 SF. Staff recommend adopting
the same standard as the Renton Housing Authority as the standard for all multifamily housing.
The maximum allowable building height in the CD Zone is 95 feet with the opportunity for taller buildings if approved
by a conditional use permit. However, all of the CD is impacted by Federal Aviation Administration rules, implemented
by RMC 4-3-020, to protect navigable airspace surrounding airports resulting in many areas of the CD Zone where 95
feet is not achievable building height. Development standards are reviewed in the process financial institutions
valuating real property, and yet often proximity to the Renton Municipal Airport is not considered, leading to over -
valued properties. Staff recommend establishing a maximum height of 150 feet in the CD Zone or the maximum height
allowed based on RMC 4-3-020, whichever is less. Staff estimate the tallest building that may be permitted in the CD
Zone is 150 feet.
#D-224 Parking Requirements for Converted Uses The parking requirements for attached affordable housing are less
than for market rate attached housing. Attached affordable housing is required to provide at minimum 1 parking stall
per 4 dwelling units and a maximum of 1.75 per dwelling unit. Parking requirements for market rate attached dwellings
are higher and detailed below. They range from at least 1 parking stall per dwelling unit to 1.6 per 3 bedroom units in
the R-10, R-14, and Residential Multi Family (RMF) zones.
The reason for the reduced requirement for affordable housing is twofold. First, parking is very expensive to construct
and/or accommodate. For structured parking cost vary widely and depend on many factors like land costs, below
grade or at grade, and façade design, but costs range from $12,000 to $40,000 per stall. It is unlikely that stru ctured
parking in Renton would be at the higher end of the range, but at the lower end a 100 unit project would add $1.2
million to construction costs to a market rate project in most zones. Surface parking is far less expensive to construct.
Costs range from $1,500 to $3,000 per stall, with costs depending on amount of clearing needed, type of material
used (gravel, asphalt, or concrete), and land costs. However, surface parking is land consumptive and in many
instances is using land that would be better utilized as housing or commercial. The second reason there is a reduced
parking requirement for affordable housing is that studies have shown that lower income households own fewer cars
than higher income households. A recent Consumer Expenditure Survey found that lower income households owned
.9 cars while higher income households owned 2.7 cars.
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There are many affordable housing projects in Renton that have been built using the 1 parking stall per 4 units
standard. If those projects covert to market rate projects, the amount of parking provided would be inadequate. For
example, a 100-unit affordable apartment could be constructed with 25 parking stalls. A market rate project in most
zones would be required to provide 100 stalls. Staff recommend that a new provision be adopted that would any
conversion of an affordable project to a market rate project be required to comply with the parking requirements for
market rate projects. While this may be challenging, the City has provisions for shared parking, as well as, allows off-
site parking.
For many commercial uses in the Center Downtown (CD) zone parking is not required to be provided. Some high trip
generating uses like bowling alleys, movie theaters, and indoor sports require parking to be provided at the same rate
as in any other zone. For all other commercial uses located in the CD zone they can provide at most 1 parking stall per
1,000 square feet of net floor area. Net floor area removes areas like hallways, mechanical areas, and elevator shafts.
However, there is no minimum parking requirement. While many people feel that parking is difficult to find in
Downtown, the parking garage is underutilized and often on and off-street parking is available a few blocks away
outside the core area. The intent is that Downtown function like an urban area where people park and then walk to
multiple destinations. Having no requirement for most commercial uses also serves as an incentive for prospective
tenants of vacant storefronts.
If a commercial use in the CD zone with no parking provided converts to a use like residential, parking should be
required to be provided. For market rate attached units the minimum and maximum parking required is 1 stall per
unit. So, if a commercial use converts to 15 dwelling units, they should be required to provide 15 parking stalls.
However, current code does not have a provision that would enable the city to make such a requirement. Staff
recommend that any conversion of a use with no parking requirement to a use with a parking requirement in the CD
zone be required to comply with the parking required.
D-225 Warehousing and Distribution Facilities: Staff recommend amending Renton Municipal Code to establish the
following zoning, development standards, requirements, and definitions for indoor storage, and warehousing a nd
distribution facilities:
A. Zoning:
Indoor Storage: Allow in the IL, IM, and IH Zones through an administrative conditional use permit.
