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HomeMy WebLinkAboutD_Lew_Boatlift_Shoreline_Permit_FINALDEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT PLANNING DIVISION SHORELINE MANAGEMENT ACT OF 1971 PERMIT FOR SHORELINE MANAGEMENT EVALUATION FORM & DECISION DATE OF PERMIT ISSUANCE: October 30, 2023 LAND USE ACTION FILE NO.: LUA23-000321, ECF, SSDP DATE RECEIVED September 19, 2023 DATE OF PUBLIC NOTICE: September 20, 2023 Pursuant to Chapter 90.58 RCW, staff recommends that the City of Renton grant a Shoreline Substantial Development Permit. This action is proposed on the following application: PROJECT NAME: Lew Boatlift PROJECT MANAGER: Jill Ding, Senior Planner OWNER APPLICANT/CONTACT: Sin Lew 3101 Mountain View Ave N Renton, WA 98056 Zion Napier Seaborn Pile Driving 1080 W Ewing Pl #300 Seattle, WA 98119 PROJECT LOCATION: 3101 Mountain View Ave N (Parcel no. 3342103895) LEGAL DESCRIPTION: (Per King County Assessors Records) HILLMANS LK WN GARDEN OF EDEN # 1 POR OF LOTS 56-57 & 58 & OF ADJ 2ND CL SH LDS DAF BEG AT INTX OF S LN OF LOT 58 WITH GOV MDR LN TH S 80-13-02 W 42.78 FT TH N 72-03-18 W 99.44 FT TH S 89- 50-57 W 190.56 FT TO INNER HARBOR LN TH N 23-40-00 E ALG SD HARBOR LN 52.76 FT TH N 89-50-57 E 219.38 FT TH S 75-24-20 E 83.14 FT TH S 61-50-30 E 22.86 FT TH N 89-50-57 E TO ELY LN OF BLK A TH SLY ALG SD ELY LN TO S LN OF LOT 58 TH S 89-50-57 W ALG SD S LN TO BEG TGW POR OF LOTS 57 & 58 & OF ADJ 2ND CL SH LDS DAF BEG AT INTX OF S LN OF LOT 58 WITH MDR LN TH S 80-13-02 W 42.78 FT TO TPOB TH N 72-03-18 W 99.44 FT TH S 89-50-57 W 190.56 FT TO INNER HARBOR LN TH S 23-40-00 W ALG SD HARBOR LN TAP S 80-13-02 W FR TPOB TH N 80-13-02 E TO TPOB SEC-TWN-R: SEC31-TWN24- R5 PROJECT WITHIN THE SHORELINE OF: Lake Washington, Reach E APPLICABLE MASTER PROGRAM: City of Renton DocuSign Envelope ID: 202BB3DF-0B94-4915-AC3E-BA6B7670C5E1 City of Renton Department of Community & Economic Development Shoreline Management Permit Lew Boatlift LUA23-000321, ECF, SSDP DATE OF PERMIT: October 30, 2023 Page 2 of 10 PROPOSAL DESCRIPTION: The applicant is requesting a Shoreline Substantial Development Permit and Environmental (SEPA) Review for the installation of a new boat lift for the property owners of 3101 Mountain View Ave N on an existing dock. The existing dock was recently permitted under LUA22-126. The project site and adjacent properties are zoned as R-8. The site is on the shoreline of Lake Washington (Reach E) within the Shoreline Residential and Aquatic designations. The proposed boat lift would be located approximately 144’ waterward of the ordinary high water mark on the south side of the dock. The boat lift would be 12’-2” wide by 15’-11” long. The bunk of the boat lift would extend 18” above the ordinary high water mark and the lift will sit on the lake bed of L ake Washington on foot pads. No dredging, fill, or excavation would be done for the project. An Environmental (SEPA) Review Determination of Non-Significance (DNS) was issued for this project on October 30, 2023. The appeal period of the determination ends on November 13, 2023. FINDINGS OF FACT: 1. The applicant is requesting a Shoreline Substantial Development Permit for the installation of a boatlift on an existing dock for the use of an upland residential property owner. 2. The landward portion of the site currently is developed with an existing single-family residence and detached garage. 3. The boat lift would be 12’-2” wide by 15’-11” long. The bunk of the boat lift would extend 18” above the ordinary high water mark and the lift will sit on the lake bed of Lake Washington on foot pads. 4. The proposed boatlift would provide boat moorage, which would facilitate access to Lake Washington for use by the property owner. 5. The boat lift use is water dependent and therefore is permitted outright per RMC Table 4-3-090.E.1 Shoreline Use Table, and would be located within water that is approximately six feet (6’) deep. 6. New residential docks are permitted when a shared/joint-use dock is not available. 7. The subject site has priority habitat and is located in areas regulated by the City of Renton Shoreline Master Program for Lake Washington. 8. There is a moderate landslide hazard area mapped on the upland portion of the project site, however the installation of the boatlift would occur below the Ordinary High Water Mark (OHWM) and would not require additional geotechnical analysis. 9. The proposed boatlift installation would not require the removal of existing trees or other significant vegetation. 10. Comments were received from the Duwamish Tribe (Exhibit 4) and King County Parks Department (Exhibit 7). Comments from the Duwamish were addressed as part of the ERC Report (Exhibit 1) and as further discussed below under Archaeological, Histrical, and Cultural Resources. The King C ounty Parks Department noted that the project site is located across the street from King County Parks parcel 3124059004, part of the Eastrail Trail system and that the parks property may not be used for construction entrance, staging, or storage. 