HomeMy WebLinkAboutFEISConsultant Team:
BERK Consulting
Perteet
The Transpo Group
Prepared For:
Rainier/Grady Junction TODSubarea Planned Action
Final Environmental Impact Statement
March 2024
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ArmondoPavoneIIMayorCommunity&EconomicDevelopment/1BrianneBannwarth,InterimAdministratorMarch27,2024Subject:Rainier/GradyJunctionTODPlannedActionFinalEnvironmentalImpactStatementDearReader:TheattachedFinalEnvironmentalImpactStatementfEIS)respondstocommentsontheDraftEISandcompletestheenvironmentalanalysisoftheRainier/GradyJunctionTransitOrientedDevelopment(TOD)SubareaPlan(“SubareaPlan”).TheCityofRenton(City)adoptedtheSubareaPlanin2021toestablishacommunity-drivenvisionforapedestrian-orienteddistrictsurroundingthefutureSouthRentonTransitCenterlocatedatthenortheastcorneroftheRainierAveSandSW/SGradyWayjunction.Theproposedconceptsincludemixed-usedevelopmentatscalesexceedingcurrentallowances,strongpedestrianandbicycleconnections,newstreetsthatcreatebetteraccessforallmodesinthesuper-blockreferredtoas“RentonVillage,”apedestrian-orientedinternalmainstreet,thecreationofpublicopenspaceuponutilityeasementcorridors,andhousingthataccommodatesawiderangeofincomes.TheCitysecuredagrantfromtheWashingtonStateDepartmentofCommercetocompletean[ISpursuanttotheStateEnvironmentalPolicyAct(SEPA)toassessthreealternativesthatincludedifferentlevelsofhousingandemploymentgrowthinthestudyarea:•Alternative1—ExistingPlan(NoAction):Continuationofexistingregulationsandtrends.•Alternative2—Incentive-BasedGrowth:SetminimumstandardsandincentivestoachieveoptimalSubareaPlanimplementationresultinginapredominatelymid-risedevelopmentpatternwithsomehigh-risedevelopmentpossiblethroughincentivizedstandards;and•Alternative3—RequiredPublicBenefit:Allowhigh-risedevelopmentwithrequiredstandardsandpublicbenefits.AsofMarch2024,theRentonPlanningCommissionandCityCouncilPlanningandDevelopmentCommitteerecommendAlternative2withitsincentive-basedapproach.BuildingheightandgrowthlevelscouldrangeuptolevelsstudiedwithAlternative3.TheSEPArequiresastatementofobjectivesdescribingthepurposeandneedfortheproposals.TheSubareaPlanincludesthefollowingfourgoals,whichserveasobjectivesforthisEIS:1.AlignwithOverallVisionforRenton:AlignwithoverallvisionforRenton’sCityCenterareaandsupporttheuniqueroleofthesubareainwaysthatarecomplementarytoDowntown,thelargerCityCenterarea,andRentonasawhole.1055SGradyWay,Renton,WA98057IIrentonwa.gov
Page2of2Match27,20242.TransitiontoMultimodalCenter:Transitiontheareaintoapedestrian-orienteddistrictwithamulti-modalcenterandstrongpedestrianconnections.3.CreateaLivableNeighborhood:Createalivable,distinctneighborhoodthatisactive18hoursaday,complementsDowntown,andgracefullyintegrateswithneighboringareas.4.CatalyzeDesiredChanges:Leveragetherecentandplannedpublicinvestmentintheareafortheprivateinvestmenttofollow.TheCityissuedaDraftElSinJanuary2024,andtheCityprovideda30-daycommentperiodandahearing.TheFinalEIScompletestheSEPAprocess,identifiesaPreferredAlternative,andprovidesresponsestocommentsontheDraftEIS.TheDraftEISandFinalElSshouldbeconsideredtogether.TheFinalEISidentifiesenvironmentalimpactsofthealternativesandwaystomitigateimpactsofdevelopment.EnvironmentalmattersevaluatedintheEISinclude:thenaturalenvironment;landuse;transportation;publicservices;andutilities.YourinterestintheCityofRentonandthecontentoftheFinalEISisgreatlyappreciated.Ifyouwouldlikemoreinformationaboutthisproposal,pleasecontactPaulHintz,PrincipalPlannerat(425)430-7436.Sincerely,MartinPastucha,PublicWorksAdministratorSEPAResponsibleOfficialCityofRenton1055SGradyWay.Renton,WA98057IIrentonwa.gov
iii
Fact Sheet
Project Title
Rainier / Grady Junction Transit Oriented Development (TOD) Subarea Planned Action
Proposed Action and Alternatives
In 2020 the City of Renton (“City”) developed the Rainier/Grady Junction TOD Subarea Plan (“Subarea Plan”) to
create a vibrant commercial and residential district oriented around near-term bus rapid transit, with potential
for light rail service in the long term.
The City is now considering Municipal Code Amendments to implement the land use vision of the Subarea Plan
to increase mixed-use opportunities and alter density and development standards including height, density,
parking, and others.
A Planned Action Ordinance “Planned Action” will facilitate growth that is consistent with the Subarea Plan by
implementing municipal code amendments and completing an Environmental Impact Statement (EIS) for the
area. The Planned Action will complete the environmental review upfront and establish environmental
performance standards that each development would be required to meet. Development consistent with the
ordinance requirements would not require a new threshold determination and could rely on the Planned Action
EIS to streamline their permit review.
The EIS studies three alternatives including current plans and regulations, called the No Action Alternative, and
two Action Alternatives that vary the amount and type of growth and investments in the area.
▪ No Action Alternative: The No Action Alternative is SEPA-required, and development would adhere to the
existing Comprehensive Plan policies, land use designations and zoning districts, while aligning with the
goals of transit-oriented development, community benefits, and quality of life.
▪ Alternative 2: In support of transitioning the subarea (also referred to as “Study Area”) into a mixed-use
pedestrian-oriented district with an active multi-modal center and strong pedestrian connections,
Alternative 2 would allow for moderate growth throughout the Planned Action Area. This growth
alternative would include a mix of commercial towers and mixed-use towers, 5-10 stories in height
predominantly. The greater heights in the range would be concentrated in Renton Village surrounding a
pedestrian-oriented internal main street concept.
▪ Alternative 3: Similar to Alternative 2, Alternative 3 would result in a mixed-use pedestrian-oriented district
with an active multi-modal center and strong pedestrian connections, while allowing for the most growth
throughout the Planned Action Area. Alternative 3 would include a mix of commercial towers and mixed-
use towers, 10-14 stories in height predominantly. Greater heights would be anticipated in Renton Village
Rainier/Grady Junction TOD Subarea Planned Action Fact Sheet
March 2024 ▪ Final EIS
iv
surrounding a pedestrian-oriented internal main street concept as well as other locations near investments
in walkability, transit access, or greenspace.
City staff recommended Alternative 2 be the Preferred Alternative because it would allow development at a
scale envisioned by the Subarea Plan but would offer developers incentives to achieve the scale and intensity of
use offered by Alternative 3. The Planning Commission and City Council’s Planning and Development Committee
recommend Alternative 2 with its incentive-based approach.
Proponent and Lead Agency
City of Renton, Department of Community & Economic Development
Location
The subarea is centered on the intersection of Rainier Avenue S and S Grady Way. A core area (“Planned Action
Area”) lies east of Rainier Avenue between South 3rd Place and I-405 around a planned transit center and
Renton Village Shopping Center, a large retail area within the Planned Action Area. For the purposes of this
document Renton Village includes all properties within the “super-block” situated east of Rainier Avenue S,
south of S Grady Way, west of Talbot Road, and north of I-405. A broader EIS Study Area is considered for
context and general conditions, while the Planned Action Area has more specific proposals for growth,
evaluation, and mitigation measures.
Rainier/Grady Junction TOD Subarea Planned Action Fact Sheet
March 2024 ▪ Final EIS
v
Source: City of Renton, BERK, 2024.
Tentative Date of Implementation
Draft Code and Planned Action: Winter 2024
Final Code and Planned Action: Spring 2024
Responsible SEPA Official
Martin Pastucha, Public Works Administrator
Environmental Review Committee Chair
City of Renton
1055 South Grady Way, 5th Floor
Renton, WA 98057
425-430-7311
Rainier/Grady Junction TOD Subarea Planned Action Fact Sheet
March 2024 ▪ Final EIS
vi
Contact Person
Paul Hintz, Principal Planner
City of Renton
Community and Economic Development, Planning Division
1055 Grady Way, 6th Floor
Renton, WA 98057
phintz@rentonwa.gov | 425-430-7436
Required Approvals
The proposed code amendments and planned action ordinance are legislative proposals. After a 60-day review
coordinated by the Washington State Department of Commerce, and Renton Planning Commission
recommendations, the proposals would be considered for adoption by the Renton City Council.
Principal EIS Authors and Contributors
Under the direction of the City of Renton, the consultant team prepared the EIS as follows:
▪ BERK Consulting: Prime Consultant, Planned Action, Alternatives, Land Use and Typology Modeling, Public
Services
▪ Perteet: Natural Environment, Transportation, Utilities
▪ The Transpo Group: Travel Demand Model
Draft EIS Date of Issuance
January 24, 2024
The City of Renton solicited comments from citizens, agencies, tribes, and all interested parties on the Draft EIS
from January 24 to February 24, 2024. Comments were due by 5:00 PM, February 24, 2024, but to allow for
comments after a public hearing on February 21, 2024, the City voluntarily held the comment period open until
February 28, 2024.
Final EIS Date of Issuance
March 27, 2024
Date of Final Action
Final Code and Planned Action: Spring 2024
Prior Environmental Review
Determination of Non-Significance and SEPA Checklist for the Rainier/Grady Junction TOD Subarea Plan.
▪ SEPA Register: 202106716 – Renton City of (wa.gov)
Rainier/Grady Junction TOD Subarea Planned Action Fact Sheet
March 2024 ▪ Final EIS
vii
Location of Background Data
You may review the City of Renton website for more information at:
▪ Rainier/Grady Planned Action and EIS, Available:
https://www.rentonwa.gov/city_hall/community_and_economic_development/long_range_planning/raini
er__grady_junction_subarea_plan/rainier__grady_planned_action_and_e_i_s
If you desire clarification or have questions, please see the contact person above.
Purchase/Availability of Final EIS
The Final EIS is available for review at City of Renton City Hall: 1055 South Grady Way, 6th Floor, Renton, WA
98057. Thumb drives are available for purchase at cost at City of Renton City Hall. The Final EIS is also available
for review at the Renton public library located at 100 Mill Avenue S, Renton, WA 98057.
▪ The Final EIS is posted on the project website at
https://www.rentonwa.gov/city_hall/community_and_economic_development/long_range_planning/raini
er__grady_junction_subarea_plan/rainier__grady_planned_action_and_e_i_s
ix
Distribution List
The following agencies received a notice of availability of the Final EIS.
Federal and Tribal Agencies
Duwamish Tribe
Muckleshoot Tribe
U.S. Army Corps of Engineers
State and Regional Agencies
Department of Commerce
Department of Ecology
Department of Natural Resources
Department of Transportation
Puget Sound Regional Council
Adjacent Jurisdictions
City of Issaquah
City of Kent
City of Newcastle
City of Tukwila
King County
Services, Utilities, and Transit
Puget Sound Energy
King County Wastewater Treatment Division
Sound Transit
King County Metro
Renton School District
Community Organizations, Stakeholders, and Individuals
Brotherton Cadillac
Renton Technical College
McCullough Hill, PLLC (Triton Towers)
LPC West (Triton Towers)
Rainier/Grady Junction TOD Subarea Planned Action Distribution List
March 2024 ▪ Final EIS
x
Renton Village Associates
Uwajimaya (Renton location)
South Renton Neighborhood Association
Kia Car Pros
Renton Downtown Partnership
Betsy Prather, Renton Historical Society
Kurt Creager, Bridge Housing
Mary Duncan, Elizabeth Gregory Home
Bellwether Housing
Commenters regarding the Draft EIS – See Chapter 2.
