HomeMy WebLinkAboutERC Reconsideration Recommendation Memo_Sounders_FINAL
DEPARTMENT OF COMMUNITY
AND ECONOMIC DEVELOPMENT
M E M O R A N D U M
DATE: December 5, 2022
TO: Environmental Review Committee (ERC)
FROM: Jill Ding, Senior Planner
SUBJECT: Sounders FC Center at Longacres (LUA22-000357) SEPA Request
for Reconsideration
The Environmental Review Committee (ERC) reviewed the above -mentioned site plan and
conditional use permit application and issued a SEPA Determination of Non-Significance –
Mitigated (DNS-M) on November 7, 2022 with six (6) mitigation measures:
1. Construction on the project site shall comply with the recommendations of the submitted
Geotechnical Report, prepared by GeoEngineers, dated June 23, 2022.
2. The applicant’s geotechnical engineer shall review the project’s construction plans for the
new fields and the building permit plans for the proposed maintenance building and
elevated patio addition to verify compliance with the submitted geotechnical report. The
geotechnical engineer shall submit a sealed letter stating that he/she has reviewed the
construction and building permit plans and in their opinion the plans and specifications
meet the intent of the report.
3. The fill material used on the synthetic fields shall be comprised of a material that would
be non-toxic to fish and other wildlife.
4. The applicant shall demonstrate that the proposed underground storage chambers, to be
utilized for compensatory storage, would not have an adverse impact on salmonids and
would ensure that salmonids would not get trapped within the proposed underground
storage chambers.
5. The applicant shall follow the Department of Ecology guidance for Tacoma Smelter Pl ume
soil contamination testing and remediation as instructed in the agency’s letter (Exhibit
15).
6. The applicant shall submit an Inadvertent Discoveries Plan prepared by a qualified
professional with the civil construction permit for review and approval by the Current
Planning Project Manager prior to permit issuance.
The DNS-M and related documents were sent to parties of record and posted online with an
appeal period that ended on November 21, 2022. A request for reconsideration of the SEPA
determination was received from the applicant (Unico Properties and Seattle Soccer, LLC). The
request for reconsideration requests alternate wording for mitigation measure #3. Below is a
summary of the concerns cited:
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December 5, 2022
A. The applicant believes that the intent of the City’s mitigation measure #3 is that the
artificial turf fields will not result in a probable significant adverse environmental impact
to fish and wildlife. Sounders contend that they have designed their artificial turf fields to
achieve that result. However, the wording of Condition 3 is problematic, because it asks
the applicant to prove a negative, i.e. that the turf material itself is “non-toxic to fish and
other wildlife.” The applicant cannot meet this standard, especially because of the limited
peer-reviewed scientific studies analyzing field-related materials in constructed,
operating synthetic turf athletic fields. This lack of information could cause confusion and
uncertainty during subsequent permitting.
Analysis of the impact of any particular material on the environment must also include
the manner, intensity, and duration of exposure created. Notwithstanding the lack of
definitive information regarding the materials themselves, there are many mitigation
factors that can limit risk to the natural environment. Means of control to limit transfer
of turf and turf components to the environment include field design, the stormwater
management and water quality system for the fields, and operational practices that
control and minimize material transport.
Field Turf is the industry standard material for competitive and practice fields in Major
League Soccer (MLS). Field Turf comes in several varieties, most of which include SBR
Crumb Rubber as infill material. The playing surface in Lumen Field, the Sounders
competition field, is made of Field Turf composed with SBR Crumb Rubber. Professional
soccer best practices which manage professional athlete load and physiological impacts
across a grueling 10-month calendar, require consistent field conditions for both match-
competition pitches and training pitches.
Because SBR Crumb Rubber is the industry standard for MLS, it would be a substantial
impact to Sounders FC to have the City prohibit use of that material. The impact is felt in
several ways. First, there is inadequate information available to know how the substitute
materials perform for MLS play, and how the materials hold up as compared to the known
standard: SBR Crumb Rubber. The ability to source less standard substitute materials and
potential timing impacts also create uncertainty for the accelerated timeline to have the
fields ready for World Cup use in 2026.
To mitigate for potential impacts from crumb rubber on salmonids from 6PPD-q and other
known toxins, the applicant is proposing to use a Filterra Bioscape, proprietary open
filtration basin design for water quality treatment of the water flowing from this field
complex. This system is sized to meet the Enhanced Basic level as required for this project
by the City, and is sized to provide treatment for the 6-month event runoff as specified in
the RSWDM. Flows exceeding the design treatment rate, will be directed around the
Bioscape system via a flow splitter located above the facility. These higher flows will be
directed into the existing water quality pond on site, Pond B. Per the Washington State
Department of Ecology report titled 6PPD in Road Runoff (Publication 22-03-020)
“Stormwater treatment infrastructures that use infiltration, sorption, filtration, and/or
effectively capture tire wear particles are expected to reduce the toxicity from 6PPD-q.”,
and “Filters that focus on reducing suspended particles (e.g., total suspended solids) will
be effective at capturing tire particles and any other particulate matter with sorbe d
contaminants including 6PPD-q.”
The applicant notes that the code requirement for treating stormwater runoff
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December 5, 2022
for all systems within this area is the 6-month storm event, to further mitigate the impacts
of the use of SBR crumb rubber within the synthetic fields, the applicant is proposing to
design their water quality treatment facility to treat the 2-year rainfall event runoff. This
treatment rate means this facility would treat more of the rainfall events that this facility
would experience. The applicant contends that this treatment level is a reasonable
approach to address the concerns raised concerning the 6PPD-q and other pollutants. The
concerns regarding the 6PPD-q pollutant have been based, to date, on studies of roadway
runoff, which we believe to have important differences from the use of rubber in
synthetic turf fields.
