HomeMy WebLinkAboutPN_ Project_Narrative_230406_v1
Puget Sound Energy
P.O. Box 97034
Bellevue, WA 98009-9734
pse.com
April 4, 2023
City of Renton
1055 S. Grady Way
Renton, WA 98057
RE: Benson Road South Pole Replacement-Geologic Hazard Letter of Exemption
To Whom It May Concern:
PSE is seeking a Geologic Hazard Critical Area Exemption for a proposed pole replacement along
Benson Road South, within the city limits of Renton, Washington. The existing pole has exceeded
its useful lifespan and must be replaced in order to continue serving safe and reliable power to
customers. Typically, new poles will be placed as close to their current location as reasonably
possible and then old poles will be removed and taken off site once all overhead attachments
have been transferred by the responsible owners. The proposed pole replacement also requires
520 square feet of vegetation removal for access. According to City of Renton Critical Areas
publicly available GIS resources and Municipal Code, the proposed pole replacement is within
two geologic hazard critical areas: sensitive (>25% & <=40%) steep slope and moderate Landslide
Hazard.
The work is categorically exempt from SEPA review pursuant WAC 197-11-800(3). The examples
provided in the exemption (“…repair or replacement of piling, ramps, floats, or mooring buoys, or
minor repair, alteration, or maintenance of docks”) are similar in scale and nature to a utility pole
replacement.
The scope of this necessary repair and maintenance falls within the classifications of RCC4-3-
050C Exempt Prohibited and Nonconforming Activities subsection (2) Letter of Exemption. The
proposed activities within the Geological Hazard Area are allowed under RCC 4-3-050C
Exemption (3)(e)(ii) and (iv) Footnotes:
14. Normal and routine maintenance, operation and repair of existing parks, trails,
streets, roads, rights-of-way and associated appurtenances, facilities and utilities where
no alteration or additional fill materials will be placed other than the minimum alteration
and/or fill needed to restore those facilities or to construct new trails to meet established
safety standards. The use of heavy construction equipment shall be limited to utilities and
public agencies that require this type of equipment for normal and routine maintenance
and repair of existing utility structures and rights-of-way. In every case, critical area and
Puget Sound Energy
P.O. Box 97034
Bellevue, WA 98009-9734
pse.com
required buffer impacts shall be minimized and disturbed areas shall be restored during
and immediately after the use of construction equipment.
18. Maintenance activities, including routine vegetation management and essential tree
removal, and removal of non-native invasive vegetation or weeds listed by the King
County Noxious Weed Board or other government agency, for public and private utilities,
road rights-of-way and easements, and parks.
The proposed pole replacement meets the criteria listed above because the project scope
includes:
Activity is normal and routine maintenance of an existing utility pole and access.
No new buildings or structures are proposed upon completion of activity the vegetation
and land configuration of the site will be restored to conditions existing before the
activity.
Use of heavy equipment will be minimized as much as required for normal and routine
maintenance.
No tree removal is proposed and vegetation removal will be kept to the minimum
amount necessary to access the pole.
The activity will have no significant adverse impact on the environment, including but not
limited to fish, wildlife, fish or wildlife habitat, water quality, erosion, and aesthetic
values.
Access routes and the pole proposed for replacement are designed for an existing distribution
corridor that has maintained the highest standard of safety feasible to provide customers in
Renton with a reliable electrical utility. The project was designed to avoid permanent impacts to
critical areas and their buffers including Geologic Hazards. Where impacts could not be avoided
(Pole 01) impacts have been minimized to the extent feasible.
The proposed project would impact two parcels one under private ownership (202305-9090)
and the other owned by Puget Sound Energy (202305-9010). The current use on both properties
is developed office building, office parking lot, and vacant parcel. The proposed access road
would extend 52. 8 feet westerly off Benson Road South ROW within the vacant parcel. The
access road would be temporary in nature and vegetation cleared would be allow to re-establish
after project is complete. Please note that PSE does not have the authority to encumber
property owners with critical areas assessments outside of PSE’s recorded utility easements or
franchise area.
If any critical areas assessments are deemed to be required for this repair and maintenance work
the study area will be limited to the franchise area where PSE has operating rights.
Puget Sound Energy
P.O. Box 97034
Bellevue, WA 98009-9734
pse.com
All work will occur within established City rights-of-way under franchise agreement, PSE Owned
Property, or within private utility easements. No tree removal is proposed. ESC measures will be
applied on an as-needed basis depending on site conditions at the time of construction.
Disturbed surfaces will be restored to original condition or better upon completion of
construction. All work will occur during reasonable hours and construction limits will be clearly
marked.
Figure 1: Location of Pole 01 within the City of Renton Regulated Slopes
P01
Puget Sound Energy
P.O. Box 97034
Bellevue, WA 98009-9734
pse.com
Figure 2. Location of P01 within the City of Renton Landslide Mapping
If you have any questions, please feel free to contact me at Mary.Nicholl@pse.com.
Sincerely,
Mary Nicholl
Municipal Land Planner
P01