11. Representatives from various city departments have reviewed the application materials to identify and address issues raised by the proposed development. These comments are contained in the official file, and the essence of the comments have been incorporated into the appropriate sections of this report, the Environmental (SEPA) Review Report, and the Departmental Recommendation at the end of this report. DocuSign Envelope ID: 202BB3DF-0B94-4915-AC3E-BA6B7670C5E1 City of Renton Department of Community & Economic Development Shoreline Management Permit Lew Boatlift LUA23-000321, ECF, SSDP DATE OF PERMIT: October 30, 2023 Page 3 of 10 12. An Environmental (SEPA) Review Determination of Non-Significance (DNS) was issued for this project on October 30, 2023. The appeal period of the determination ends on November 13, 2023. No appeals have been filed as of the date of this decision. 13. An updated Lake Study, prepared by Northwest Environmental Consulting, LLC, dated May 2022 (Exhibit 3) was submitted with the project application. The Lake Study states that with the mitigation installed under LUA22- 000126, there would be no net loss of ecological functions and values. 14. The following table contains project elements intended to comply with the Shoreline Master Program standards and policies, as outlined in RMC 4-3-090: SHORELINE MASTER PROGRAM CRITERIA: A. COMPREHENSIVE PLAN COMPLIANCE AND CONSISTENCY, SHORELINE ELEMENT: The site is located in the Shoreline Residential and Aquatic Overlay Districts. The objective of the Residential Shoreline Overlay District is to accommodate residential development and appurtenant structures that are consistent with this chapter. The objective of the Aquatic designation is to protect, restore, and manage the unique characteristics and resources of the areas waterward of the ordinary high water mark. The proposal is compliant with the following Shoreline pol icies: ✓ Objective SH-A. Provide for use of the limited water resource consistent with the goals of the Shoreline Management Act by providing a preference for water-oriented uses. ✓ Objective SH-B. Provide that the policies, regulations, and administration of the Shoreline Master Program ensure that new uses, development, and redevelopment within the shoreline jurisdiction do not cause a net loss of shoreline ecological functions. ✓ Policy SH-7. Existing and future activities on all Shorelines of the State regulated by the City of Renton should be designed to ensure no net loss of ecological functions. ✓ Policy SH-14. Shoreline use and development should be carried out in a manner that prevents or mitigates adverse impacts so that the resulting ecological condition does not become worse than the current condition. This means ensuring no net loss of ecological functions and processes in all development and use. Permitted uses should be designed and conducted to minimize, in so far as practical, any resultant damage to the ecology and environment (RCW 90.58.020). Shoreline ecological functions that should be protected include, but are not limited to, fish and wildlife habitat, food chain support, and water temperature maintenance. Shoreline processes that shall be protected include, but are not limited to, water flow; littoral drift; erosion and accretion; infiltration; ground water recharge and discharge; sediment delivery, transport, and storage; large woody debris recruitment; organic matter input; nutrient and pathogen removal; and stream channel formation/maintenance. B. DEVELOPMENT STANDARDS: The subject site where the pier will be located is classified as Shoreline Residential and Aquatic on the City of Renton Shoreline Overlay Map. The following development standards are applicable to the proposal: DocuSign Envelope ID: 202BB3DF-0B94-4915-AC3E-BA6B7670C5E1 City of Renton Department of Community & Economic Development Shoreline Management Permit Lew Boatlift LUA23-000321, ECF, SSDP DATE OF PERMIT: October 30, 2023 Page 4 of 10 1. No Net Loss of Ecological Functions Required ✓ Shoreline use and development shall be carried out in a manner that prevents or mitigates adverse impacts to ensure no net loss of ecological functions and processes in all development and use. Permitted uses are designed and conducted to minimize, in so far as practical, any resultant damage to the ecology and environment (RCW 90.58.020). Shoreline ecological functions that shall be protected include, but are not limited to, fish and wildlife habitat, food chain support, and water temperature maintenance. Shoreline processes that shall be protected include, but are not limited to, water flow; erosion and accretion; infiltration; groundwater recharge and discharge; sediment delivery, transport, and storage; large woody