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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