Media
The Seattle Times
xi
Contents
1 Summary 1-1
1.1 Introduction and Proposals 1-1
1.2 Study Area 1-1
1.3 Public Comment Opportunities 1-3
1.4 Objectives, Proposal, and Alternatives 1-3
Objectives 1-3
Alternatives 1-3
Key Elements by Alternative 1-12
1.5 Key Issues and Options 1-15
1.6 Summary of Impacts and Mitigation Measures 1-16
Natural Environment 1-16
Land Use 1-19
Transportation 1-27
Public Services 1-36
Utilities 1-41
2 Public Comments & Responses 2-1
2.1 Commenters 2-1
2.2 Comments and Responses 2-2
3 Appendix 3-1
a) Marked Comment Letters 3-1
Rainier/Grady Junction TOD Subarea Planned Action Contents
March 2024 ▪ Final EIS
xii
Exhibits
Exhibit 1-1. Vicinity Map 1-2
Exhibit 1-2. Study Area Zoning Map – No Action Alternative 1-4
Exhibit 1-3. Development Typology Descriptions 1-5
Exhibit 1-4. Development Typologies – Action Alternatives 1-6
Exhibit 1-5. Alternative 2 Modeled Typologies 1-8
Exhibit 1-6. Alternative 3 Modeled Typologies 1-10
Exhibit 1-7. Total Housing by Alternative: Detail 1-11
Exhibit 1-8. Total Employment by Alternative: Detail 1-11
Exhibit 1-9. Modeled Height Comparison 1-12
Exhibit 1-10. Alternative Features Compared 1-13
Exhibit 1-11. Total Housing by Alternative 1-20
Exhibit 1-12. Total Jobs by Alternative 1-21
Exhibit 1-13. Alternative 2 Shadow Analysis, 3PM 1-23
Exhibit 1-14. Alternative 3 Shadow Analysis, 3PM 1-25
Exhibit 1-15. PM Peak Hour Vehicle Trips Generated 1-28
Exhibit 1-16. Anticipated Right-of-Way to be Acquired for RapidRide I Line on S
Grady Way 1-30
Exhibit 1-17. 2044 PM Peak Hour LOS and Delay, With and Without
Mitigations 1-34
Exhibit 1-18. Potential Demand for Police Services, Full Study Area – All
Alternatives 1-37
Exhibit 1-19. Potential Demand for Fire and EMS Services, Full Study Area – All
Alternatives 1-38
Exhibit 1-20. Estimated Additional Student Generation by Grade Level – All
Alternatives 1-38
Exhibit 1-21. Water System: Average Daily Demand (ADD) and Maximum Daily
Demand (MDD) – Alternative 1 1-42
Exhibit 1-22. Wastewater Demand Comparison 1-43
Exhibit 2-1. Draft EIS Commenters 2-1
Exhibit 2-2. Comments and Responses 2-2
1-1
1 Summary
1.1 Introduction and Proposals
The City of Renton desires to create a vibrant commercial and residential district, based on the adopted
Rainier/Grady Junction TOD Subarea Plan (2021), oriented around near-term bus rapid transit (BRT), with
potential for light rail service in the long term. Now the City intends to develop Municipal Code Amendments to
implement the land use vision of the Subarea Plan to increase mixed-use opportunities and alter development
standards including height, density, parking, and others. Additionally, to facilitate the development of the vision,
the City intends to adopt a Planned Action Ordinance to establish environmental performance standards that
each development would meet. Development consistent with the ordinance requirements would not require a
new environmental threshold determination and could rely on the Planned Action EIS to streamline permit
review.
The City is considering three alternatives including the No Action Alternative, Alternative 2 (mid-rise focus), and
Alternative 3 (high rise focus), that vary the amount and type of housing and employment growth and
investments in the area that could occur under the new municipal code amendments. The modeling associated
with each alternative is intended to reveal significant impacts that might be realized with future development,
but the modeling is in no way based on or informed by the financial feasibility developing the land as modeled.
For each alternative, the Final Environmental Impact Statement (Final EIS), compares the environmental impacts
of the alternatives and identifies mitigation measures. Environmental topics include: natural environment, land
use, transportation, public services, and utilities. The Final EIS is organized as follows:
▪ Chapter 1 Summary
▪ Chapter 2 Public Comments and Responses
▪ Chapter 3 Appendix
The Chapter 1 Summary highlights features of the alternatives described fully in Draft EIS Chapter 2, and
associated environmental impacts detailed in Draft EIS Chapter 3. The Final EIS completes the SEPA process,
identifies a Preferred Alternative, and provides responses to comments on the Draft EIS. The Draft EIS and Final
EIS should be considered together.
1.2 Study Area
The Rainier/Grady Junction TOD Subarea serves as the Study Area (“subarea” and “Study Area” are used
interchangeably in this document) and is centered on the intersection of Rainier Avenue S and S Grady Way. A
core “Planned Action Area” (PAA) lies east of Rainier Avenue between South 3rd Place and I-405 around a
planned transit center and “Renton Village” – the name of a commercial center used in this document to
broadly refer to all properties within the “super-block” situated east of Rainier Avenue S, south of S Grady Way,
west of Talbot Road, and north of I-405. See Exhibit 1-1.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-2
Exhibit 1-1. Vicinity Map
Source: City of Renton, BERK, 2024.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-3
1.3 Public Comment Opportunities
The City of Renton received a grant from the Washington State Department of Commerce to promote transit-
oriented development (TOD) with a streamlined SEPA review under a planned action. To initiate the planning
process the City sought comments from the public, agencies, and tribes through a formal SEPA scoping process
including a written comment period and a community meeting per RCW 43.21c.440. The meeting was held
online in August 2022 with six participants. In addition, a comment letter from the Duwamish Tribe was
received. See Appendix 5.1 of the Draft EIS.
The City held a five-week comment opportunity. This Final EIS presents the EIS Summary and responses to
public comments. See the project website for more information about the proposals and public engagement:
https://www.rentonwa.gov/city_hall/community_and_economic_development/long_range_planning/rainier__
grady_junction_subarea_plan/rainier__grady_planned_action_and_e_i_s.
1.4 Objectives, Proposal, and Alternatives
Objectives
The State Environmental Policy Act (SEPA) requires a statement of objectives describing the purpose and need
for the proposals. The Subarea Plan includes the following four goals, which serve as objectives for this EIS:
1. ALIGN WITH OVERALL VISION FOR RENTON: Align with overall vision for Renton’s City Center area
and support the unique role of the subarea in ways that are complementary to Downtown, the
larger City Center area, and Renton as a whole.
2. TRANSITION TO A MULTIMODAL CENTER: Transition the area into a pedestrian-oriented district
with a multi-modal center and strong pedestrian connections.
3. CREATE A LIVABLE NEIGHBORHOOD: Create a livable, distinct neighborhood that is active 18
hours a day, complements Downtown, and gracefully integrates with neighboring areas.
4. CATALYZE DESIRED CHANGES: Leverage the recent and planned public investment in the area for
the private investment to follow.
The objectives also serve as criteria by which the alternatives are evaluated.
Alternatives
Alternative 1 No Action
Alternative 1, the No Action Alternative, is SEPA-required. Under Alternative 1, development would adhere to
the existing Comprehensive Plan policies, land use designations and zoning districts, while aligning with the
adopted Subarea Plan goals of transit-oriented development, community benefits, and quality of life. The
current zoning is shared in Exhibit 1-2.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-4
Exhibit 1-2. Study Area Zoning Map – No Action Alternative
.
Source: City of Renton, 2022.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-5
Action Alternatives
Two Action Alternatives were developed for evaluation in the EIS, and both align with the goals of the Subarea
Plan, described in Section 2.3 Objectives. While both Action Alternatives would meet objectives for an active
pedestrian-oriented district that supports multiple modes of transportation around an active transit hub, each
alternative would vary densities, heights, and growth in the Planned Action Area.
▪ Alternative 2 would set minimum standards and incentives to achieve optimal Subarea Plan
implementation resulting in a predominately mid-rise development pattern with some high-rise
development possible through incentivized standards; and
▪ Alternative 3 would allow high-rise development with required standards and public benefits scaled to the
intensity of the development.
Both Action Alternatives would be implemented under one zoning code but explore two separate growth
concepts to test against the No Action Alternative.
The Action Alternatives consider a range of building typologies that fit the Subarea Plan Growth Concept, and
the proposed Municipal Code amendments, but vary the height, density, and other facets of the potential
mixed-use buildings in the Study Area. See Exhibit 1-3, as well as Exhibit 1-4 for images that are representatives
of the typologies.
Exhibit 1-3. Development Typology Descriptions
Development Type Description
Commercial – Retail Single story commercial uses in a low rise building with at grade parking.
Commercial – Tower Primarily office/commercial uses consisting of towers and mid-rise building up to
ten stories in height. The building envelope could accommodate an office tower or
hotel.
Mixed-Use – Base Mid-rise structures with four to five floors of residential uses over one floor of
commercial use.
Mixed-Use – Maximum Towers with eight to thirteen floors of residential uses over one or two floors of
commercial use.
Source: BERK, 2023.
Notes: Each ground floor commercial retail story is modeled to be 20 ft. tall and 15 ft. tall for second story commercial retail. Each residential
story is modeled to be 10 ft. tall. Each office story is modeled to be 15 ft. tall.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-6
Exhibit 1-4. Development Typologies – Action Alternatives
Commercial –
Retail
Renton, WA
Seattle, WA
Commercial –
Tower
Renton, WA
Seattle, WA
Mixed Use – Mid-
Rise (Base)
Bellevue, WA (5/1)
Seattle, WA (5/2)
Mixed Use – High
Rise (Maximum)
Seattle, WA
Bellevue, WA
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-7
Alternative 2
In support of the Subarea Plan’s objectives and goals to transition the Study Area into a mixed-use pedestrian-
oriented district with an active multi-modal center and strong pedestrian connections, Alternative 2 would
result in moderate growth throughout the Planned Action Area.
This growth alternative is modeled to include a mix of development typologies with most buildings no taller
than 5-10 stories predominantly. The potential to achieve greater heights in the range would be in exchange for
public benefits (e.g., affordable housing, open space, etc.). Greater heights would be anticipated in Renton
Village surrounding a pedestrian-oriented internal main street concept. See Exhibit 1-5.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-8
Exhibit 1-5. Alternative 2 Modeled Typologies
Source: BERK, 2023.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-9
Alternative 3
Consistent with the adopted Subarea Plan, under Alternative 3 high-rise growth and investment in housing,
employment, transit, and parks and open space would support the transformation of the Study Area into a
mixed-use pedestrian-oriented district with an active multi-modal center and strong pedestrian connections.
Alternative 3 is modeled to achieve the most growth throughout the Planned Action Area. Alternative 3 would
include a mix of Commercial Towers and Mixed-Use towers 10-14 stories in height in Renton Village surrounding
a pedestrian-oriented internal main street concept as well as other locations near investments in walkability,
transit access, or greenspace. See Exhibit 1-6.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-10
Exhibit 1-6. Alternative 3 Modeled Typologies
Source: BERK, 2023.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-11
Growth and Height Comparison
In the exhibit below, the three alternatives’ capacity is compared for housing and job growth. Within the
Planned Action Area, the No Action Alternative shows a total net housing capacity of 3,339 units. The
predominant mid-rise approach proposed in Alternative 2 shows a net housing capacity of 5,932 units, and the
predominant high-rise approach proposed in Alternative 3 shows a net housing capacity of 8,688 units. See
Exhibit 1-7.
Exhibit 1-7. Total Housing by Alternative: Detail
No Action Alternative 2 Alternative 3
Planned Action Area 3,339 5,932 8,668
EIS Study Area 3,337 3,337 3,337
Total* 6,676 9,269 12,005
*Totals may vary due to rounding.
Source: BERK, 2023.
Within the Planned Action Area, the No Action Alternative shows a total net jobs capacity of 560 jobs. The
primarily mid-rise approach proposed in Alternative 2 shows a net jobs capacity of 3,663 jobs, and the primarily
high-rise approach proposed in Alternative 3 shows a jobs housing capacity of 6,653 jobs. See Exhibit 1-8.
Exhibit 1-8. Total Employment by Alternative: Detail
No Action Alternative 2 Alternative 3
Planned Action Area 560 3,663 6,653
EIS Study Area 1,353 1,353 1,353
Total* 1,912 5,015 8,006
*Totals may vary due to rounding.
Source: BERK, 2023.
Currently, heights are 70-150 feet under Alternative 1 with reduced heights in the north and central area and
greater heights to the south. Proposed Municipal Code Amendments will allow heights of 70-150 feet across a
greater portion of the Planned Action Area; however, building heights are also subject to Federal Regulation
Title 14 Part 77, which establishes standards and notification requirements for objects affecting navigable
airspace. Modeled heights vary to test the proposed mid-rise and high-rise intensities and densities for purposes
of the EIS. See Exhibit 1-9. Further discussion is found in Draft EIS Section 3.2 Land Use.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-12
Exhibit 1-9. Modeled Height Comparison
Note: Building heights are subject to Federal Regulation Title 14 Part 77, which establishes standards and notification requirements for objects
affecting navigable airspace.