Unlike in a roadway environment where tire dust and fine particles are blown or washed
off of the road surface quickly into storm systems or directly into receiving waters
containing fish, the granular crumb rubber in the synthetic turf fields at the proposed
Sounders FC facility remains at the surface, prevented from entering the stormwater
system. The crumb rubber used in fields is sieved and processed to reduce finer particles
to the maximum extent possible, including the finest dust. Therefore the mechanisms
believed to cause degradation of the rubber into 6PPD-q and the mobilization of those
particles themselves are far less in the field context than in roadway runoff which is the
current basis of research on the issue. The largest constituent of pollutant transport is
broadly recognized to be the finer particles, down to dust-sized. Smaller particles both
degrade quicker (producing pollutants such as 6PPD-q) and can be transported
downstream more easily, for direct contact into waterways and aquatic organisms.
Additionally, the potential for fugitive infill materials to directly leave the field s urface is
further mitigated by 1) a continuous perimeter containment curb and windscreen/fence,
and 2) controlled access and use, which limits potential unintended migration or
transport.
In conclusion, the applicant is requesting that the wording of mitig ation measure #3 be
amended to read as follows: “The artificial turf field program, including field design,
construction and operation, together with stormwater management and water quality
treatment for drainage from the artificial turf fields, shall assu re that the field materials
do not result in a probable significant adverse environmental impact on fish and wildlife.
Sounders would undertake quarterly water quality tests of field drainage, during the 2 -
year maintenance period for the stormwater system. The Sounders field and stormwater
consultants will work with City of Renton to determine a reasonable and appropriate
monitoring protocol to test for SBR Crumb Rubber constituents of concern in field
drainage.”
Staff Comment: Staff has reviewed the submitted request for reconsideration. The
original intent behind mitigation measure #3 was to ensure that the proposed synthetic
athletic fields would not result in an adverse environmental impact to fish and wildlife.
Staff has concerns that the word “significant” in the proposed language would be difficult
to quantify, therefore staff recommends removing the term “significant” from the
applicant’s proposed language.
The applicant’s proposal has been reviewed by the City’s Peer Review Consultant Otak,
who concurs that the proposal to increase the size of the water quality treatment facility
to treat the 2-year storm event, rather than the 6-month storm even would reduce the
direct discharge into Pond B and would be more than is required by the current City
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December 5, 2022
Renton Surface Water Design Manual (RSWDM). Otak also concurs that the applicant’s
proposal to monitor the stormwater outflow would also minimize the risk of the SBR
crumb rubber on aquatic wildlife. However, in lieu of the two (2) year monitoring
timeframe proposed by the applicant, staff recommends that the field runoff shall be
monitored for the life of the field or five (5) years, whichever comes first.
Recommendation: Based on the additional information provided in the reconsideration request
by the Applicant, staff recommends that the ERC retain SEPA mitigation measures 1 and 2 and
amend mitigation measure 3 as stated below, add a new mitigation measure 4 and renumber and
retain mitigation measures 4, 5, and 6 as 5, 6, and 7:
3. The artificial turf field program, including field design, construction and operation,
together with stormwater management and water quality treatment for drainage from
the artificial turf fields, shall assure that the field materials do not result in a probable
adverse environmental impact on fish and wildlife. The proposed water quality treatment
facility shall be a Filterra Bioscape facility sized to treat the 2-year storm event or
equivalent as approved by the City and the applicant shall undertake quarterly water
quality tests of field drainage, during the life of the field or for a five (5) year period,
whichever comes first. The applicant will submit a monitoring protocol to test for SBR
Crumb Rubber constituents of concern in field drainage for City approval.
4. When the fill within the synthetic turf athletic fields is replaced, the applicant shall be
required to go through a new Environmental Review.
Environmental Determination Appeal Process: Appeals of the environmental determination
must be filed in writing on or before 5:00 p.m. on December 19, 2022. 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. The appeal
submitted in person may be paid on the first floor in our Finance Department. 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.
Enclosures: Request for Reconsideration
SIGNATURES:
Martin Pastucha, Administrator
Public Works, Chair
Date Anjela Barton, Fire Marshal
Renton Regional Fire Authority
Date
for Kelly Beymer, Administrator
Parks and Recreation
Department
Date Chip Vincent, Administrator Date
Community and Economic
Development
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12/5/2022 | 2:22 PM PST
12/5/2022 | 2:24 PM PST
12/5/2022 | 3:40 PM PST
From: Jeff Gray <Jeff.Gray@otak.com>
Sent: Monday, December 5, 2022 7:58 AM
To: Jill Ding
Subject: RE: Friday 9am Meeting - City of Renton, Otak, & Sounders/Unico
Follow Up Flag: Follow up
Flag Status: Flagged
Looks good to me. They’re sizing the facility to accommodate the 2-year storm rather than the 6-month
storm event, which reduces direct discharge to Pond B, and is more than required per the stormwater
regs. I think the condition to require monitoring after Ecology develops standard monitoring protocols
and before the fields are replaced again is further insurance to minimizing risk to aquatic wildlife.
Jeff
Jeff Gray | Managing Senior Scientist
Otak, Inc.
Direct: 971.337.3047 | Cell: 609.532.4620 | Main: 425.822.4446
From: Jill Ding <JDing@Rentonwa.gov>
Sent: Friday, December 2, 2022 3:29 PM
To: Jeff Gray <Jeff.Gray@otak.com>
Subject: FW: Friday 9am Meeting - City of Renton, Otak, & Sounders/Unico
Please see attached the revised memo from the Sounders team. Let me know if you have any questions
or concerns regarding this approach.
Thanks,
JILL DING, Senior Planner
City of Renton | CED | Planning Division
1055 S Grady Way | 6th Floor | Renton, WA 98057
Virtual Permit Center | Online Applications and Inspections
(425) 430-6598 | jding@rentonwa.gov
From: Jeremy Eckert <jeremy@tharsis.land>
Sent: Friday, December 2, 2022 3:23 PM
To: Jill Ding <JDing@Rentonwa.gov>; Vanessa Dolbee <VDolbee@Rentonwa.gov>
Subject: Re: Friday 9am Meeting - City of Renton, Otak, & Sounders/Unico
Jill and Vanessa:
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open
attachments unless you know the content is safe.