debris recruitment; organic matter input; nutrient and pathogen removal; and stream channel formation/maintenance. Impact Evaluation Required: In assessing the potential for net loss of ecological functions or processes, project-specific and cumulative impacts shall be considered and mitigated on- or off-site. Evaluation of Mitigation Sequencing Required: An application for any permit or approval shall demonstrate all reasonable efforts have been taken to provide sufficient mitigation such that the activity does not result in net loss of ecological functions. Mitigation shall occur in the following prioritized order: (a) Avoiding the adverse impact altogether by not taking a certain action or parts of an action, or moving the action. (b) Minimizing adverse impacts by limiting the degree or magnitude of the action and its implementation by using appropriate technology and engineering, or by taking affirmative steps to avoid or reduce adverse impacts. (c) Rectifying the adverse impact by repairing, rehabilitating, or restoring the affected environment. (d) Reducing or eliminating the adverse impact over time by preservation and maintenance operations during the life of the action. (e) Compensating for the adverse impact by replacing, enhancing, or providing similar substitute resources or environments and monitoring the adverse impact and taking appropriate corrective measures. Staff comment: The applicant submitted a Lake Study (Exhibit 3), prepared by Northwest Environmental Consulting, LLC, dated May 2022 with the project application materials. The report includes an evaluation of mitigation sequencing. The proposed boatlift would be located on an existing dock resulting in no vegetation removal thereby avoiding impacts to existing vegetation. Construction impacts, including noise disturbance of sediments during piling installation would be minimized by using Best Management Practices (BMPs) during project construction. As a part of mitigation for the dock installation (LUA22-000126), the applicant planted three (3) western red cedars, two (2) shore pine, four (4) nootka rose, and three (3) mock orange along the shoreline. These proposed plantings will provide overhanging cover, structural diversity for birds and wildlife, detritus for aquatic invertebrates and long -term recruitment of woody material and other allochthonous food sources for aquatic invertebrates and fis h. It is anticipated that these plantings would also mitigate for impacts that could result from the DocuSign Envelope ID: 202BB3DF-0B94-4915-AC3E-BA6B7670C5E1 City of Renton Department of Community & Economic Development Shoreline Management Permit Lew Boatlift LUA23-000321, ECF, SSDP DATE OF PERMIT: October 30, 2023 Page 5 of 10 installation of the boatlift. The plantings were inspected and an As -Built (Exhibit 8) was received on May 3, 2023. The study concludes that with the previously installed mitigation plantings proposed the proposed dock would result in no net loss of ecological functions at the site. 2. Burden on Applicant ✓ Applicants for permits have the burden of proving that the proposed development is consistent with the criteria set forth in the Shoreline Master Program and the Shoreline Management Act, including demonstrating all reasonable efforts have been taken to provide sufficient mitigation such that the activity does not result in net loss of ecological functions. Staff Comment: The applicant has submitted a Lake Study (Exhibit 3) that demonstrates that the proposed boatlift woud not result in a net loss of ecological functions and values on the project site, which is consistent the the City of Renton’s Shoreline Master Program and the Shoreline Management Act. 3. View Obstruction and Visual Quality N/A View Corridors Required: Where commercial, industrial, multiple use, multi -family and/or multi-lot developments are proposed, primary structures shall provide for view corridors between buildings where views of the shoreline are available from public right- of-way or trails. Staff comment: Not applicable, the proposal does not include commercial, industrial, multiple use, multi-family and/or multi-lot developments. ✓ Maximum Building Height: Buildings shall be limited to a height of no more than 35 feet above average finished grade level except at specific locations. Staff comment: The lift is less than 35 feet in height above the waterline. N/A Minimum Setbacks for Commercial Development Adjacent to Residential or Park Uses: All new or expanded commercial development adjacent to residential use and public parks shall provide fifteen feet setbacks from adjacent properties to attenuate proximity impacts such as noise, light and glare, and may address scale and aesthetic impacts. Fencing or landscape areas may be required to provide a visual screen. N/A Lighting Requirements: Display and other exterior lighting shall be designed and operated so as