Key Elements by Alternative
The EIS Alternatives would leverage the Subarea Plan but test different assumptions about the intensity of land
use, building heights, residential densities, street requirements, common open space and tree standards, and
other elements of development. Alternative 1 assumes current plans and codes; Alternative 2 would consider
new standards that set base goals but provide incentives to achieve optimal Subarea Plan implementation; and
Alternative 3 would allow maximum heights and densities but require public benefits like the creation of
affordable housing or substantial open spaces to achieve the Subarea Plan vision. Growth would vary depending
on densities and heights. Key elements described by the alternatives above are compared in Exhibit 1-10 and
Exhibit 2-20 of the Draft EIS.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-13
Exhibit 1-10. Alternative Features Compared
Features Alt 1: No Action Alt 2: Mid Rise –
Incentive Zoning
Alt 3: High Rise –
Required Public Benefit
Subarea Goals
and Objectives
▪ Adopted Subarea Plan. ▪ Adopted Subarea Plan
▪ Consider business displacement
mitigation incentives.
▪ Coordination of development
across site boundaries.
▪ Adopted Subarea Plan.
▪ Consider business
displacement policy
considering Subarea Plan and
developed through EIS.
▪ Coordination of development
across site boundaries.
Zoning and
Mixed-Use
Development
Patterns
▪ Mix of CA and CO zoning in
PAA.
▪ Current standards for mixed-
use development in
Commercial Arterial and
Commercial Office Zones:
Equivalent to at least 40% of
building footprint required to
be commercial.
▪ CO Zone restricts residential
uses to no more than 25% of
gross floor area on site.
▪ Structured parking required
for all residential.
▪ CA zoning throughout PAA, with
an overlay zone.
▪ Residential buildings required to
have ground floor commercial
with potential for reduced
ground floor commercial
adjacent to South Renton
neighborhood. Increased
residential density for
affordable housing or
substantial open space
dedication.
▪ Promote a range of commercial
space sizes to encourage diverse
business opportunities and
retention of existing businesses.
▪ Structured parking required for
all residential but prohibited on
ground floor along streets or
active public realms. Consider
incentives for parking
reductions.
▪ CA zoning throughout PAA
with an overlay zone.
▪ Residential buildings required
to have ground floor
commercial with greater
amount of commercial space
along the “Main Street.”
▪ Allow standalone residential if
dedicated as affordable
housing and not abutting
“Main Street.”
▪ Require range of commercial
space sizes for diverse
business opportunities and
retention of existing
businesses.
▪ Structured parking required
for all residential but
prohibited on ground floor
along streets or active public
realms. Consider requirements
for parking reductions.
Height ▪ CA: 50’–70’
▪ CO: 250’ (greatest height
achievable is ~150’ in Planned
Action Area)
▪ Subarea vision: predominantly
70’ with incentives up to 150’.
▪ Base height with incentives for
affordable housing, and open
space.
▪ Building step-backs adjacent to
residential zones.
▪ Graduated heights up to
airport height limits: 70’ -150’
with amenities required.
▪ Building step-backs adjacent to
residential zones.
Density
(dwelling units
per acre
[DU/AC])
Min. and Max.:
▪ CA: 20 – 60 DU/AC
▪ CO: 75 – 150 DU/AC
Min. and Max.:
▪ 60 – 150 DU/AC, up to 250
DU/AC with incentives.
Min. and Max.:
▪ 60 – 250 DU/AC with public
benefits required.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-14
Features Alt 1: No Action Alt 2: Mid Rise –
Incentive Zoning
Alt 3: High Rise –
Required Public Benefit
Affordable
Housing
Density Bonus
▪ CO Zone: 30% above max
density or density allowed via
conditional use permit for
affordable bonus at 1:1 ratio.
▪ Increase max density bonus to
65% for affordable housing.
▪ No bonus. Rely on multifamily
tax exemption, fee reductions,
and inclusionary zoning to
create affordable housing.
Health – Air
Quality
▪ None ▪ Implement a 500’ mitigation buffer from I-405 for residential
development. Require centralized air filtration systems, air intake
vents located away from highways, noise attenuating construction
and materials, and other appropriate mitigation measures.
Open Space,
Landscaping &
Stormwater
▪ Current common open space
and stormwater requirements
▪ Increase and require dedication of public open space via public or
private easement.
▪ Creation of public plaza.
▪ Green factor standards.1
▪ Augment street tree standards.
▪ Increase green infrastructure; integrate into street standards.
Potential
Investments in
Transportation
▪ New Transit Station
▪ Sound Transit Renton HOV
Access Project
▪ Bike/Trail Plan Improvements
▪ Similar to Alternative 1 plus
supportive modal infrastructure
(e.g., multi-use paths, increased
bicycle parking, etc.).
▪ Similar to Alternative 1 plus
supportive modal
infrastructure (e.g., multi-use
paths, increased bicycle
parking, etc.).
Core Area –
New Streets
▪ Subarea Plan provides cross-
sections (pp 55-59).
▪ Implement Subarea Plan Street
Standards, including the
creation of Main Street/festival
shared street with pedestrian-
oriented retail and services.
▪ Require greater amount of
commercial space abutting
“Main Street” or other active
pedestrian realms. Address mid-
block connections.
▪ Implement Subarea Plan Street
Standards including the
creation of Main
Street/festival shared street
with pedestrian-oriented retail
and services.
▪ Wider pedestrian clear zones
to accommodate additional
pedestrian volume.
▪ Address mid-block
connections.
Process ▪ Current permit procedures. ▪ Master Site Plan
▪ Planned Action
▪ Master Site Plan
▪ Planned Action
Source: BERK, 2023.
1See Seattle’s Green Factor Standards
Both Alternatives 2 and 3 in the Planned Action Area will support a mixed-use pedestrian-oriented district with
an active multi-modal center and strong pedestrian connections. Based on the modeling, Alternative 2 would
predominantly include a mix of commercial towers and mixed-use towers, 5-10 stories in height. Alternative 3
anticipates more height compared to Alternative 2, predominantly with a mix of commercial towers and mixed-
use towers, 10-14 stories in height. The modeled building heights in both alternatives are based on the
described building typologies.
For each alternative, the EIS modeled different assumptions about building typologies, unity density and height.
Although modeled differently, Alternative 2 and Alternative 3 have the same development capacity but offer
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different approaches; incentivized standards in exchange for public benefits or maximized standards for
required public benefits. Incentivized standards allow developers to determine if the added cost of providing
income-restricted housing or dedicating large areas for open space makes financial sense.
The Planning Commission and City Council’s Planning and Development Committee selected Alternative 2 for its
incentive-based approach as the Preferred Alternative, which offers the same potential for growth as
Alternative 3.
1.5 Key Issues and Options
The key issues facing decision makers are summarized below.
▪ Approval of municipal code amendments to provide for transit-oriented development including additional
housing and employment opportunities.
▪ Creating a mix of incentives and requirements to encourage affordable housing, green infrastructure, and
other public benefits.
▪ Identifying the desired land use pattern and growth levels to respond to and integrate the BRT Station and
future light rail investments and provide for housing and employment opportunities.
▪ Identifying the mix of infrastructure and transportation investments to ensure added greenspace and
connected multimodal streets.
▪ Considering alternative open space and park investments suited to a transit-oriented urban neighborhood.
▪ Approving Planned Action Ordinance to help incentivize growth while mitigating impacts.
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1.6 Summary of Impacts and Mitigation Measures
Natural Environment
Source: Makers, Rainier/Grady Junction TOD Subarea Plan
How did we analyze Natural Environment?
The project team toured the Study Area and reviewed published maps, studies, literature, and regulations
regarding natural environment conditions including surface water critical areas, species habitat, and cultural
significance.
Thresholds of significance are established to differentiate significant impacts that may require mitigation from
insignificant impacts. Thresholds of significance in this impact analysis include:
▪ Tree canopy impacts are considered significant when the action alternative would cause a net loss in the
City’s overall current tree canopy coverage.
▪ Natural environment impacts are considered significant when the action alternative would cause
degradation of habitats, changes to wetland hydroperiods, or decreased water quality of wetlands and
streams.
▪ Archaeological impacts are considered significant when development would have the potential to alter or
damage archaeological resources.
What impacts did we identify?
Under all alternatives, the project area includes growth in or near critical areas such as seismic hazard areas,
wellhead protection areas, wetlands, streams, and special flood hazard areas for a 100-year flood event. Critical
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areas typically require enhanced protection, such as limited fill material in wellhead protection areas and
buffers/setbacks near streams and wetlands.
Any development or redevelopment requiring excavation poses threats of erosion hazards until construction is
completed and soils on the site have been permanently stabilized. With compliance to The Model Toxics Control
Act (MTCA) and Critical Areas Regulations, the residual impacts would be less than significant for the natural
environment.
The proposed growth in Renton Village is directly on top of an existing creek – Rolling Hills Creek – that has been
piped underground. Stream relocation and/or daylighting (open channel where stream is currently in a culvert)
is an option allowable under the current City code when developers propose building directly above streams
piped underground.
The Study Area has a very high risk of archaeological resources and is located in proximity to known
archaeological sites and indigenous villages and camp sites.
What is different between the alternatives?
Alternative 1: This alternative would continue existing development standards throughout the Planned Action
Area (i.e., no increased requirements or incentives for green space, reduced parking requirements), resulting in
a higher percentage of impervious surface compared to the Action Alternatives. The No Action Alternative
would also lack the support of an areawide EIS and Planned Action Ordinance to expeditiously facilitate
development, which would likely result in a slower pace of redevelopment and therefore perpetuate existing
conditions.
Alternative 2: Alternative 2 would result in increased investments in green spaces and increased landscaping
requirements.
Alternative 3: Green space and enhanced landscaping would be similar to Alternative 2. Alternative 3 also
proposes a Commercial – Tower typology adjacent to the Puget Wetland which would eliminate surface-level
parking on this parcel. The proposed towers could create the potential for shade around the wetland which
could be beneficial in reducing water temperatures. Setbacks are required and measured from the buffers
around the wetlands for any development or redevelopment.
What are some solutions or mitigation for impacts?
Application of federal, state, and local laws would apply to development in proximity to critical areas. City
review applies to projects in critical areas and requires compliance with Renton Municipal Code 4-3-050. Critical
areas protected under these regulations include flood hazard areas, steep slopes, habitat conservation areas,
streams and lakes, wellhead protection areas, and wetlands or sites within 200 feet of a wetland. In all flood
hazard areas, new construction and substantial improvements must be constructed to minimize flood damage.
Federal and state laws apply to the protection of archaeological resources. This includes but is not limited to:
▪ Archaeological Excavation and Removal Permit (WAC 25-48)
▪ Archaeological Sites and Resources (RCW 27.53)
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Other potential mitigation measures include:
▪ Planting appropriate trees and native vegetation to improve the overall environmental quality of the area.
This could include adopting different street tree standards for the Renton Village internal street network,
adding greenery to the south side of 7th street to enhance the proposed non-motorized improvements,
and/or implementing specific landscaping standards for the Study Area. Prioritize planting native species in
the Study Area; this could be accomplished in proposed street tree and landscape code amendments or in
the Planned Action Ordinance. In the broader Study Area, consider whether wetland and tree regulations
encourage use of native plants.
▪ Any additional green spaces that are added to the existing conditions would improve water quality of
natural water features in the area.
▪ Green infrastructure, such as Silva Cells and other best management practices, to support tree growth,
protect sidewalks from root spread, and provide on-site stormwater management. The City could require
an archaeological review in the planned action area, and notification to tribes. The City could consult with
recognized tribal, State, Federal, and other local governments as well as the Duwamish Tribe, which is
seeking federal recognition.
▪ The City currently restricts buildings over piped streams and easements to maintain the piping. Mitigation
opportunities for daylighting Rolling Hills Creek include allowing transfer of residential density/floor area
ratio so the daylighted stream and any natural buffer does not reduce the development potential when the
stream is daylighted. The City could also require daylighting if development would relocate the creek, as
well as incentivize daylighting where increased heights are allowed.
With mitigation, what is the ultimate outcome?
No significant unavoidable adverse impacts are expected for any alternatives if the potential mitigation
measures and City regulations are followed.
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Land Use
Source: Makers, Rainier/Grady Junction TOD Subarea Plan, 2021
How did we analyze Land Use?