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open
attachments unless you know the content is safe.
DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6
We've attached a letter from CPL that answers your questions below. We've traded a handful of emails /
letters on this topic. To help the ERC, the attached letter is an attempt to put all of the relevant
information into one document. We're standing by if you have any follow up questions after you read
the letter.
Thank you,
Jeremy
On Fri, Dec 2, 2022 at 10:34 AM Jill Ding <JDing@rentonwa.gov> wrote:
Jeremy,
Thank you for sending over this memo, this provides a lot of helpful background information on the
proposed water quality treatment facility with respect to 6PPD. During our meeting, additional
information was provided that we think would be helpful to also include within the memo: 1. It sounds
like the proposed water quality treatment facility is mentioned as a recommended facility within the
6PPD study prepared by Ecology, in the meeting Tim specified that while the proposed Filterra system
has not yet been tested as a treatment for 6PPD, that he believes that it would perform as well or
better than the 60-40 mix, which has been tested. If something to this effect could be added to the
memo, that would be helpful to communicate to our Environmental Review Committee (ERC); 2. Eric
provided a description of the cleaning process that the crumb rubber goes through before being placed
in the field. A summary of this process would also be helpful for us to communicate to the ERC; and 3.
A description of the vertical filtration that rainwater goes through when it hits the fields would also be
helpful.
If this information could be provided by the end of the day, this would give me sufficient time to
prepare a presentation to the ERC on Monday.
Thanks,
JILL DING, Senior Planner
City of Renton | CED | Planning Division
1055 S Grady Way | 6th Floor | Renton, WA 98057
Virtual Permit Center | Online Applications and Inspections
DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6
(425) 430-6598 | jding@rentonwa.gov
From: Jeremy Eckert <jeremy@tharsis.land>
Sent: Thursday, December 1, 2022 5:03 PM
To: Jill Ding <JDing@Rentonwa.gov>
Cc: Tom Chiado <tom@chiadollc.com>; Julia Reeve <juliar@unicoprop.com>; William Andres
<williama@cplinc.com>; Tim Brockway <timb@cplinc.com>; Eric Gold <EricG@dahogan.com>; Vanessa
Dolbee <VDolbee@Rentonwa.gov>
Subject: Re: Friday 9am Meeting - City of Renton, Otak, & Sounders/Unico
Hi Jill:
I've attached CPL's response to your questions from Monday. You also sent follow-up questions.
Responses to those questions are below:
1. At what frequency is stormwater expected to overflow/bypass the Filterra treatments and
discharge directly into Pond B? What is the design capacity (storm event) of treatments?
A: Flows above the 6-month rainfall event, as defined by King County and Ecology as the
water quality storm event, will bypass the facility. The same 6-month flow rate will continue
to be treated during larger storms, but as a percentage of the larger storm volume.
2. How much area (%) of the 3 synthetic fields will be treated by the Filterra system during those
storm conditions?
A: 100% of the synthetic field surface will be treated by the Filterra system for all rain events.
To help facilitate a productive discussion, we propose working off of the following agenda at
tomorrow's 9am meeting. The team is open to amending the agenda if that would be beneficial.
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open
attachments unless you know the content is safe.
DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6
Introductions
Otak provides summary of its comments
Project Overview
Project Goals
Sounders / Unico review of science in response to Otak/City questions and comments
Operations / Proposed Mitigation / Treatment Design:
o Overview of materials out for bid and cost associated with same
o Field Maintenance Schedule and cost
o Stormwater design / water quality treatment
o Existing infrastructure at Longacres
Discussion
Thanks,
Jeremy
On Thu, Dec 1, 2022 at 8:58 AM Jeremy Eckert <jeremy@tharsis.land> wrote:
Hi Jill:
Here's the list of attendees for Friday's 9am meeting, with everyone cc'd to provide you with emails
for your meeting invite.
Tom Chiado, Sounders Project Manager
Julia Reeve, Unico Project Manager
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William Andres, CPL
Tim Brockway, CPL
Eric Gold, DA Hogan
The attendees are consultants and the respective Unico/Sounders project managers. No lawyers. This
team can speak to field materials, stormwater, and existing infrastructure at Longacres. CPL is
preparing a short response to your email. We'll send that to you as soon as it is ready.
Thanks again for the invitation to discuss this outstanding item. We're looking forward to the
collaborative conversation.
Jeremy
On Tue, Nov 29, 2022 at 7:48 PM Jeremy Eckert <jeremy@tharsis.land> wrote:
Thank you, Jill. Let me coordinate with the team and get back to you. 9am Friday should work. Also,
CPL is preparing a response to your email from earlier today. We'll send that along as soon as it is
available. More soon.
Jeremy
On Tue, Nov 29, 2022 at 3:14 PM Jill Ding <JDing@rentonwa.gov> wrote:
Jeremy,
DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6
Vanessa, myself, and Jeff Gray from Otak are available to meet Friday morning at 9am, does this
work for your team? Do you want me to send out a Teams Meeting invite? If so, please let me know
who I should invite.
Thanks,
JILL DING, Senior Planner
City of Renton | CED | Planning Division
1055 S Grady Way | 6th Floor | Renton, WA 98057
Virtual Permit Center | Online Applications and Inspections
(425) 430-6598 | jding@rentonwa.gov
--
Tharsis Law P.S.
tharsis.land
--
Tharsis Law P.S.
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tharsis.land
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Second Request for Reconsideration of SEPA MDNS Condition #3
Second Request for Reconsideration of MDNS SEPA Condition
Project File No.: PR22-000301
Project Name: Sounders FC Center at Longacres
Land Use File No.: LUA22-000357; SA-H; CU-H; ECF; MOD
Date: November 23, 2022
I. Second Request for Reconsideration of SEPA MDNA Condition #3:
On behalf of Co-applicant Seattle Sounders FC, we write to ask the ERC to further reconsider
the language of SEPA Condition 3. We had first asked the City not to set a standard that required
the Sounders to prove a negative, regarding synthetic turf materials being non-toxic to fish and
wildlife. We proposed alternative language that we believed met the purpose to assure the
synthetic fields would not pose probable adverse environmental impacts to fish and wildlife.1 We
appreciate the ERC willingness to consider the applicants’ concern with Condition 3. We
understand that the ERC had questions on Friday, and is now considering imposing a prohibition
on using crumb rubber manufactured from recycled tires (hereafter “SBR Crumb Rubber”) as
infill material for synthetic turf field assemblies. For reasons explained below, this would be an
intrusive condition on the proposal, which we believe to be unwarranted and not legally
supportable under SEPA, and it would generate significant unanticipated costs to the proposal.