Warehousing and Distribution Facilities: Allow in the IM and IH Zones
south of SW 27th St through an administrative conditional use permit.
B. Standards or Requirements:
Indoor Storage: Limit gross floor area to 200,000 square feet.
Warehousing and Distribution Facilities: Limit gross floor area to
400,000 square feet.
Both Land Uses:
• Traffic monitoring required for 2-years after beginning operations
to ensure accurate vehicle trips, especially freight.
• Make compliance with local and state idling laws a condition of
approval.
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C. Transportation Impact Fees:
The Institute of Transportation Engineers’ (ITE) Trip Generation Manual provides trip generation rates for
various land use and building types. ITE Procedures estimate the number of trips entering and exiting a site at
a given time. ITE Rates are functions of type of development based on independent variables such as square
footage of the gross leasable area, number of gas pumps, number of dwelling units, or other standard
measurable things.
Currently, the city uses the 10th Edition of the ITE but an 11th Edition has been published, which provides
updated modeling. Staff recommend adopting the 11th Edition ITE Trip Generation Manual, which will be
applied to all future land uses when determining transportation impact fees.
Furthermore, staff recommend adopting a “truck adjustment factor” to calculated trips. The ITE Manual
estimates trip generation for passenger vehicles, so the adjustment factor would convert passenger vehicles
trips by establishing truck equivalent trips. Staff recommend adopting a factor that equates four passenger
car vehicle trips into a single truck trip.
D. Definitions:
Indoor Storage: Recently, staff have responded to inquiries about zoning for data centers. “Data center” is
not defined land use in Renton Municipal Code (RMC). However, the 11th Edition ITE Manual defines data
center as follows:
A data center is a free-standing warehouse type of facility that is primarily used for off-site storage of computer
systems and associated components including applications and secure data. Some data centers may include
maintenance areas and a small office. Data centers may be occupied by single or multiple tenants. Data centers
typically have a small number of employees and visitors.
Because data centers, as defined by the ITE Manual, share many of the same characteristics as “indoor
storage,” staff recommend revising RMC’s definition of indoor storage to include data centers, which would
have the effect of applying indoor storage zoning and development standards to data centers.
Warehousing and Distribution Facilities: The 11th Edition ITE Manual provides definitions for a “high-cube
fulfillment center warehouse” (see below). Staff recommend revising the definition of “warehousing and
distribution facilities” to better reflect the ITE Manual’s definition.
A building that typically has at least 200,000 gross square feet of floor area, has a ceiling height of 24 feet or
more, and is used primarily for the storage and/or consolidation of manufactured goods (and to a lesser extent,
raw materials) prior to their distribution to retail locations or other warehouses. A typical HCW has a high level
of on-site automation and logistics management. The automation and logistics enable highly efficient
processing of goods through the HCW. A high-cube warehouse can be free-standing or located in an industrial
park.
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.
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B. Mitigation Measures
1. None
C. Exhibits
None
D. Environmental Impacts
There are no environmental impacts that are anticipated to occur in conjunction with the proposal.
E. Comments of Reviewing Departments
The proposal has been circulated to City Department and Division Reviewers. Where applicable, their
comments have been incorporated into the text of this report and/or “Advisory Notes to Applicant.”
✓ Copies of all Review Comments are contained in the Official File and may be attached to this report.
The Environmental Determination decision will become final if the decision is not appealed within the 14-day
appeal period (RCW 43.21.C.075(3); WAC 197-11-680).
Environmental Determination Appeal Process Appeals of the environmental determination must be filed in
writing on or before 5:00 p.m. on September 26, 2022. Due to the ongoing state of emergency enacted by Governor’s
Proclamation 20-28.14 (and as amended), the City Clerk’s Office is working remotely. For that reason, appeals
must be submitted electronically to the City Clerk at cityclerk@rentonwa.gov or delivered to City Hall 1st floor
Lobby Hub Monday through Friday. The appeal fee, normally due at the time an appeal is submitted, will be
collected at a future date if your appeal is submitted electronically. Appeals to the Hearing Examiner are governed by
RMC 4-8-110 and additional information regarding the appeal process may be obtained from the City Clerk’s Office,
cityclerk@rentonwa.gov.
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