The EIS team reviewed the policy and regulatory framework through adopted plans, existing uses, and future
designations and zoning applied by the City of Renton. The team considered the King County Urban Growth
Capacity Report and results for Renton under Alternative 1 – No Action. The EIS team developed typologies for
different types of uses and buildings, and estimated growth in the Study Areas under the Action Alternatives.
Thresholds of significance, used here to define land use impacts that would have adverse effects without
mitigation, include:
▪ Interferes with state, regional, or local plans.
▪ Increases potential for incompatible land use transitions.
▪ Potential to increase households’ exposure to air pollution, noise pollution.
▪ Transitions in scale. Height of development, location of roads, and landscaping abutting surrounding
neighborhoods creating an appropriate transition to areas of greater or lower density.
▪ Shadows on public space. The potential for future development to cast shadows on public open spaces that
could hinder public use and enjoyment of the space.
What impacts did we identify?
Alternative 1 No Action is consistent with VISION 2050 goals and Countywide Planning Policies relevant to the
Subarea, but Action Alternatives would more optimally meet goals for increasing densities and providing
housing, improving environmental conditions (e.g., tree canopy), and supporting transit.
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The Action Alternatives propose alternative land use designations and zones compared to the No Action
Alternative. The Subarea Plan would be integrated into the 2024 Comprehensive Plan Periodic Update.
Alternative 1 No Action generally meets Renton Comprehensive Plan Policies, though Alternatives 2 and 3 more
optimally meet existing policies.
What is different between the alternatives?
Growth: All alternatives will make progress towards meeting the City of Renton’s housing and jobs growth
targets, which at the time of the King County Urban Growth Capacity Report showed a deficit in housing and
jobs through the year 2044. The Action Alternatives will more aggressively meet the growth targets, with
Alternative 3 proposing the greatest addition to both housing and jobs.
Within the Study Area, the No Action Alternative shows a total net housing capacity of 6,676 units. The mid-rise
approach proposed in Alternative 2 shows a net housing capacity of 9,269 units, and the high-rise approach
proposed in Alternative 3 shows a net housing capacity of 12,005 units. Additionally, within the Study Area, the
No Action Alternative shows a total net jobs capacity of 1,912 jobs. Alternative 2 shows a net jobs capacity of
5,015 jobs, and Alternative 3 shows a jobs housing capacity of 8,006 jobs. See Exhibit 1-11 and Exhibit 1-12.
Exhibit 1-11. Total Housing by Alternative
Source: BERK, 2023.
3,339
5,932
8,668
3,337 3,337 3,337
6,676
9,269
12,005
-
2,000
4,000
6,000
8,000
10,000
12,000
14,000
No Action Alternative 2 Alternative 3
Planned Action Area EIS Study Area Total
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Exhibit 1-12. Total Jobs by Alternative
Source: BERK, 2023.
The Washington State Department of Commerce has developed guidance for Comprehensive Plan Housing
Elements updated per HB 1220 that aligns different housing types with the level of affordability they typically
provide.1 Housing that is particularly suited to meeting low-income housing needs include low and mid-rise
housing. Housing at moderate income levels includes middle housing and mid and high-rise housing. All
alternatives increase housing options particularly Alternatives 2 and 3.
Exposure to Air Quality Emissions and Noise: Growth of a mixed-use, multi-modal center in the Study Area will
increase traffic volume, potentially impacting pedestrian safety, noise, and air and light pollution. Additionally,
the placement of taller mixed-use, standalone residential, or commercial buildings could create noise and light
pollution impacts to adjacent low-intensity residential areas north of the Study Area, with Alternative 1 the least
intense and Alternative 3 the most. These impacts can be mitigated by design standards that prescribe features
such as transitional height limits, setbacks, or landscaping.
Air quality within the PAA and surrounding area are impacted by aircraft and roadway traffic due to proximity to
Renton Municipal Airport and major roadways. While the Subarea Plan recommends 350 feet as an acceptable
buffer from highway traffic emissions, the Planned Action explores 500 feet as a uniform standard for indoor
sound and air quality mitigation. Alternative 3 would result in a greater concentration of high-rise mixed-use
typologies adjacent to I-405. As part of the municipal code amendments associated with the Action Alternatives,
the City can address orientation and location of residential uses in mixed use developments to reduce the
potential for localized air quality effects and improve compatibility.
Expected noise levels are on the threshold of acceptable (not exceeding 65 dB) and normally unacceptable
(above 65 dB but not exceeding 75 dB) by HUD’s standards. Across all alternatives, resulting residential
1 See: Guidance for Updating your Housing Element, Book 2, 2023. Available:
https://deptofcommerce.app.box.com/s/1d9d5l7g509r389f0mjpowh8isjpirlh.
560
3,662
6,653
1,353 1,353 1,353
1,912
5,015
8,006
-
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
9,000
No Action Alternative 2 Alternative 3
Planned Action Area EIS Study Area Total
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development would be exposed to noise impacts, varying by location, orientation, design, density, and height
allowance.
Development Scale: The Action Alternatives would implement the Subarea Plan while testing different
assumptions about the intensity of land uses near the new transit center and parking garage, including
variations in building heights, residential densities, street requirements, common open space, and tree
standards.
The No Action Alternative assumes the implementation of current plans and codes. Under this alternative, the
adopted Subarea Plan provides a policy direction for future development within the Study Area without having
the regulatory support to fully implement the Subarea Plan’s vision.
Both Action Alternatives would organize development south of S Grady Way around an east-west Main Street
designed to promote pedestrian scale retail and promote a robust and engaging public realm. Development
fronting Shattuck Avenue S and S 7th Street would have transition standards and accommodate a mix of walk-up
residential buildings and ground floor commercial uses within mixed-use typologies. Renton Village, south of S
Grady Way and east of Rainier Avenue S, would focus on Mixed-Use Base and Maximum, centered around an
interior main commercial street.
Shadows: Alternative 2 would set minimum standards and incentives to achieve optimal Subarea Plan
implementation resulting in a mix of commercial towers and mixed-use towers typically 70- 120 feet in height in
most of the Study Area with a node of 150 feet in Renton Village. The taller buildings would surround a
pedestrian-oriented internal main street concept. Alternative 2 proposes the fullest realization of the Subarea
Plan. The scale and mix of future development fit the ideal heights and uses proposed within the Subarea Plan.
The future proposed open space network south of S Grady Way would be impacted by the proposed building
heights during the afternoon. The proposed Main Street would be impacted by the surrounding building heights
throughout the morning. See Exhibit 1-13.
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Exhibit 1-13. Alternative 2 Shadow Analysis, 3PM
Source: BERK, 2023.
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Alternative 3 would allow high-rise development with required standards and public benefits with a height
range of 70 – 150 feet in height in Renton Village surrounding a pedestrian-oriented internal main street
concept. More areas would develop to the upper range of the heights in Renton Village potentially shading
green spaces. Mid-range heights north of S Grady Way could increase shading of areas to the north along S 7th
Place; design standards such as building setbacks and upper story step backs could reduce the impacts.
Northwestern portions of the Planned Action Area would develop to 70 feet, while areas to the northeast could
develop 130-140 feet high. While the existing conditions may be out of scale, the maximum allowable height
adjacent to the Study Area is 70 feet in the Commercial Arterial zone. If the parcels west of Rainier Avenue S are
built to achieve their full development potential, they would visually support the proposed height ranges under
Alternative 3.
Under Alternative 3, the majority of the internal roadways in Renton Village would be shaded during both the
morning and afternoon. The proposed open space south of S Grady Way would be shaded during the afternoon
but would have access to light during the morning hours. See Exhibit 1-14.
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Exhibit 1-14. Alternative 3 Shadow Analysis, 3PM
Source: BERK, 2023.
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What are some solutions or mitigation for impacts?
▪ Subarea Plan Policies: Subarea Plan policies support appropriate landscaping and green infrastructure
treatments that can address air quality and noise compatibility. The adopted Subarea Plan includes an
expanded buffer recommendation for a natural area on the northern side of I-405 to reduce noise and air
impacts and support environmental functions of Rolling Hills Creek and aid with flood storage. The adopted
Subarea Plan recommends a 350-foot air quality buffer.
▪ Adopted Regulations: Title IV regulations address landscaping, noise compatibility between land uses,
airport height and safety, and others.
▪ Air Quality and Noise Mitigation: The City can reduce exposure to air quality emissions and reduce heat
islands in paved areas through site design and tree canopy plantings. Federal regulations and mitigation
options (e.g., under US HUD) include site design techniques, such as positioning parking garages or berms
closest to a highway to shield a residential area from noise. To mitigate airplane noise, new construction or
renovations can apply acoustical construction policies, such as material selection for improved insulation
and window sizing, location, and thickness. The City could also require a noise evaluation, similar to the
HUD noise assessment through the Planned Action Ordinance.
▪ Daylighting Creek: The unintended effects of burying or covering rivers and streams include an increase in
nutrient contamination, the degradation of ecosystems, and an increase in downstream floods. When
feasible, daylighting restores rivers and streams to their natural courses by removing these human-caused
obstructions; in cases where development is preventing this, daylighting can provide a new path for the
waterway by avoiding immovable obstructions. The City currently restricts buildings over piped streams
and easements to maintain the piping. Mitigation opportunities for daylighting Rolling Hills Creek include
allowing transfer of residential density/floor area ratio so that the daylighted stream and any natural buffer
does not reduce the development potential when the stream is daylighted. The City could also require
daylighting if development would relocate the creek, as well as incentivize daylighting where increased
heights are allowed.
▪ Height Transition Area: Alternatives 2 and 3 identify a height transition area along Shattuck Avenue S and S
7th Street (see Exhibit 1-9) where human-scale design standards would address compatibility of building
scales with abutting lower intensity areas. Site and building design standards could include greater setbacks
and upper-level step backs (e.g., 20 feet setback at ground floor, and similar step backs at one or more
upper floors for adequate light).
With mitigation, what is the ultimate outcome?
The area will experience more growth and activity under studied alternatives and help the City achieve its vision
and growth targets; see the evaluation of Transportation, Public Services, and Utilities for the ways in which
additional growth and activity would be addressed in service standards.
More areas will experience bigger transitions between zoned height limits, particularly over the 20-year period
as development infills. The increased height limits, modernized zoning, and improved development and design
standards would improve the human experience of these subareas. There are no significant unavoidable
adverse impacts to scale transitions.
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Transportation
Source: City of Renton
How did we analyze Transportation?
Current and future access and circulation are evaluated for vehicles, pedestrians, and bicycles with a focus on
connectivity for pedestrians and bicyclists. The EIS team evaluated traffic operations for Alternative 1 and
Alternative 3 as bookends of growth, leveraging a Travel Demand Model that encompasses this Subarea.
The following scenarios will result in a significant impact for Alternative 1 No Action and Alternative 3.
Pedestrians and bicycles have qualitative thresholds of significance throughout this study, focused on
multimodal access and connectivity. Conversely, vehicles have quantitative thresholds of significance based on
intersection operational delay and queue lengths.
This study does not have a threshold of significance for transit. Impacts to overall transportation in the Rainier
Grady subarea are qualitatively considered as improvements to the transit system.
Vehicles
▪ Traffic operations at study intersections on arterials and collectors (excluding Rainier Avenue and Grady
Way) fall below a LOS D (policy T-48 of the City of Renton Comprehensive Plan).
▪ Traffic operations at study intersections on Rainier Avenue and Grady Way fall below a LOS E (policy T-48 of
the City of Renton Comprehensive Plan).
▪ 95th percentile queues of a downstream study intersection extend into an upstream intersection.
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Pedestrians/Bicycles
▪ Crosswalks are spaced at least 750 feet apart.
▪ Pedestrian and bicycle facilities lack at least one continuous feasible route from the transit center to the
north, south, east, and west directions on arterial or collector streets to the extent of the EIS Study Area
boundary.
What impacts did we identify? What is different between the alternatives?
Vehicles
All alternatives would add trips to the road system. Alternative 3 would add more trips than Alternative 1.
Exhibit 1-15 summarizes the anticipated trips to be generated for modeled alternatives.