We appreciate the opportunity to further explain why the proposed prohibition is unwarranted,
and the impacts it would have on Sounders FC Center at Longacres.
II. Impacts of Departing from Industry Standard
Field Turf is the industry standard material for competitive and practice fields in Major League
Soccer (MLS). Field Turf comes in several varieties, most of which include SBR Crumb Rubber
as infill material. The playing surface in Lumen Field, the Sounders competition field, is made of
Field Turf composed with SBR Crumb Rubber. Professional soccer best practices which manage
professional athlete load and physiological impacts across a grueling 10-month calendar, require
consistent field conditions for both match-competition pitches and training pitches.
Because SBR Crumb Rubber is the industry standard for MLS, it would be a substantial impact to
Sounders FC to have the City prohibit use of that material. The impact is felt in several ways. First,
there is inadequate information available to know how the substitute materials perform for MLS
play, and how the materials hold up as compared to the known standard: SBR Crumb Rubber. The
ability to source less standard substitute materials and potential timing impacts also create
uncertainty for the accelerated timeline to have the fields ready for World Cup use in 2026.
Finally, replacing SBR Crumb Rubber with the known available substitute for two to three fields
at Sounders FC Center is estimated to cost somewhere from $750,000 to more than $1 million.
This would be a significant economic factor in addition to existing known costs of a new
headquarters and training facility in the City of Renton.
1 The applicants’ language actually tracked SEPA phrasing to prevent “probable significant adverse environmental
impacts.” We understand the City prefers to strike the word “significant” from that phrase, and the applicant does
not object to that change.
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III. Stormwater Regulations Require Treatment for Constituents of Concern
Renton has adopted the King County Surface Water Design Manual (2021) (KCSWDM or “Design
Manual” as its stormwater regulations. These regulations are applicable to the Sounders FC Center
at Longacres.2 The Design Manual classifies athletic fields as “pollution generating pervious
surfaces,” and requires higher levels of water quality treatment for these uses in commercial
zones.3 The applicant’s field designer and stormwater engineer have collaborated on a field design
and drainage system that meets the Enhanced Basic Water Quality Treatment requirements of
KCSWDM. The Enhanced Basic treatment system treats for metals in stormwater, which includes
treatment to remove copper and zinc, the two main constituents of potential concern with regard
to stormwater drainage from athletic fields using SBR Crumb Rubber if they were designed
without this protection. The treatment type selected by the design team has been approved by the
State Department of Ecology. If the City desires additional information about how the selected
treatment works to remove these constituents of potential concern, we can arrange to have our
consultants address those questions. Accordingly, the proposal with its elevated water quality
treatment is already mitigating for the use of SBR Crumb Rubber infill. Further mitigation is not
required, and a prohibition against using the material is not warranted.
In addition, while Sounders acknowledge the ongoing conversation nationwide regarding the use
of SBR Crumb Rubber in synthetic turf for playing fields, we can provide the City with a reputable,
local study that looked carefully at the issue and concluded that synthetic field drainage does not
pose an environmental impact to surface waters.4 The attached Woodland Park Study was two
pronged, including both a survey of existing literature on the topic, including studies performed in
Washington State, and a rigorous sampling program from synthetic turf fields at Seattle’s
Woodland Park playfields. Those fields included a surface made from SBR Crumb Rubber infill
(Playfield #7). The Report concluded that “Water quality results for the three base flow samples
and eight storm samples collected from Playfield #7 drain show that pollutant concentrations were
very low in synthetic turf field drainage and do not pose an environmental impact to Green Lake.
None of the pollutant concentrations in synthetic turf field drainage exceeded Washington State
surface water quality standards.”5
Although we find the Woodland Park Study well-conducted and persuasive, we are aware that
other literature speculates differently. We are also aware that infill materials for synthetic athletic
fields are under continual review and study by regulatory entities, primarily and importantly due
to their prevalence in youth and amateur athletics. But the controlling factors here based on the
proposed design outweigh the speculation: (1) the required Enhanced Basic water quality treatment
addresses the zinc and copper constituents most associated with toxicity to fish; (2) the stormwater
system effectively captures the stormwater drainage for treatment; (3) the fields are fenced and
maintained as a professional MLS facility; and (4) access controls avoid inadvertent transfer of the
infill material. We ask that the City not impose a condition prohibiting the industry standard
2 Renton has adopted a few amendments to the Design Manual, not relevant here.
3 See applicable excerpts from the KCSWDM at Exhibit A.
4 See attached Exhibit B, Water Quality Report, Woodland Park Synthetic Turf Field Stormwater Drainage Study, p.
51 (June 2010), prepared for Seattle Parks and Recreation by Herrera Consultants.
5 Id.
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material when there is not definitive science or standards that mandate such a condition.
Nonetheless, we also want the City to know that Seattle Sounders FC cares deeply about its
environmental footprint, and desires to be an environmentally responsible new member of the
Renton community. For that reason, we would propose the following mitigation in lieu of the SBR
Crumb Rubber prohibition.