to prevent glare, to avoid illuminating nearby properties used for noncommercial purposes, and to prevent hazards for public traffic. Methods of controlling spillover light include, but are not limited to, limits on the height of light structure, limits on light levels of fixtures, light shields, and screening. Staff comment: Not applicable, no lighting is proposed as part of this project. N/A Reflected Lights to Be Limited: Building surfaces on or adjacent to the water shall employ materials that limit reflected light. Staff comment: Not applicable, no buildings are proposed as part of this project. DocuSign Envelope ID: 202BB3DF-0B94-4915-AC3E-BA6B7670C5E1 City of Renton Department of Community & Economic Development Shoreline Management Permit Lew Boatlift LUA23-000321, ECF, SSDP DATE OF PERMIT: October 30, 2023 Page 6 of 10 N/A Integration and Screening of Mechanical Equipment: Building mechanical equipment shall be incorporated into building architectural features, such as pitched roofs, to the maximum extent feasible. Where mechanical equipment cannot be incorporated into architectural features, a visual screen shall be provided consistent with building exterior materials that obstructs views of such equipment. Staff comment: Not applicable, no mechanical equipment is proposed as part of this project. ✓ Visual Prominence of Freestanding Structures to Be Minimized: Facilities not incorporated into buildings including fences, piers, poles, wires, lights, and other freestanding structures shall be designed to minimize visual prominence. Staff comment: The boatlift would primarily be located below the water surface. Therefore the structure would not have a significant visual prominence when viewed from neighboring homes or the shoreline in general. ✓ Maximum Stair and Walkway Width: Stairs and walkways located within shoreline vegetated buffers shall not exceed four feet in width; provided, that where ADA requirements apply, such facilities may be increased to six feet in width. Stairways shall conform to the existing topography to the extent feasible. Staff comment: No stair or walkways are proposed as part of this project. 4. Community Disturbances: ✓ Noise, odors, night lighting, water and land traffic, and other structures and activities shall be considered in the design plans and their impacts avoided or mitigated. Staff comment: The project is not anticipated to generate noise, odors, lighting issues, or other water and land traffic disturbances beyond those that are part of water and boating related activities on the lake and that occur with a residential pier and moorage facility. 5. Public Access: Physical or visual access to shorelines shall be incorporated in all new development when the development would either generate a demand for one or more forms of such access, would impair existing legal access opportunities or rights, or is required to mee t the specific policies and regulations of the Shoreline Master Program. N/A Lake Washington Reach E: Public access shall be provided when lots are subdivided or new nonresidential development occurs consistent with standards of this Section. Staff comment: The project proposal includes the addition of a residential boatlift to an existing dock. No subdivision or nonresidential development is proposed ; therefore the public access requirement is not applicable. 6. Building and Development Location – Shoreline Orientation Shoreline developments shall locate the water-dependent, water-related, and water-enjoyment portions of their developments along the shoreline. Development and use shall be designed in a manner DocuSign Envelope ID: 202BB3DF-0B94-4915-AC3E-BA6B7670C5E1 City of Renton Department of Community & Economic Development Shoreline Management Permit Lew Boatlift LUA23-000321, ECF, SSDP DATE OF PERMIT: October 30, 2023 Page 7 of 10 that directs land alteration to the least sensitive portions of the site to maximize vegetation conservation; minimize impervious surfaces and runoff; protect riparian, nearshore and wetland habitats; protect wildlife and habitats; protect archaeological, historic and cultural resources; and preserve aesthetic values ✓ Minimization of Site Alteration: Development shall minimize site alteration in sites with substantial unaltered natural features by applying the following criteria: (a) Vehicle and pedestrian circulation systems shall be designed to limit clearing, grading, and alteration of topography and natural features. (b) Impervious surfacing for parking lot/space areas shall be limited through the use of under-building parking or permeable surfaces where feasible. (c) Utilities shall share roadway and driveway corridors and rights-of-way wherever feasible. (d) Development shall be located and designed to avoid the need for structural shoreline stabilization over the life of the development. Exceptions may be made for the limited instances where