Exhibit 1-15. PM Peak Hour Vehicle Trips Generated
In Out Total
2022 Existing 357 666 1,023
2044 Alternative 1 1,225 1,536 2,761
2044 Alternative 3 2,863 3,255 6,118
Source: Perteet, Transpo Group, 2023
Similar to existing conditions, the majority of trips are distributed to turning movements heading toward I-405
and SR 167. Within the Planned Action Area, the most commonly used streets are S Grady Way, S 7th Street,
Shattuck Avenue S, and the new primary streets (identified in the Subarea Plan) spanning north-south from S
Grady Way. Outside of the Planned Action Area throughout the EIS Study Area, the most commonly used streets
are SW Grady Way, Rainier Avenue S, and Talbot Road S. In general, traffic volumes are lower during the AM
peak hour than during the PM peak hour.
All alternatives experience northbound SR 167 95th percentile queues that develop from the Rainier Avenue S /
Grady Way intersection that may extend past the I-405 S off ramp. It is important to note that as vehicles merge
with SR 167 northbound traffic from the I-405 southbound off ramp, vehicles have a separate lane that is used
(which eventually turns into the northbound-right turn lane at Rainier Avenue S / S Grady Way) rather than
being forced to merge immediately with traffic on SR 167; however, the off ramp from I-405 N forces vehicles to
immediately merge with SR 167 traffic and vehicles entering the I-405 S on ramp. Vehicles attempting to turn
left onto SW Grady Way have limited distance to cross travel lanes, which is further complicated by the queues
from the Rainier Avenue S / Grady Way intersection. Additional traffic modeling can be performed, specifically
with micro-simulation software, to analyze the impacts further.
Throughout the S Grady Way corridor, the adopted Subarea Plan proposes roadway sections that generally
retain existing roadway configuration but calls for exploring options to add or expand bicycle and pedestrian
facilities and improve multimodal safety at key intersections.
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Alternative 1: Throughout Alternative 1 No Action Synchro modeling, one intersection surpasses the level of
service threshold of significance during the AM peak hour: Talbot Road S / S 7th Street. The overall delay for this
intersection is118.8 seconds during the AM peak hour. The rest of the study intersections meet the level of
service standard and do not surpass the level of service threshold of significance, including the two intersections
that are anticipated to function as the main entrances/egresses for the roadway network within the Renton
Village area.
There are two study intersections that surpass the 95th percentile queue length threshold of significance during
the PM peak hour: S Grady Way / Talbot Road S and Rainier Avenue S / S 7th Street. The southbound approach
at S Grady Way / Talbot Road S develops a 95th percentile queue length that extends into the intersection of
Talbot Road S / S 7th Street, 388-feet long. The northbound approach at Rainier Avenue S / S 7th Street develops
a 95th percentile queue length that extends into the new intersection of Rainier Avenue S / Hardie Avenue SW,
428-feet long.
Rainier Avenue S / S Grady Way shows an increase in delay times during both peak hours from existing
conditions not only due to the change in volume, but also with the removal of all slip lanes (per the adopted
Subarea Plan). S Grady Way / Talbot Road S has a slight decrease in overall delay compared to existing
conditions due to signal optimization.
Alternative 3: Trip distribution under Alternative 3 is similar to Alternative 1 No Action; however, Alterative 3
has more trips entering/exiting the Planned Action Area through the northern region since the alternative has
“Mixed-Use – Maximum” typologies in that area. Specifically, entering trips increase by 5% on southbound
Rainier Avenue S and westbound S 7th Street and decrease by 5% on northbound Talbot Road S and northbound
Rainier Avenue S. Exiting trips increase by 5% on eastbound S 4th St and decrease by 5% on southbound SR 167.
The Alternative 3 Synchro modeling shows results very similar to the Alternative 1 No Action scenario. The
differences across the Study Area intersections for Alternative 3 are: the overall delay for Talbot Road S / S 7th
Street intersection is longer at 160.9 seconds during the AM peak hour and 57.3 seconds during the PM peak
hour with both peak hours now surpassing the threshold of significance, the S Grady Way / Talbot Road S
southbound approach develops a 95th percentile queue length that is longer at 400-feet during the PM peak
hour, and the Rainier Avenue S / S Grady Way intersection level of service is downgraded to an “E” during the
PM peak hour. LOS E at the Rainier Avenue S / S Grady Way intersection is not considered a significant impact.
Rainier Avenue S / S Grady Way also develops a 95th percentile queue during both peak hours that extends into
upstream intersections, surpassing the threshold of significance. With most of the study intersections displaying
queue length changes between the alternatives, the 95th percentile queue lengths at Rainier Avenue S / S 7th
Street to Shattuck Avenue S / S 7th Street during the AM peak hour and to Rainier Avenue S / Hardie Avenue SW
during the PM peak hour are not expected to increase from Alternative 1 No Action to Alternative 3 High Rise –
Required Benefit.
The 95th percentile queues will spill into and past Lake Avenue S / S Grady Way. When this occurs, westbound
vehicles may choose to reroute and turn north on Lake Avenue S instead of waiting in the long queue to access
Rainer Avenue S / S Grady Way.
All study intersections experience a slight increase in delay from Alternative 1 No Action. Although Rainier
Avenue S / S Grady Way downgrades the intersection level of service rating, it only has an increase in
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intersection delay of 4.6 seconds from Alternative 1 No Action to Alternative 3. The intersection that sees the
highest increase in delay is Talbot Road S / S 7th Street. During the AM peak hour, the intersection has a delay
increase of 258.3 seconds and 178.8 seconds during the PM peak hour.
Pedestrians/Bicycles
The implementation of primary, secondary, main, and internal through-block connections in the adopted
Subarea Plan greatly increases access and connectivity in the Planned Action Area. With these improvements,
pedestrians and bicyclists will be able to connect seamlessly throughout Renton Village and with the transit
center.
The conceptual section for S Grady Way requires 23-feet of acquired or dedicated right-of-way on the south
side, and 11- to 23-feet of acquired or dedicated right-of-way on the north side to implement this conceptual
section. However, this section does not reflect the proposed RapidRide I line project. The RapidRide I Line plans
require an additional 11-ft lane to the total width for vehicle travel, which means the section below will require
an additional 11-ft acquisition width or a reduction of landscape and sidewalk area by 11-ft total.
Exhibit 1-16 shows how much right-of-way will be acquired for the RapidRide I Line roadway section on the
north side of S Grady Way per 90% submittal documents provided to the City of Renton, totaling 10,227 SF.
These areas do not include permanent or temporary construction easements.
Exhibit 1-16. Anticipated Right-of-Way to be Acquired for RapidRide I Line on S Grady Way
Property Area (SF) Typical Width (FT)
700 S Grady Way 6,294 11.0
710 S Grady Way 3,658 14.5
800 S Grady Way 275 0.0
Source: Perteet, 2023.
Within the Planned Action Area, the majority of distances between crosswalks at each intersection do not
surpass the threshold of significance of greater than 750 feet apart. The short blocks allow pedestrians/bicyclists
to access both sides of the road and connect to various routes. There are two blocks within the Planned Action
Area that surpass the 750 ft distance between crosswalks: S Grady Way between Rainier Avenue S and Lake
Avenue S, and between Shattuck Avenue S and Talbot Road S. The Grady Way Overpass project is still in the
planning phase, so it is unknown at this time how the overpass may impact pedestrians/bicyclists in order to
cross S Grady Way.
Outside of the Planned Action Area throughout the rest of the EIS Study Area, several blocks surpass the 750-
foot distance between crosswalks, discouraging circulation and access for pedestrians/bicyclists.
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Alternative 1: Most pedestrian/bicyclist activity during peak commuting hours will occur within the relatively
highest density zoning designation of the Planned Action Area, Commercial Office. Pedestrians/bicyclists will
most likely use the primary street paths identified in the adopted Subarea Plan along the outer edge of Renton
Village prior to connecting with the new transit center (or in route to adjacent, connecting paths as stated in
Impacts Common to All Alternatives). The intersections of S Grady Way with Shattuck Avenue S and Lake
Avenue S will observe the most pedestrian/bike usage in this alternative.
Given that there are not high density and high employment rates for the planned zoning designations for this
alternative, it is not anticipated that there will be a shift toward more pedestrian activity outside of the Planned
Action Area.
Alternative 3: With high-rise typologies, high usage of the sidewalk and bike facilities is anticipated with an
increase of 5,539 housing units and 6,093 jobs compared to Alternative 1 No Action in the Planned Action Area.
Pedestrians/bicyclists will have more opportunities for access and circulation within the Planned Action Area in
Alternative 3 due to the implementation of mid-block crossings adjacent to proposed bus stops. Access and
circulation are further improved through all-way crossings at intersections within Renton Village, specifically at
crossings with primary, secondary, and main streets.
Transit
All alternatives incorporate the operations of the new transit center and new 700-stall garage. I-405, SR-167,
Rainier Avenue S, SW Sunset Blvd, and SW 16th Street all become transit corridors. Several projects will revise
signal detection to prioritize transit upon approaching an intersection.
Bus Access Transit (BAT) lanes will help transit more efficiently move through traffic and provide better access
to businesses and will be installed on Rainier Avenue S north of S 3rd St (Rainier Avenue S Phase 4 project) and
on S Grady Way from Rainier Avenue S to Talbot Road S (S Grady Way Overpass project).
All alternatives will also experience the same anticipated transit route connections anticipated for the I-405 Bus
Rapid Transit. By 2044, connections will be provided to Sound Transit route 566, King County RapidRide F Line,
RapidRide I Line and Metro routes 101, 102, 106, 143, 169, 240, 907, 2022, 2614, 3162, 3218, and 3221.
Alternative 1: Under Alternative 1 No Action, the intersections of S Grady Way with Shattuck Avenue S and Lake
Avenue S are anticipated to experience the largest volume of pedestrians/bicyclists in the Planned Action Area.
Adding on transit and vehicles traveling to and from the transit center to these two heavily used intersections,
queue lengths and delay times will continue to increase. The LOS D operations at Rainier Avenue S / S 7th Street
will impact King County RapidRide F Line, Metro routes 102, 153, 160, 167, and Sound Transit routes 560 and
566. The LOS D operations at Rainier Avenue S / S Grady Way will impact King County Metro route 153 and
Sound Transit 560 and 566. The LOS D operations at S Grady Way / Talbot Road S may impact King County
RapidRide I Line and King County Metro routes 101, 102, 148, 153, and 160.
Alternative 3: Similar to Alternative 1 No Action, Alternative 3 will also likely experience impacts from the new
transit center and new 700-stall garage. However, the intersections of S Grady Way with Shattuck Avenue S and
Lake Avenue S will continue to have heightened queue lengths and delay times. The LOS E operations at Rainier
Avenue S / S Grady Way will likely impact transit routes the most of all studied intersections. Routes impacted
include King County Metro route 153 and Sound Transit routes 560 and 566.
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What are some solutions or mitigation for impacts?
Programs and Planned Capital Investments
▪ Transportation Demand Management (TDM) measures would reduce trips, disperse peak period travel
demand throughout the day, and increase transit usage and ride sharing in place of constructing new or
widening existing facilities.
▪ Intelligent Transportation Systems (ITS) can apply technological solutions to problems such as congestion,
safety, and mobility.
▪ Capital projects designed to address the needs of multiple modes are identified in the existing
Comprehensive Plan, 2022-2027 Transportation Improvement Plan, and the Trails and Bicycle Master Plan.
▪ Recommendations from the Subarea Plan for transportation address roadways, needs of pedestrians and
bicyclists including connectivity to transit, and considerations for future light rail in the area.
Renton Municipal Code encompasses the transportation ordinances for the City of Renton:
▪ Chapter 4-6-060 provides street standards to ensure reasonable and safe access to public and private
properties.
▪ Chapter 4-6-070 ensures Renton transportation level of service standards are achieved concurrently with
development.
▪ Chapter 13 establishes plans and goals for Commute Trip Reduction.
Renton’s Public Works department also has standard details for construction.
Other Potential Mitigation Measures
Other potential mitigation measures include the following by mode.
Vehicles
▪ Implement change from the stop-control at the intersection of Talbot Road S and S 7th Street to a
roundabout. See further discussion in Draft EIS Section 3.3 Transportation.
▪ Implement change from the linked signal timing at the intersection of S Grady Way and Talbot Road S with
adjacent signals to unlinked signal timing with adjacent signals.
▪ Study and implement intersection improvements to address long queues for the northbound-through
movement at the intersection of Rainier Avenue S and S 7th Street.
One potential solution to consider is an additional northbound-through lane to provide additional
queueing space between this intersection and the new Rainier Avenue S / Hardie Avenue SW
intersection.
Another potential solution to consider is converting the bus-only lane to bus and carpool to help
alleviate congestion and queues leading up to the intersection of Rainier Avenue S and S 7th Street.