IV. Prohibition Exceeds Adopted SEPA Standards
Under SEPA, mitigation measures must be based on policies, plans, rules, or regulations formally
designated by the agency as a basis for the exercise of substantive authority and in effect when the
DNS is issued.6 We can find no adopted policy or regulation of the City of Renton that would
authorize the prohibition of the use of SBR Crumb Rubber on soccer fields in this case, where
water quality measures will be in place. Moreover, before requiring mitigation measures, the
agency must consider whether local, state or federal requirements and enforcement would mitigate
an identified impact.7 As we have pointed out, the project is required by the city’s stormwater
regulations to implement enhanced water quality measures that are specifically designed and
adopted to prevent pollution from synthetic turf athletic fields. For these reasons, and because there
is no specific, adverse environmental impact associated with the use of SBR Crumb Rubber
identified in any environmental documents for the proposal, we ask that the City not condition the
project to prohibit the use of SBR Crumb Rubber infill.
V. Substitute Mitigation Proposal
The Sounders FC Center at Longacres will implement Enhanced Basic water quality treatment for
all playing field drainage. Although the KCSWDM does not require monitoring, Sounders would
undertake quarterly water quality tests of field drainage, during the 2-year maintenance period for
the stormwater system. The Sounders field and stormwater consultants will work with City of
Renton to determine a reasonable and appropriate monitoring protocol to test for SBR Crumb
Rubber constituents of concern in field drainage.
This request for reconsideration is supported by the attached exhibits. We would be happy to
answer any questions. Thank you for attention to this second request for reconsideration of SEPA
Condition #3.
Respectfully submitted on behalf of the co-applicants
HILLIS CLARK MARTIN & PETERSON P.S.
Ann Gygi
Ann Gygi
999 Third Avenue | Suite 4600 | Seattle, WA 98104
(206) 470-7638
ann.gygi@hcmp.com
6 WAC 197-11-660(1)(a).
7 WAC 197-11-660(1)(e).
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Exhibit A
Excerpts from King County Surface Water Design Manual
KCSWDM, 2021, Ch. 1: Key Terms and Definitions.
KCSWDM, 2021, Ch. 1, Sec. 1.2.8.2.A, p. 1-71, -72
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KCSWDM, 2021, Sec. 6.1.2, p. 6-7
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Exhibit B
Woodland Park Water Quality Study
(Please Click on Attached pdf)
09-04418-000
Woodland Park Water Quality Report 2010 06 07 (1).pdf
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Request for Reconsideration of SEPA MDNS Condition #3
Request for Reconsideration of MDNS SEPA Condition
Project File No.: PR22-000301
Project Name: Sounders FC Center at Longacres
Land Use File No.: LUA22-000357; SA-H; CU-H; ECF; MOD
Date: November 18, 2022
I. Request for Reconsideration of SEPA MDNA Condition #3:
Co-applicants Unico Properties 1 and Seattle Soccer LLC, respectfully ask the Responsible SEPA
Official for the City of Renton to reconsider the wording of Condition #3 of the Environmental
Review Committee Report issued November 7, 2022 for the above-referenced application, for the
reasons stated below.
II. Current Condition #3:
“The fill material used on the synthetic fields shall be comprised of a material that would be non -
toxic to fish and other wildlife.”
III. Proposed Substitute Condition #3:
The applicant proposes the following alternative condition which, if approved, would satisfy the
purpose of condition #3:
“The artificial turf field program, including field design, construction and operation, together with
stormwater management and water quality treatment for drainage from the artificial turf fields,
shall assure that the field materials do not result in a probable significant adverse environmental
impact on fish and wildlife.”
IV. Explanation of Request for Reconsideration
Sounders believe that the intent of the City’s Condition #3 is that the artificial turf fields will not
result in a probable significant adverse environmental impact to fish and wildlife. Sounders have
designed their artificial turf fields to achieve that result. However, the wording of Condition 3 is
problematic, because it asks the applicant to prove a negative, i.e. that the turf material itself is
“non-toxic to fish and other wildlife.” The applicant cannot meet this standard, especially because
of the limited peer-reviewed scientific studies analyzing field-related materials in constructed,
operating synthetic turf athletic fields. This lack of information could cause confusion and
uncertainty during subsequent permitting.
Analysis of the impact of any par ticular material on the environment must also include the manner,
intensity, and duration of exposure created. Notwithstanding the lack of definitive information
regarding the materials themselves, there are many mitigation factors that can limit risk to the
1 The Unico Properties applicant entities are: Unico Longacres South Building LLC, Unico Longacres
South Campus Land LLC, Unico Longacres Central Drainage LLC.
DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6
natural environment. Means of control to limit transfer of turf and turf components to the
environment include field design, the stormwater management and water quality system for the
fields, and operational practices that control and minimize material transport.
This request for reconsideration is supported by the attached letter prepared by Eric Gold of DA
Hogan, the field design consultant for Sounders FC Center at Longacres, which is attached as
Exhibit A. Please see Exhibit A for further discussion of these mitigation factors, and how they
have been incorporated into the proposal for two or more artificial t urf fields at the Sounders FC
Center at Longacres.
Respectfully submitted on behalf of the co-applicants,
THARSIS LAW P.S.
Jeremy Eckert
DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6
1450 114th Ave SE Page 1 of 2 p. 206-285-0400
Suite 225 f. 206-285-0480
Bellevue, WA 98004 www.dahogan.com
EXHIBIT A
MEMORANDUM
To: Julia Reeve, UNICO
Maya Mendoza-Exstrom, Seattle Sounders FC
Tom Chiado, Chiado LLC
Gretchen Blaine, Generator Studio
Cc: File
From: Eric Gold
Date: November 17, 2022
Re: Seattle Sounders FC HQ / Longacres Property
City of Renton SEPA Mitigation Condition 3
My Name is Eric Gold. I have over 20 years of experience on a wide range of public facilities, including parks,
recreational, and sports field development projects throughout Western Washington. I am the landscape architect
and field design consultant for the Sounders FC Center at Longacres.
As the field design consultant for the Sounders FC Center at Longacres, DA Hogan has significant concerns with the
wording of Condition #3 of the issued SEPA MDNS for the project. The condition reads: The fill material used on the
synthetic fields shall be comprised of a material that would be non -toxic to fish and other wildlife. We are not aware
of any synthetic field material that has been scientifically proven to meet this standard, so we do not know how we
could meet it. Initially, I would like to note that I am not an industrial hygienist or chemist. However, a s a professional
athletic field designer, I am very familiar with the ongoing conversations between grass and synthetic turf fields. Most
of these conversations focus on the perceived negative aspects of synthetic turf. DA Hogan has no stake in this debate
as we design grass and synthetic fields equally.