stabilization is necessary to protect allowed uses, particularly water - dependent uses, where no alternative locations are available and no net loss of ecological functions will result. Staff comment: The site is already developed and the addition of the lift will not substantially alter any natural features. The criteria above are not applicable to the proposed lift due to the type of project and waterward location of the project. N/A Location for Accessory Development: Accessory development or use that does not require a shoreline location shall be located outside of shoreline jurisdiction unless such development is required to serve approved water-oriented uses and/or developments or unless otherwise allowed in a High Intensity designation. When sited within shoreline jurisdiction, uses and/or developments such as parking, service buildings or areas, access roads, utilities, signs and storage of materials shall be located inland away fro m the land/water interface and landward of water-oriented developments and/or other approved uses unless a location closer to the water is reasonably necessary. ✓ Navigation and Recreation to Be Preserved: Shoreline uses shall not deprive other uses of reasonable access to navigable waters. Existing water-related recreation shall be preserved. Staff comment: The proposed boatlift would be located within the property boundaries of the project site and would not encroach past the inner harbor line of Lake Washington or impede access to navigable waters. 7. Archaeological, Historical, and Cultural Resources: Compliant if condition of approval is met Detailed Cultural Assessments May Be Required: The City will work with tribal, State, Federal, and other local governments as appropriate to identify significant local historical, cultural, and archaeological sites in observance of applicable State and Federal laws protecting such information from general public disclosure. Detailed cultural assessments may be required in areas with undocumented resources based on the probability of the presence of cultural resources. DocuSign Envelope ID: 202BB3DF-0B94-4915-AC3E-BA6B7670C5E1 City of Renton Department of Community & Economic Development Shoreline Management Permit Lew Boatlift LUA23-000321, ECF, SSDP DATE OF PERMIT: October 30, 2023 Page 8 of 10 Staff comment: The project proposal and notice of application were provided to reviewing agencies including the State Department of Archaeology & Historic Preservation (DAHP), and the Duwamish and Muckleshoot Tribes as part of the SEPA review process. Comments were received from the Duwamish Tribe (Exhibit 4) requesting that the tribe be notified if archeological resources are identified during the installation of the boatlift. Staff recommends, as a condition of approval, that the Duwamish Tribe be notified if archeological resources are discovered during the installation of the boatlift. ✓ Coordination Encouraged: Owners of property containing identified or probable historical, cultural, or archaeological sites are encouraged to coordinate well in advance of application for development to assure that appropriate agencies such as the Washington State Department of Archaeology and Historic Preservation, affected tribes, and historic preservation groups have ample time to assess the site and identify the potential for cultural resources. Staff comment: See comment above. ✓ Detailed Cultural Assessments Required: Upon receipt of application for a development in an area of known or probable cultural resources, the City shall require a site assessment by a qualified professional archaeologist or historic preservation professional and ensure review by qualified parties including the Washington State Department of Archaeology and Historic Preservation, affected tribes, and historic preservation groups. Staff comment: See comment above. ✓ Work to Stop Upon Discovery: If historical, cultural, or archaeological sites or artifacts are discovered in the process of development, work on that portion of the site shall be stopped immediately, the site secured, and the find reported as soon as possible to the Administrator of the Department of Community and Economic Development or designee. Upon notification of such find, the property owner shall notify the Washington State Department of Archaeology and Historic Preservation and affected tribes. The Administrator of the Department of Community and Economic Development or designee shall provide for a site investigation by a qualified professional and may provide for avoidance, or conservation of the resources, in coordination with appropriate agencies. Staff comment: See comment above. ✓ Access for Educational Purposes Encouraged: Land owners are encouraged to provide access to qualified professionals and the general public if appropriate for the purpose of public education related to a cultural resource identified on a property. Staff comment: See comment above. 