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▪ Study and implement intersection improvements to address long queues for the westbound-right
movement at the intersection of Rainier Avenue S and S Grady Way. During the implementation of the
Grady Way Overpass, one potential consideration during design is to separate the at-grade westbound-
through and westbound-right movements to provide additional queuing space between this intersection
and S Grady Way / Lake Avenue S.
▪ Prioritize “Access to Transit” project if funding is provided. This project is not listed in Affected Environment
section due to the funding pending. Features of “Access to Transit” may analyze the impacts of the 95th
percentile queues at the Rainier Avenue S / S Grady Way intersection that may extend past the I-405 off
ramp.
The intersections surpassing significance thresholds no longer do so with mitigations applied. See Exhibit 1-17.
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Exhibit 1-17. 2044 PM Peak Hour LOS and Delay, With and Without Mitigations
Alternative 3
Overall Delay (sec) /
Intersection LOS
95th Percentile Queue (ft) <
Distance to Intersection (ft)
Intersection Traffic Control No Mitigation
With
Intersection
Improvements
No Mitigation
With
Intersection
Improvements
2044 AM Peak Hour
Rainier Avenue S / S Grady
Way Signal 60.2 / E 55.2 / E 960 > 770** 670 < 770**
S Grady Way / Talbot Road S Signal 35.0 / C 25.7 / C 105 < 310 70 < 310
Talbot Road S / S 7th Street Stop Control* 160.9 / F 0.0 / A n/a n/a
Shattuck Avenue S / S 7th
Street Signal 17.1 / B n/a n/a n/a
Shattuck Avenue S / S Grady
Way Signal 30.0 / C n/a n/a n/a
1Rainier Avenue S / S 7th
Street Signal 45.8 / D 41.7 / D 415 ≤ 415 165 < 415
2044 PM Peak Hour
Rainier Avenue S / S Grady
Way Signal 58.0 / E 54.0 / D 775 > 770** 503 < 770**
S Grady Way / Talbot Road S Signal 44.4 / D 28.1 / C 400 > 310** 258 < 310**
Talbot Road S / S 7th Street Stop Control* 57.3 / F 3.6 / A n/a n/a
Shattuck Avenue S / S 7th
Street Signal 15.4 / B n/a n/a n/a
Shattuck Avenue S / S Grady
Way Signal 31.3 / C n/a n/a n/a
1Rainier Avenue S / S 7th
Street Signal 50.3 / D 44.4 / D 428 > 415** 173 < 415**
Source: Perteet, 2023.
Notes: *Traffic control is three-way stop controlled. Synchro modeling software does not support this type of stop-control. Modeled in Synchro
as two-way stop controlled at the eastbound and westbound approaches, and yield controlled at the southbound approach.**95th percentile
queue length analyzed only at the intersection approach that surpasses the threshold of significance. n/a = No intersection improvements.
1Modeled with additional northbound-through lane.
2Modeled with bus-only lane changed to bus and carpool lane.
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Policy MT-2 Evaluation
Analysis called for in MT-2 from the Subarea Plan emphasizes that the new grid of complete streets should
prioritize the high-growth Renton Village area, serving to connect with Talbot Road S and S Grady Way, with an
east-west street that can be used to access into the core of Renton Village area. The EIS evaluates the area, with
the following limitations on that analysis:
▪ Without traffic counts for the intersections of S Grady Way / Lake Avenue S and Talbot Road S / S Renton
Village Pl, volumes were assumed from balancing between adjacent intersections that have been studied
for Alternative 1 and Alternative 3. Similar turn-movement ratios from the City’s travel demand model for
Alternative 1 and Alternative 3 were also applied to each intersection turn-movement. Collecting traffic
counts at S Grady Way / Lake Avenue S and Talbot Road S / S Renton Village Pl may result in slightly
different delay and queueing results than what is presented in the EIS. In particular, S Renton Village Place
and Talbot Road S should have traffic counts obtained and be re-analyzed when development begins to
occur.
Transit
The transit network will continue to be impacted by intersection delays, especially routes that pass-through
Rainier Avenue S / S Grady Way, S Grady Way / Talbot Road S, and Rainier Avenue S / S 7th Street. The
installation and usage of Transit Signal Priority (TSP) and Business Access and Transit (BAT) lanes should
promote transit efficiency and circulation surrounding the transit center. “Access to Transit” may perform
additional studies for more TSP and BAT lane implementation as connections are established between the Bus
Rapid Transit (BRT) and existing Sound Transit and Metro routes.
The City could consider adding a Planned Action mitigation measure that all construction and other work activity
affecting King County Metro Transit Operations or Facilities must be coordinated through the KCM System
Impacts workgroup.
Pedestrians/Bicyclists
▪ Consider modifying the main street sections proposed for use by the Subarea Plan for Renton Village from
shared bicycle lanes connecting to shared-use paths for pedestrians and bicyclists.
▪ The top priority from Subarea Plan Recommendation MT-7 should be studying options for safe pedestrian
crossings across S Grady Way at intersections with Shattuck Avenue S and Lake Avenue S, as well as
between Rainier Avenue S and Lake Avenue S. These studies will include cost estimating so the City can
identify funding needs and mechanisms to establish this key connection between Renton Village and the
transit center. An option to be considered is a pedestrian/bicycle bridge over S Grady Way.
▪ Avoid major right-of-way dedication that could hinder development by implementing a roadway section on
S Grady Way that varies from the proposed conceptual section in the Subarea Plan. The south side of S
Grady Way should provide an 8-ft minimum landscape strip to buffer pedestrians from vehicle traffic with
an 8-ft minimum sidewalk behind. This would only require an additional 8-ft of right-of-way acquisition,
instead of 34-ft to match the conceptual section from subarea plan. The north side of S Grady Way should
match what is provided for in the RapidRide I line plans with a typical shared-use path width of 12-ft and a
minimum shared-use path width of 8-ft only on the block between Lake Avenue S and Shattuck Avenue S.
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Intersection Improvements at S Grady Way
The adopted Subarea Plan discusses several high priority intersection improvements at S Grady Way for
pedestrian/bicycle circulation and safety; however, many recommendations of the specific improvements
require additional studies and were not detailed out within the plan. In order to fulfill the pedestrian/bicycle
circulation and safety needs on S Grady Way, a pedestrian/bicycle bridge over S Grady Way between Rainier
Avenue S and Lake Avenue S could be installed. The location of this bridge will allow for pedestrians/bicyclists to
seamlessly access the new transit center without intermixing with vehicle traffic, as well as reduce the distance
to the nearest crosswalk below the 750-foot threshold of significance. This would need to be coordinated with
the Grady Way overpass project which will also be elevating two lanes along S Grady Way in this same area.
Because the Grady Way Overpass project will reduce the surface-level lanes to one lane in each direction, there
is the possibility that other crossing treatments, such as a signalized crossing underneath the planned overpass,
could be a viable option. Ultimately, the City should investigate at least these two options and how they would
interface with the Grady Way Overpass project to determine what type of pedestrian crossing is feasible at this
location.
With mitigation, what is the ultimate outcome?
Vehicle and pedestrian/bicycle significant impacts are anticipated to be mitigated through a combination of
incorporated plan features, City of Renton regulations, and other potential mitigation measures as discussed in
the previous section. Therefore, there are no anticipated significant unavoidable adverse impacts to
transportation.
Public Services
City of Renton, Burnett Linear Park
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How did we analyze Public Services?
The EIS team reviewed studies and plans regarding police services, fire and emergency medical services,
schools, and parks and recreation. The primary providers of these services in the Study Area are the Renton
Police Department, the Renton Regional Fire Authority (RRFA), and the Renton School District. Following a
description of current services in the Study Area and level of service (LOS) standards, an impact analysis is
presented for each alternative.
Impacts of the alternatives on public service are considered significant if they:
▪ Negatively affect the response times for police and/or fire and emergency medical services.
▪ Result in increases in students and lack of facilities unanticipated in district plans or that would reduce
adopted levels of service.
▪ Increase in demand for acres of parkland and miles of trail that cause a decline in the levels of service
beyond planned capacity.
What impacts did we identify?
Police Services
All studied alternatives are anticipated to increase housing and employment within the subarea. Given that the
LOS criteria are based on or affected by population growth, all studied alternatives would create an increased
demand for police, fire and emergency services, schools, and parks.
What is different between the alternatives?
Police Services
With the increased number of commissioned officers needed to support the population demand, it will also
result in increased police equipment and facility needs. See Exhibit 1-18. Additional growth may also increase
traffic volumes, which might increase the response time to priority calls. Regular planning by the Department is
anticipated to address incrementally increased demand for police services.
Exhibit 1-18. Potential Demand for Police Services, Full Study Area – All Alternatives
Officers Per 1,000 Pop1. Alternative 1 No Action Alternative 2 Alternative 3
New Population Capacity 17,491 24,285 31,453
Additional Officers Needed 21.0 29.1 37.7
Note: 12022: Commissioned Officers per 1,000: 1.2
Source: BERK, 2023.
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Fire and Emergency Medical Services
The subarea is served by Station 11, which is the second most active station and sees 20% of the responses in
the Fire District. The increased population growth in all three alternatives is expected to lead to an increased
number of calls for emergency services. As the population grows incrementally, the RRFA would need to
maintain response times consistent with or better than current performance levels. Additional staffing, fire
equipment, and facilities may be required to maintain performance levels with the population growth. See
Exhibit 1-19. The incremental growth will allow time for RRFA and Station 11 to address future staffing,
equipment, and facility needs in the Study Area through planned improvements.
Regarding equipment, the existing ladder truck at Station 11 is equipped to provide services to buildings of
heights proposed under all alternatives. Additionally, new buildings would be required to have sprinklers to
meet the Fire Code. Limited impacts to fire services are anticipated under all alternatives.
Exhibit 1-19. Potential Demand for Fire and EMS Services, Full Study Area – All Alternatives
Personnel Per 1,000 Pop1. Alternative 1 No Action Alternative 2 Alternative 3
New Population Capacity 17,491 24,285 31,453
Additional Personnel Needed 24.5 34.0 44.0
Note: 12020: Personnel per 1,000: 1.4
Source: BERK, 2023
Schools
Renton School District’s enrollment currently outpaces permanent capacity at the elementary and high school
grade levels despite added capacity from the new Sartori Elementary School. Each alternative would generate
new students in housing units, with all new residential growth assumed to be multifamily.
Estimated additional demand based on Renton School District’s multifamily student generation rate at each
school level and estimated dwelling units for each alternative is shown in Exhibit 1-20. There would be a
corresponding need for teaching units (classrooms).
Exhibit 1-20. Estimated Additional Student Generation by Grade Level – All Alternatives
School Level Student Generation
Factors – Multifamily
(>1 bedroom)
Alternative 1 No
Action
Alternative 2 Alternative 3
Elementary School 0.14 915 1,270 1,645
Middle School 0.04 280 389 504
High School 0.06 401 556 720
Total 0.24 1,596 2,215 2,869
Source: Renton School District Capital Facilities Plan, 2022; BERK, 2023
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As the District has exhausted permanent capacity, additional facilities would be needed to accommodate
student growth and the associated teaching stations at all grade levels under all alternatives. However, the
associated growth in student population is expected to occur incrementally as individual development projects
are constructed. This would allow time for the Renton School District to address future facility and staffing
needs through its Capital Facilities Plan.
Parks and Recreation
With each alternative resulting in increased residential and total population, additional park land will be needed
to maintain the current level of service of 5.07 acres of developed parks per 1,000 residents, and 6.14 acres of
natural areas per 1,000 residents. Alternative 3 needs the most additional park acreage.
Given the anticipated incremental population growth of the three alternatives, the City would need to add
approximately 125 – 283 additional acres of park land, which is 25 to 55 percent of the total acreage of the
Study Area. The Study Area’s total acreage is 510 acres, but that includes the high voltage power line corridors,
interchanges, and other rights-of-way. However, LOS standards are determined based on resident population
citywide; additional acres of park land could be added outside the Study Area to meet the population demand.
The Study Area also currently lacks a strong existing trail network and meaningful connection to nearby trails. In
addition, the trail level of service quantity standard is increasing from 0.29 miles of trail per 1,000 residents in
2018 to 0.95 miles per 1,000 residents by 2035. With each alternative, additional trail miles and connections will
need to be considered to maintain the current and future level of service.
Given the anticipated incremental population growth, the City would need to add approximately 16 – 30
additional miles of trails. However, LOS standards are determined based on resident population citywide, so the
additional miles of trail demanded can be added beyond the Study Area.