▪ Regarding the subject condition, its w ording selects a single attribute of synthetic fields, the “fill material,” as
the sole means for controlling impacts to the environment. But other field attributes can also effectively protect the
environment. Methods of field design, construction and operation can provide reasonable assurance that synthetic
materials remain in place as intended, and are not transported off site in quantities that are anything more than
incidental. The Sounders fields have been designed with these controls in place.
▪ Ways infill is prevented from “escaping into the wild” in the Project, as proposed, include:
à Field Section is vertically draining, i.e., precipitation is infiltrated at a high rate directly downward by
force of gravity, through the infill, turf backing, 2” of finely graded stone, 8”+ of coarse graded stone,
collected in subsurface drainage pipes and collectors, and conveyed and discharged to a water
quality treatment system. This is a closed system.
à Water quality treatment meets GULD Enhanced Basic requirements as described by the King County
Surface Water Design Manual.
à Fields are surrounded by a perimeter concrete containment curb that is designed to meet and match
to infill elevation at installation. Typically we can expect settlement of the initial 1.5” of infill by 15-
20%, meaning it is maintained slightly below the containment curb.
à The synthetic turf fields are surrounded by security and ball control fencing, with a continuous
woven vinyl wind screen material secured to it. This design would deflect most airborne material
back onto the field.
DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6
1450 114th Ave SE Page 2 of 2 p. 206-285-0400
Suite 225 f. 206-285-0480
Bellevue, WA 98004 www.dahogan.com
à Operationally, this is the training facility for a professional sports franchise , and use of the fields is
supervised. Random, unintended acts that might result in significant transport of infills off -site at a
local park, such as a giant snowball rolled around by kids ending up in a creek, are not likely to occur.
à The fields are designed at 1.5’ above flood stage (FG 21.50 over 20.00) to prevent material from
migrating with floodwater in the event of flood.
à The synthetic fields have been deliberately located further from Wetland A and its buffer, to provide
additional protection against transport to sensitive areas.
▪ Current status of the Turf System Design:
à The Project Team is finalizing a Request for Proposals (RFP) to be distributed to a shortlisted group
of 3 synthetic turf vendors.
à The structure of the RFP includes base bid and alternate bid options for a variety of synthetic turf
assemblies, that specify a variety of infill materials including SBR Crumb Rubber, Granular Cork, TPE,
and EPDM. We expect that sometime around mid-February sufficient pricing, availability, and
performance criteria will be available to the Sounders to make an informed decision.
à As stated at the beginning, we have no certification or surety that any of the materials described
above “would be non-toxic to fish or wildlife”.
Conclusion: In our experience, the field design, construction and operation measures are effective means to control
the transport of synthetic field material off-site.
DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6
December 2, 2022
City of Renton
c/o Julia Reeve
Unico Properties LLC
1215 Fourth Avenue, Suite 600
Seattle, WA 98161
RE Sounders Facility, Water Quality Treatment, and 6PPD-q
Dear Julia:
In 1998 the Boeing Master Plan for the Longacres site (approximately 158 acres in size) designed Pond B as a
Large Wetpond per the King County Surface Water Design Manual (KCSWDM) and the Renton Surface Water
Design Manual (RSWDM). Pollution generating impervious surfaces (PGIS) and non-pollution generating
pervious and impervious surfaces (NPGPS, NPGIS) on the Longacres site, including some of the Kaiser
Permanente Campus to the south, drains through Pond B. The site discharges to the managed stormwater
system within the Longacres property which was sized and constructed in anticipation of receiving undetained
and untreated runoff from this site. That system flows through a series of large ponds, small ponds, swales,
and control vaults and weirs, prior to leaving the site. The system then drains to Springbrook Creek which in
turn drains to the Black River and ultimately the Duwamish River and Puget Sound.
The Sounders Facility proposes to construct up to five playing fields, three of which will be covered with a
synthetic turf system. This project proposes to use a Filterra Bioscape, proprietary open filtration basin design
for water quality treatment of the water flowing from this field complex. This system is sized to meet the
Enhanced Basic level as required for this project by the City, and is sized to provide treatment for the 6-month
event runoff as specified in the RSWDM. Flows exceeding the design treatment rate, will be directed around
the Bioscape system via a flow splitter located above the facility. These higher flows will be directed into the
existing water quality pond on site, Pond B.
Per the Washington State Department of Ecology report titled 6PPD in Road Runoff (Publication 22-03-020)
“Stormwater treatment infrastructures that use infiltration, sorption, filtration, and/or effectively capture tire
wear particles are expected to reduce the toxicity from 6PPD-q.”, and “Filters that focus on reducing
suspended particles (e.g., total suspended solids) will be effective at capturing tire particles and any other
particulate matter with sorbed contaminants including 6PPD-q.”
We offer the following information to explain our conclusion that the recommended treatment system
(Bioscape) as currently sized. We should note that though the code requirement for treating stormwater runoff
for all systems within this area is the 6-month storm event, this project will be designed to treat the 2-year
rainfall event runoff, in a good-faith effort to even further reduce concerns regarding the field material. This
treatment rate means this facility will treat all of even more of the rainfall events that this facility will experience.
We believe that this treatment level is a reasonable approach to address the concern raised concerning the
6PPD-q pollutant. The concerns regarding this pollutant have been based, to date, on studies of roadway
runoff, which we believe to have important differences from the use of rubber in synthetic turf fields.
1. WATER TREATMENT
The selected Bioscape system as proposed, uses the recommended methods to treat water runoff to
reduce or eliminate 6PPD-q, as stated in the most recent Ecology discussions of the research
available. This system uses a combination of infiltration, filtration and sorption, as specifically
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2
mentioned to reduce the toxicity concerns of this chemical. This system also is listed as a highly
effective treatment for all stormwater systems designed to protect fish and other aquatic life from the
negative effects of pollutants in general beyond 6PPD-q.