8. Standards for Density, Setbacks, and Height – Activities Exempt from Buffers and Setbacks The following development activities are not subject to buffers and setbacks; provided, that they are constructed and maintained in a manner that minimizes adverse impacts on shoreline ecological functions; and provided further, that they comply with all the applicable regulations in RMC Title IV. DocuSign Envelope ID: 202BB3DF-0B94-4915-AC3E-BA6B7670C5E1 City of Renton Department of Community & Economic Development Shoreline Management Permit Lew Boatlift LUA23-000321, ECF, SSDP DATE OF PERMIT: October 30, 2023 Page 9 of 10 This Permit is granted pursuant to the Shoreline Management Action of 1971 and pursuant to the following: 1. The issuance of a license under the Shoreline Management Act of 1971 shall not release the applicant from compliance with federal, state, and other permit requirements. 2. This permit may be rescinded pursuant to Section 14(7) of the Shoreline Management Act of 1971 in the event the permittee fails to comply with any condition(s) hereof. 3. Construction permits shall not be issued until 21 days after approval by the Washington State Department of Ecology or until any review proceedings initiated within this twenty -one (21)-day review period have been completed. 4. The proposed boatlift may require additional permits from other state and federal agencies. It is the applicant’s repsonsiblity to obtain all necessary permits. 5. The Duwamish Tribe shall be notified if archeological resources are discovered during the installation of the boatlift. 6. The project site is located across the street from King County Parks parcel 3124059004, part of the Eastrail Trail system, the parks property shall not be used for a construction entrance, staging, or storage. DATE OF DECISION ON LAND USE ACTION: SIGNATURE: Matthew Herrera, Acting Planning Director Department of Community & Economic Development Date APPEALS: Appeals of Shoreline Substantial Development Permit issuance must be made directly to the Shorelines Hearings Board. Appeals are made by filing a request in writing within the 21 days of receipt of the final order and concurrently filing copies of such request with the Washington State Department of Ecology and the Attorney General’s office as ✓ Water-Dependent Development: Those portions of approved water-dependent development that require a location waterward of the OHWM of streams, rivers, lakes, ponds, marine shorelines, associated wetlands, and/or within their associated buffers. Staff comment: The proposed boatlift would be considered water-dependent development and would therefore not be subject to the vegetation conservation buffer or building setback requirements. 9. Use Regulations: Boat Moorage, such as piers and docks, is permitted in the Aquatic Shoreline Overlay District as it is water dependent pursuant to the Shoreline Use Table RMC 4-3-090E.1. Boatlifts: ✓ Boat lifts are water dependent uses and therefore permitted outright in the Aquatic designation. Staff comment: The proposed boatlift is located adjacent to an existing dock within the Shoreline Aquatic designation. DocuSign Envelope ID: 202BB3DF-0B94-4915-AC3E-BA6B7670C5E1 10/30/2023 | 2:51 PM PDT City of Renton Department of Community & Economic Development Shoreline Management Permit Lew Boatlift LUA23-000321, ECF, SSDP DATE OF PERMIT: October 30, 2023 Page 10 of 10 provided in section 18(1) of the Shorelines Management Act of 1971. All copies of appeal notices shall also be filed with the City of Renton Planning Division and the City Clerk’s office. EXPIRATION: Unless a different time period is specified in the shoreline permit as authorized by RCW 9 0.58.143 and subsection J1 of RMC 4-9-190, construction activities, or a use or activity, for which a permit has been granted pursuant to this Master Program must be commenced within two (2) years of the effective date of a shoreline permit, or the shoreline permit shall terminate, and a new permit shall be necessary. However, the Planning Division may authorize a single extension for a period not to exceed one year based on reasonable factors, if a request for extension has been filed with the Planning Division before the expiration date, and notice of the proposed extension is given to parties of record and the Washington State Department of Ecology. DEFINITION OF COMMENCEMENT OF CONSTRUCTION ACTIVITIES: the construction applications must be submitted, permits must be issued, and foundation inspections must be completed before the end of the two (2) year period. Exhibits/Attachments: Exhibits 1-5: ERC Report and Exhibits Exhibit 6: DNS Exhibit 7: King County Parks Comments and City Response Exhibit 8: Mitigation Plantings As-Built for LUA22-000126 cc: Office of Attorney General Matthew Herrera, Current Planning Manager DocuSign Envelope ID: 202BB3DF-0B94-4915-AC3E-BA6B7670C5E1