What are some solutions or mitigation for impacts?
The City of Renton addresses public service levels in its Capital Facilities Plan Element of the Comprehensive
Plan. The element is updated periodically to ensure that proposed growth and change can be served.
Renton Municipal Code allows for the collection of impact fees to address increased demand generated by new
development. Charging impact fees will provide funding needed to provide emergency services, expand the park
system, build new recreational facilities, and construct new school facilities as needed.
Police
▪ The City could consider the hiring of additional police officers and police department staff to maintain
levels of service consistent with growth. This would be considered with the Comprehensive Plan, Capital
Facility Plan, and regular budget adjustments.
▪ To reduce the increased need for police response to that area, the City could require new developments in
the Study Area to provide on-site security services to reduce calls for service. This reduction is largely
dependent on the nature of the incident.
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▪ The City could adopt specific Crime Prevention Through Environmental Design (CPTED) principles to provide
tips to residents, businesses, and developers on how to create designs in landscaping, access, and buildings
to promote natural surveillance.
Fire / EMS
▪ As development occurs, the Fire Authority could reassess future operations plans to ensure that staff and
equipment are located close enough to areas of concentrated development to maintain adequate response
times according to the Fire Authority’s Annual Report. This may entail redistribution of staff or equipment
between fire stations or construction of new facilities.
▪ The City could require a mitigation agreement at the time a development application is submitted to
address additional staffing needs and needed capital investments at stations serving the Study Area (e.g.,
stations, ladder trucks, or other).
▪ The City could condition Planned Action proposals during development review to develop protocols for fire
aid and emergency medical services in conjunction with the RRFA.
Schools
▪ Renton School District tracks information on growth in enrollment and demand for educational program
offerings across all grade spans in the region, including the Study Area, to determine if and when additional
personnel or facilities are needed. The City will periodically review trends and information from the Renton
School District to ensure school impact fees are sufficient to address the District’s needs, including grade
configuration, optimum facility size, educational program offerings, classroom utilization, scheduling
requirements, and the use of temporary classroom facilities.
Parks and Recreational Facilities
▪ LOS standards are determined based on resident population citywide. Given the acreage of the Study Area
and the anticipated number of future residents, the current parks LOS standard of 5.07 acres per 1,000
people cannot practically be achieved within the Study Area. Additionally, the Study Area will also have
non-residential users generating demand for parks and recreation. The City could consider the anticipated
impacts of new visitors, residents, and employees working in the Study Area to determine what additional
or future amenities and improvements are needed.
▪ The City could adopt an urban park LOS category in an upcoming PROS Plan update to encourage dedicated
park and open space while addressing specific needs and uses. This could address the idea of adding
capacity through a combination of new power line parks/trails and improvements at existing parks (e.g.,
Burnett Linear Park) to address increased demand.
▪ The City could encourage and promote dedicated public space through public/private partnerships where
possible.
▪ The City could ensure the Trails and Bicycle Master Plan is implemented along key rights-of-way.
▪ The City could adapt its onsite open space standards for mixed use and residential development to address
development-specific recreation needs.
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With mitigation, what is the ultimate outcome?
Future population and employment growth will increase the demand for public services including police, fire,
schools, and parks. This growth would occur incrementally over the 20-year planning period and would be
addressed in regular capital planning. Each service provider in conjunction with the City could evaluate levels of
service and funding sources to balance with expected growth; if funding falls short, there may need to be an
adjustment to levels of service or growth as part of regular planning under the Growth Management Act. With
implementation of mitigation measures and regular periodic review of plans, significant unavoidable adverse
impacts to public services are not anticipated.
Utilities
Source: Makers, Rainier/Grady Junction TOD Subarea Plan
How did we analyze Utilities?
The EIS team reviewed current utility plans, levels of service, and subarea conditions, and evaluated utility
implications of each alternative regarding stormwater, water, and wastewater. Wastewater modeling was
conducted for the bookend Alternative 1 No Action and Action Alternative 3.
Thresholds of significance utilized in this impact analysis include:
▪ Projected growth demand exceeds planned capacity of utility.
▪ Decreases in adopted levels of service.
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What impacts did we identify?
The subarea would experience growth under all alternatives, increasing demand on water and wastewater
utilities. Impacts to the existing stormwater system are expected to be insignificant. Critical areas within the
Study Area will remain undeveloped under all alternatives.
What is different between the alternatives?
Stormwater: Both residential and commercial populations in the Study Area will increase in each of the
alternatives. Increase in traffic due to development in the area will result in increases in traffic related pollutants
entering the stormwater system, but this increase is projected to be minor compared to background levels.
Excluding the critical areas that will remain undeveloped, the Study Area is nearly 100% comprised of
impervious surfaces, so the potential for additional impervious surfaces in this highly developed area is
significantly lower than in less developed areas. Under all alternatives, the impervious surface area is expected
to either remain the same or decrease.
Water Distribution: Under all alternatives, demand for domestic water and for fire protection service will
increase. See Exhibit 1-21. Each alternative requires fire flow requirements to be met. The portion of the
subarea east of Rainier Avenue S, including Renton Village, has mostly 8-inch and smaller water mains that will
need to be upsized, replaced, and/or relocated to meet the required fire flow demand for future development
and redevelopment projects. Additional water main improvements, including looping of water mains around
proposed development/redevelopment (e.g., if fire flow demand exceeds 2,500 gallons per minute), extensions
of water mains in existing and new roadways fronting properties to be developed or redeveloped, and the
installation of additional hydrants and fire sprinkler systems, would be required to meet fire code and city
development regulations.
Exhibit 1-21. Water System: Average Daily Demand (ADD) and Maximum Daily Demand (MDD) – Alternative 1
Existing City Demand
(mgd)
Additional Demand
(mgd)
Combined Demand
(mgd)
City Capacity
(mgd)
ADD 7.39 0.9 8.29 9.43
MDD 13.59 1.1 14.69 21.82
Source: City of Renton, Perteet, 2023.
Wastewater System: Under all alternatives, wastewater demand or average dry weather flow (ADWF) from
both residential and commercial development would increase. See Exhibit 1-22.
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Exhibit 1-22. Wastewater Demand Comparison
Alternative Additional ADWF in Study Area
(mgd)
Total ADWF
(mgd)
Peak ADWF with Factor
of 2
(mgd)
Alternative 1 0.6 0.7 1.4
Alternative 3 2.4 2.5 4.9
Calculations assume an average household size of 2.62 people, based on the American Community Survey 5-year estimate (2017-2021).
Assumptions of water use include 100 gallons of flow per day (gpd) per person, and 20 gpd per employee per day (Renton Long-Range
Wastewater Management Plan assumptions).
Source: Perteet 2023.
According to the 2015 City of Renton Comprehensive Plan (Amended in 2018), demand on the sewer system is
projected to exceed its capacity as the city nears “ultimate build-out” in 2030 (City of Renton, 2018).
In July of 2023, the City modeled the wastewater system to provide a baseline for the existing conditions and
determine the system’s capacity. The City’s modeling efforts have identified the same deficient areas within the
Renton Village area as those provided in the Long-Range Management Plan including infiltration/inflow (I/I)
issues contributing to existing deficiencies requiring upsizing to 30-inch pipe in the Renton Village area if I/I is
not addressed upstream of Renton Village even without growth. Addressing I/I would reduce the necessary pipe
size, but sewer system upsizing will be needed even with the reduction of I/I. These deficient areas will need to
be addressed under all alternatives. Note that Alternative 2 was not run in the City’s hydraulic model,
Alternative 3 was used for system capacity analysis as a bookend.
What are some solutions or mitigation for impacts?
State and local laws address water quality and compliance with City stormwater, water system, and wastewater
system standards.
Stormwater System
The City’s Surface Water Utility System Plan mentions Rainier Pump Station upgrades on Rainier Avenue S to
address flooding at the low elevation on Rainier Avenue S at the BNSF railroad underpass and Talbot Road
Culvert Improvements on Talbot Road between Grady Way and I-405 to replace a 48-inch culvert that is
deficient due to its age and condition. The Talbot Road project is identified by the City as a priority two project
meaning it could be funded after all priority one projects are addressed.
All development and redevelopment are required to comply with Department of Ecology’s Green River
Watershed Temperature Total Maximum Daily Load (TMDL) standards. According to 2011 Green River
Watershed Temperature TMDL, the plan to reduce temperature in this watershed includes encouraging Low
Impact Development (LID) and restoring riparian vegetation.
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Alternative 2 and Alternative 3 both propose increased green space, required dedication of public open/green
space (public or private with easements), creation of public plaza, green factor standards2, and a modification of
street tree standards. These features would bring both qualitative and quantitative benefits to stormwater.
In the highly developed Study Area, the stormwater in this area is already being collected and conveyed within
the system. Due to the reduction of overall impervious area under Alternatives 2 and 3, the projected growth is
unlikely to produce higher stormwater runoff volumes but will likely increase the pollutants entering the system
as the population and employment levels rise. One option for reducing pollutants would be to use LID
techniques that are intended to treat and infiltrate portions of runoff to reduce pollution in the system.
The City could require enhancement of native growth protection areas within the Rolling Hills Creek stream
buffer to encourage use of native and riparian vegetation (RMC 4-3-050). Encouraging native and riparian
vegetation provides thermal cover and shields Rolling Hills Creek from extreme temperatures, reduces the
amount of algae in the creek allowing for the waters to hold more dissolved oxygen, and also supports the
request of the Duwamish tribe for more native vegetation within the subarea.
A portion of Rolling Hills Creek is currently piped underneath development. It should be noted that daylighting
the creek or portions of the creek would allow for an increased impervious surface lot coverage per RMC
4-3-050 section 7f-ii. This is a viable option to improve existing conditions as well as benefit the developer. The
City code allows for, but does not specify, incentives for developers to daylight streams. The City should
consider implementing specific incentives to encourage developers to daylight portions of Rolling Hills Creek to
restore more natural habitat to the area.
When new street networks are formalized, regulatory stormwater standards will be required, and the
development applications will receive a formalized review to verify required stormwater systems. The City could
also consider encouraging detention facilities or bio-swales that allow for open space.
Under all alternatives, a downstream analysis and hydraulic model analysis for the stormwater system should be
conducted to verify the system’s capacity is efficient for the level of growth expected.
Water Distribution System
The City is planning to construct additional storage facilities for the water distribution system, including a 6.3
MG reservoir in the Highlands in 2026-2028 to accommodate the city’s growth and associated water demand
(2021 Water System Plan, 2022-2028 Capital Improvement Program).
When development or redevelopment is proposed, developers are required to submit information about the
proposed development for the city and for Renton Regional Fire Authority to determine water demand for
domestic use and fire protection. Developers must submit basic information such as the location and size of the
buildings, number of dwelling units, proposed type of building construction materials, and occupancy. RRFA will
determine the fire flow demand for the development based on the submitted information. The City Water
Utility will verify through the use hydraulic model of the water system to determine if the existing water
distribution system in the vicinity of the development is adequately sized to provide the fire flow demand, or if
2 See Seattle’s Green Factor Standards
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-45
additional water main extensions, and upsizing of existing water mains are required to provide the fire flow
demand.
To accommodate additional water demand for domestic use and for fire protection resulting from the
implementation of the selected land use Alternative, the following water system improvements are
recommended:
▪ Developers will be required to install new water mains, including replacement and upsizing of existing
mains, to meet the required fire flow demand for future development and redevelopment projects within
the portion of the subarea east of Rainier Avenue S, including Renton Village. Additional water main
improvements, including looping of water mains around proposed development/redevelopment and the
installation of additional hydrants and fire sprinkler systems would be required to meet fire codes. Water
line extensions for domestic water uses and to meet fire flow demands for development and
redevelopment projects in the City shall be constructed by developers’ projects.
▪ To reduce summertime peak water demand, the City could adopt Landscape Water Budgeting
requirements that would be applicable to the irrigation of landscape areas created by new or
redevelopment projects. Landscapes will be required to comply with the Landscape Water Budgeting
Requirements when they are adopted by the City.
Wastewater System
To accommodate additional wastewater flows resulting from the implementation of the Alternative 2 or
Alternative 3, the following wastewater system improvements are recommended:
▪ Deficiencies 7A, located southeast of the I-405 and SR 167 intersection with a small portion overlapping the
south side of the Planned Action Area boundary, and 45A, located on the south side of the Planned Action
Area overlapping the Renton Village area, both have high Infiltration and Inflow (I/I) at upstream mini-
basins and are recommended for micro-monitoring (City of Renton, 2022). These specific locations are
depicted in Draft EIS Appendix 5.4.