2. EXISTING SYSTEM PROTECTIONS
This system is being installed within a larger water quality system for the original Boeing Longacres
site. This site was permitted starting in 1995 using the best available science, as reviewed by City of
Renton and by Ecology, to protect the downstream waterways from the pollutants created by urban
development in the proposed Boeing Master Plan. This plan consisted of multiple asphalt parking lots
around the future buildings. The Sounders project is adding the high-performance Bioscape water
quality system above the existing system on site. Water from the proposed fields will be filtered and
treated before flowing into the existing systems, in order to both comply with current standards and to
apply the best available science for pollutant removal of all types further reducing potential for
pollutant transport.
3. FIELD MATERIALS
Unlike in a roadway environment where tire dust and fine particles are blown or washed off of the road
surface quickly into storm systems or directly into receiving waters containing fish, the granular crumb
rubber in the synthetic turf fields at the proposed Sounders FC facility remains at the surface,
prevented from entering the stormwater system.
The crumb rubber used in fields is sieved and processed to reduce finer particles to the maximum
extent possible, including the finest dust. Therefore the mechanisms believed to cause degradation of
the rubber into 6PPD-q and the mobilization of those particles themselves are far less in the field
context than in roadway runoff which is the current basis of research on the issue. The largest
constituent of pollutant transport is broadly recognized to be the finer particles, down to dust-sized.
Smaller particles both degrade quicker (producing pollutants such as 6PPD-q) and can be transported
downstream more easily, for direct contact into waterways and aquatic organisms. Additionally, the
potential for fugitive infill materials to directly leave the field surface is further mitigated by 1) a
continuous perimeter containment curb and windscreen/fence, and 2) controlled access and use,
which limits potential unintended migration or transport.
4. FIELD DESIGN
The synthetic fields are constructed in a manner that provides a certain level of drainage pre-
treatment via filtration through gravel, in addition to preventing crumb rubber material from being
transported downstream. It is almost impossible for the field material to migrate via surface runoff,
which is the typical method of transport for both crumb rubber and the dissolved potential pollutants.
No surface should come into contact with the rubber, as the fields are designed for surface infiltr ation
into their under-drains, of the 100-year or larger storm event, more than twice the statistical storm
size, in a much shorter time period. 10-inches of rain falling in an hour, vs 5-inches of rain falling in 24
hours.
Once the water flows through the crumb rubber and then the underlying rock layers, the water is
carried on a very flat prepared subgrade and geotextile surface. This surface is then drained via flat
underdrain pipes. From a stormwater hydrology standpoint, Ecology has recognized that t hough
under-drained, synthetic turf fields only behave as though they are 50% impervious, whereas all
paved roadways are considered to be 100% impervious. Meaning significantly less water will ever
leave the fields compared to roadways, for the majority of stormwater events. Also the field drainage
design causes whatever water that does runoff beneath the fields, to move more slowly to enter the
piped under-drains.
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3
This added residence time via longer runoff time, is a factor to reduce the likelihood or amount of
pollutant runoff potential. Given the half-life of the 6PPD-q chemical that is quoted in the Ecology
study, the longer it takes for runoff to occur, theoretically less pollutants are transported downstream.
This runoff mechanism and time factor is very different than roadways which are the basis of the
current studies, which have almost immediate runoff downstream into a collection system or a
waterway.
5. FIELD MAINTENANCE
Professional Sports Franchises are required to maintain their facilities at the highest established
standards. In the case of the proposed Sounders fields, the design specifications require that the
installation be “FIFA QualityPRO” certified, meaning they must pass a battery of very specific
performance testing with very tight tolerances. Many characteristics are tested and measured against
this standard to allow the fields to be certified. For these reasons, Pro Sports Facilities surfaces are
typically replaced at a higher frequency than at park or school facilities, even high level collegiate
facilities. From our design team’s experience, this replacement will typically occur every 4-5 years.
By replacing the field surfaces systems more frequently, the crumb rubber used in the field
construction will have less time to degrade within the life cycle of the fields. This theoretically will also
reduce the opportunity for ozone related creation of the 6PPD-q pollutant, which occurs over the life
cycle of the rubber.
6. PROXIMITY TO FISH
Salmonids and other species of fish are not able to enter the Longacres site. The original design for
the Longacres mitigation project (ponds, swales, wetlands, etc) included a fish-barrier at the outfall to
Springbrook Creek. This helps to ensure that all of the existing and proposed systems on the campus
have the ability to provide maximum effectiveness prior to contact with the fish.
This concern had also been raised with regard to the potential flood mitigation storage currently
proposed for the fields. Due to the screens present at the site’s outfall to Springbrook Creek, there
should be no concerns about fish sequestration in the flood chambers and therefore the need to
provide screens or other methods at those proposed systems.
In summary, we believe this system, in addition to the existing downstream settlement ponds and the rigorous
maintenance associated with a professional sports field system, should be considered an adequate precaution
and appropriate design measure for this project with regard to this potential pollutant concern.
Our conclusion is based on the reasons stated above, which are summarized as:
1. Redundant existing water quality systems and conveyance systems exist already on the
Longacres site, as intended during the original and highly scrutinized design for the campus.
2. The best available science for mitigating potential runoff of 6PPD and 6PPD-q is proposed for this
project in the form of the Bioscape system that utilizes the same treatment methods
recommended by Ecology in the existing written documents concerning this pollutant. Even
further, the system proposed will be designed to treat a 2-year flow rate, which is 2 to 4 times
statistically less likely to occur than the 6-month storm standard requirement. The Bioscape
system is widely recognized and utilized by public agencies in Puget Sound for its high-
performance as tested by Ecology for regulated pollutants, and the higher treatment capacity
increases that performance.
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3. The rubber material used in the field construction is much more stable by its production method,
which is sieved and processed to reduce fine particles, and is therefore less likely to generate
pollutants through degradation or transport.
4. The field designs create a reduced volume and slower moving runoff regime, which works to
allow more degradation of the 6PPD-q to occur before runoff occurs, as identified currently in
available technical documents related to half-life of the pollutant.
5. The curbed design, and high-quality operations and maintenance of the professional sports fields
in question, result in less potential migration and degradation of the crumb rubber.
6. The entire train of systems in place on the site will have a chance to filter and remove pollutants
prior to discharge to the creek. This longer residency time should increase the chance for the
6PPD-q to biodegrade if present, before reaching the outfall.
We appreciate your consideration of our proposal and conclusions.
Sincerely,
Tim Brockway, P.E.
Principal
COUGHLINPORTERLUNDEEN
DocuSign Envelope ID: 11DC5520-6240-4D6D-A391-002D7BD9ABC6
DEPARTMENT OF COMMUNITY & ECONOMIC DEVELOPMENT
Planning Division
1055 South Grady Way, 6th Floor | Renton, WA 98057 | 425-430-7200, ext. 2
www.rentonwa.gov
OF ENVIRONMENTAL DETERMINATION
RE-ISSUANCE OF A DETERMINATION OF
NON-SIGNIFICANCE - MITIGATED (DNS-M)
POSTED TO NOTIFY INTERESTED PERSONS OF AN ENVIRONMENTAL ACTION
DNS-M: The City of Renton Environmental Review Committee (ERC) has determined that the proposed action has
probable significant impacts that can be mitigated through mitigation measures. This DNS -M is issued after using the
optional DNS process in WAC 197-11-355. There is no further comment period.
DATE OF NOTICE OF ENVIRONMENTAL
DETERMINATION:
December 5, 2022
PROJECT NAME/NUMBER: PR22-000301 Sounders FC Center at Longacres / LUA22-
000357, CUP-H, SA-H, ECF, MOD
PROJECT LOCATION: 1901 Oakesdale Ave SW (APN’s 0886700220,
0886700210, 0886700110, 0886700130, 0886700120,
0886700140, 0886700370)
APPLICANT/PROJECT CONTACT
PERSON:
Julia Reeve /1215 Fourth Ave, Suite 600 Seattle, WA 98161 /
juliar@unicoprop.com
LOCATION WHERE APPLICATION MAY
BE REVIEWED:
Applicant documents are available online through the City of Renton
Document Center website. See also https://cutt.ly/yBQ3iK7
DESCRIPTION: The applicant is requesting a Hearing Examiner Conditional Use Permit, Hearing Examiner Site Plan
Review, Environmental (SEPA) Review, and a Street Modification for the use of a portion of an existing office building
for Sounders FC office space and indoor training facilities and associated activities, outdoor recreation facilities including
5 full-size soccer fields a Goal Keepers Field and accessory structures, and reconfiguration of and existing surface parking
lot. The overall project site totals approximately 30 acres in area and is zoned Commercial Office (CO). Access to the Site
would be maintained via existing curb cuts off of Oakesdale Ave SW. The project site is currently developed with an
existing 5-story office building totaling approximately 311,982 sq. ft., and the Sounders propose to lease approximately
50,000 sq. ft. of floors 1 and 2. A new accessory viewing deck proposed to overlook Field 1 from floor 2 would total be
approximately 1,650 sq. ft. in area. Some existing surface parking would be removed for the placement of Fields 1 and 2
and additional parking would be removed to create a secure 1st team parking area in the existing southern parking lot.
The total remaining parking area would include approximately 766 surface parking stalls. A maintenance building
(approximately 4,000 sq. ft.) and future field restroom (approximately 800 sq. ft.) are proposed to be co-located between
fields 2 and 4. A Modification to the City's Street Standards was requested to maintain the existin g frontage
improvements around the project site. The project site is mapped with high seismic hazard areas, wetlands, and flood
hazard areas. A Category II wetland was identified to the northwest of the project site, a Category II wetland has a
standard buffer of 100 feet for low impact land uses and 150 feet for all other land uses. The proposal includes a reduction
in the standard buffer width in the vicinity of the soccer fields and the paper fill of the wetland. Wetland buffer
REVISED NOTICE
Anyone that would like to be informed of future actions or would like to become a party of record on this
proposal must fill out our online form at https://cutt.ly/SQvBak4 or complete this form and return to: City of
Renton, CED Planning Division, 1055 So. Grady Way, Renton, WA 98057.
Name/File No.: PR22-000301 Sounders FC Center at Longacres / LUA22-000357, CUP-H, SA-H, ECF, MOD
Name: ____________________________________ Email: _________________________ Phone#:__________________
Mailing Address: ____________________________________________ City/State/Zip: ___________________________
Notice will be sent via email, unless a hard copy is specifically requested. Check box to receive via US Mail
enhancement plantings and the purchase of wetland mitigation bank credits are proposed to mitigate for the impacts to
the wetland and buffer.
DECISION: Based on the additional information provided in the reconsideration request by the Applicant, the ERC has
retained SEPA mitigation measures 1 and 2 and amend mitigation measure 3 as stated below, add a new mitigation
measure 4 and renumber and retain mitigation measures 4, 5, and 6 as 5, 6, and 7:
3. The artificial turf field program, including field design, construction and operati on, together with stormwater
management and water quality treatment for drainage from the artificial turf fields, shall assure that the field materials
do not result in a probable adverse environmental impact on fish and wildlife. The proposed water quality treatment
facility shall be a Filterra Bioscape facility sized to treat the 2-year storm event or equivalent as approved by the City and
the applicant shall undertake quarterly water quality tests of field drainage, during the life of the field or for a five (5)
year period, whichever comes first. The applicant will submit a monitoring protocol to test for SBR Crumb Rubber
constituents of concern in field drainage for City approval.
4. When the fill within the synthetic turf athletic fields is replaced, the applicant shall be required to go through a new
Environmental Review.
Appeals of the environmental determination must be filed in writing on or before 5:00 p.m. on December 19, 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.
PUBLIC HEARING: If the Environmental Determination is appealed, a public hearing will be set and all parties notified.