▪ Deficiency 14A is located on West Sunset Blvd and SW 4th Place (Manhole MH6332), as depicted in Draft EIS
Appendix 5.4. It is recommended that this location be monitored for a duration of 3-7 years as part of the
Long-Term Flow Monitoring.
▪ The City should upsize Renton’s wastewater pipes when replaced due to development to eliminate
surcharging in the system.
▪ The City should continue to coordinate with King County regarding the King County interceptor which
surcharges 400-500 yards into Renton’s system during King County’s peak flows. The City should consider
applying for grants, or funding projects upfront using a Local Improvement District (LID) or Special
Assessment District (SAD), to make sewer readily available to encourage development.
▪ The City should continue upgrading sewer services to match adopted land use densities where
transportation projects are already planned.
▪ The City should maintain the hydraulic model analysis for the wastewater system.
▪ Specific potential projects to upgrade the system to address future growth proposed in Alternative 3 (based
on the City’s hydraulic model analysis of the Planned Action Area) are upgrading 1,175 LF to 12-inch pipe,
153 LF to 18-inch pipe, and 2,221 LF to 36-inch pipe. See Appendix 5.4 of the Draft EIS.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary
March 2024 ▪ Final EIS
1-46
▪ King County Wastewater Treatment Division (WTD) requires that City of Renton submit construction
drawings for proposed project identified as a result of the EIS that lie within 500-feet of the WTD facilities
and sewers, so that WTD can assess its potential impacts. King County has permanent easements for
facilities and sewers in the EIS study area, and must be assured the right to maintain and repair the facilities
and sewers.
With mitigation, what is the ultimate outcome?
No significant unavoidable adverse impacts are expected for any alternatives if the potential mitigation
measures and City regulations are followed.
Through an overall reduction of runoff volumes, regulatory stormwater standards, and implementation of GSI
techniques, all impacts should be mitigated. Therefore, no unavoidable adverse impacts are expected within the
stormwater system.
All impacts to the water distribution system should be mitigated by upsizing and looping water mains to meet
fire flow demands and following City water regulations, resulting in no unavoidable adverse impacts expected
within the water system.
Development and redevelopment would be required to implement wastewater standards. Therefore, no
unavoidable adverse impacts to wastewater are expected.
2-1
2 Public Comments
& Responses
2.1 Commenters
This section of the Final EIS summarizes the comments received on the Draft EIS from January 24 to February
28, 2024. Approximately nine written comments were received on the Draft EIS. In addition, comments were
shared via a public hearing on February 21, 2024.
Exhibit 2-1. Draft EIS Commenters
Number Agency Last Name First Name Comment Date
Government Agencies
1 Duwamish Tribe Sackman Nancy February 22, 2024
2 King County
Wastewater Treatment
Division (WTD)
Satterwhite Zanna February 21, 2024
3 King County Metro Markwell Thi February 8, 2024
Business/ Non-profit
4 McCullough Hill PLLC,
on behalf of Innovatus
Capital*
McCullough John February 23, 2024
February 28, 2024
(supersedes February 23,
2024 comments)
Individuals
5 Artze Andres February 21, 2024
6 Kelly Jeff January 26, 2024
7 Tamasan Ion January 30, 2024
8 LaFranchi Philip January 27, 2024
*Hearing participant
Rainier/Grady Junction TOD Subarea Planned Action Ch. 2 ▪ Public Comments & Responses
March 2024 ▪ Final EIS
2-2
Correction Note: The Draft EIS cover letter and Notice of Availability indicated the end of the comment period
as February 24, 2024 (providing a 31st day of the comment period), while the Fact Sheet identified the end of
the comment period as February 23, 2024. Regardless, the City accepted comments for one week after the
public hearing, effectively extending the comment period to February 28, 2024.
2.2 Comments and Responses
Below is a summary of comments and responses. Full copies of the comments are included in the Appendix.
Responses provide clarifications about the Draft EIS analysis or alternatives. Where preferences are noted, the
responses acknowledge them and note the comments are forwarded to City decision makers.
Exhibit 2-2. Comments and Responses
Number Comment Summary Response
1 The project location is culturally significant for
the Duwamish Tribe consisting of three ancient
village sites. The DAHP WISAARD map also shows
several known archaeological sites within the
vicinity.
Recommends:
An archaeological survey and monitoring with an
IDP (inadvertent discovery plan) for the
development within and around the
Rainier/Grady Junction subarea, especially if any
ground disturbance cuts below
fill/asphalt/topsoil or other modern and/or
impervious surfaces into native soil.
Notification for any archaeological work or
monitoring.
Only native vegetation be used for any proposed
landscaping and that wetland and stream buffers
are maintained to enhance fish habitat, native
avian life and native pollinators as well as to
mitigate seasonal urban flooding.
Supports Alternative 2
Permitting standards to be maintained for
development in the Rainier/Grady subarea.
Duwamish Tribe to be a part of the story and
vision of the subarea. An area be laid out for the
Duwamish where the village sites once were and
have a space to practice the traditional lifeways.
The Draft EIS identifies archaeological review and
monitoring as a potential mitigation measure.
See page 3-11 of the Draft EIS; also summarized
in Chapter 1. The City can address that as a
mitigation measure in the Planned Action
Ordinance.
The use of native plantings is another potential
mitigation measure on page 3-10 of the Draft EIS;
also summarized in Chapter 1. Street trees are
chosen for appropriateness. In green space, City
standards could emphasize native plants. The City
can consider its current landscaping standards
and potential adjustments in its proposed zoning
and development standards for the Planned
Action Area.
The support of Alternative 2 is noted and
forwarded to City decision makers.
The City will continue to have notices of
application for development in the Planned
Action Area and such notices can identify if a
planned action is proposed.
Proposed requirements for long-term and short-
term bike parking are intended to encourage
non-motorized travel to enhance health of
people and the environment in this higher
density alternative. No adverse impacts are
anticipated.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 2 ▪ Public Comments & Responses
March 2024 ▪ Final EIS
2-3
Number Comment Summary Response
“We would like to see water and fish flowing
through the Black River again.”
Concerns:
Concern about long- and short-term bike parking
requirements, width of the pedestrian clear
zones.
Many times Tribes are left out of the details and
nuances of planning and design once a planned
action is put in place. This urban planning
strategy disregards changes that can occur from
the time of adoption to actual groundbreaking
construction.
Thank you for your review of the Draft EIS. The
Black River is located west of the study area. The
Black River forest is largely in public ownership
and contains protected wetlands. The cultural
importance of the Black River is noted and
forwarded to City decision makers.
The comments regarding urban design are noted.
The City is interested in positive placemaking.
When public green spaces are designed, the City
would have opportunities for engagement.
2 King County has multiple facilities and sewers in
the EIS Study Area. In order to protect these
wastewater facilities and sewers during
construction, WTD requires that City of Renton
submit construction drawings for proposed
project identified as a result of the EIS that lie
within 500-feet of the WTD facilities and sewers,
so that WTD can assess its potential impacts. King
County has permanent easements for facilities
and sewers in the EIS study area, and must be
assured the right to maintain and repair the
facilities and sewers.
The comment is noted. The notification of King
County WTD can be included in the proposed
Planned Action Ordinance. The notice is added as
a mitigation measure and reflected in the Chapter
1 Summary under Utilities.
3 All construction and other work activity affecting
King County Metro Transit Operations or Facilities
must be coordinated through the KCM System
Impacts workgroup. Please contact them to
provide specific information related to the
activity and allow the required lead time
necessary for responding to any impacts caused
by it.
The comment is noted. The notification of King
County Metro can be included in the proposed
Planned Action Ordinance. The notice is added as
a mitigation measure and reflected in the Chapter
1 Summary under Transportation.
4 Development plans for the Triton Tower site is
well-aligned with the overall vision of the
adopted Subarea Plan to encourage dense,
mixed-use development with improved
pedestrian and bike connections near the Transit
Center.
Policy objective of catalyzing desired changes
through zoning incentives will be vitally
important (see comments added below).
The comment is noted and forwarded to City
decision makers.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 2 ▪ Public Comments & Responses
March 2024 ▪ Final EIS
2-4
Number Comment Summary Response
4.1 Flexibility and Incentives:
Supports Alternative 2 to the extent that it
studies the same amount of height and density
but would provide for voluntary incentives for
extra development capacity.
EIS should remain as flexible as possible to allow
for site-specific modifications during the
entitlement process.
Does not support mandatory inclusionary
requirements such as for affordable housing or
other public benefits because it will not result in
more development, but rather the opposite.
Voluntary incentives should be used in this
location to achieve the City’s goal of catalyzing
development.
The Draft EIS and resulting development
standards provided by the Planned Action
Ordinance will be as flexible as possible; however,
mitigation measures are necessary to lessen or
avoid adverse impacts.
While open space dedication beyond current
Renton Municipal Code (RMC) requirements was
identified as a public benefit to be derived as
either an incentive for greater building height or
density under Alternative 2 or as a requirement
under Alternative 3, pedestrian connections such
as “thru-block connections” identified in the
Subarea Plan are necessary to create transit-
oriented development (TOD) and will be required
under either of the Action Alternatives.
4.2 Typologies:
The Preferred Alternative should study mixed-use
and a flexible range of height throughout the
Subarea. On the Triton site, the Preferred
Alternative should study height limits up to at
least 85 feet, or seven stories to accommodate
the most likely residential typology in this
location: midrise, modular or five-over-two
construction.
Typologies indicated are too specific as to the
number of floors and should not exclude seven-
story buildings.
The “typologies” identified in the Draft EIS were
used to model a range of possible development
for analysis of impacts, but these modeled
typologies will not be used to limit use or building
height on any of the parcels in the Planned Action
Area to be the typology shown. A range of
building heights were studied between single-
story commercial uses to mixed-use buildings up
to 150 feet tall. The proposed development
standards would not require or limit land uses or
building height to reflect what was modeled in
the Draft EIS; the code would set the maximum
height and density but allow those maximums to
be exceeded in exchange for providing public
benefits. Please refer to Draft EIS Exhibit 1-9,
Alternative Features Compared, also shown in
Final EIS Exhibit 1-10, for a summary of the
proposed development standards for each
alternative.
4.3 Height:
Support the 70-150 foot height ranges reflected
in Alternatives 2 and 3 in Exhibit 2-20. The
studied building typologies should be revised to
include these height ranges.
See response to comment 4.2.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 2 ▪ Public Comments & Responses
March 2024 ▪ Final EIS
2-5
Number Comment Summary Response
4.4 Uses:
Residential uses should be allowed throughout.
Limiting significant parts of the Subarea to
commercial uses as shown in Alternatives 2 and 3
seems contrary to the City’s mixed-use vision.
The entire Triton Towers site should be studied in
the FEIS as mixed-use to allow for flexibility and
without any minimum story height requirements.
See response to comment 4.2.
4.5 Ground-floor commercial:
At present, the cost of development of any
required ground-floor commercial space in this
location would be assigned to residential units for
the purposes of underwriting due to current lack
of demand for retail space.
The FEIS and future zoning should reflect this
reality by containing flexible ground-floor
requirements.
The FEIS should study some amount of
commercial uses at the ground-level focused on
street frontages on large sites but zoning should
allow less than 40% ground floor commercial.
The 20-foot ground-floor story height articulated
in the Draft EIS (pg. 1-5) is not realistic or feasible.
The Final EIS should assume 15-foot ground-floor
story heights.
While a substantial amount of housing is
anticipated in the area, the area is zoned for
commercial land uses and it is important for the
City regulations to require commercial space be
created for the sake of economic development,
livability, and creating the vibrant mixed-use
district envisioned by the Subarea Plan.
Commercial uses are necessary for successful
TOD to improve access to shopping,
entertainment, and other daily needs while
discouraging auto-dependence for residents.
While the vision of the area as a vibrant mixed-
use district will not be realized in the near-term,
the cumulative effects of requiring development
to provide ground floor commercial, public open
spaces, mixed-income housing, and quality urban
design, are needed to help make the vision a
reality.
The City’s current mixed-use development
standards (e.g., 40% floor plate requirement, 20-
foot tall podium height, etc.), applied to all
commercial zones, were carefully considered
before they were adopted in 2018 and were in
response to commercial zones being developed
with only a modicum of commercial space. The
decision to base the amount of commercial space
required on a percentage of the building
footprint was chosen, in part, because it can be
applied uniformly and it incentivizes smaller
building footprints, which can result in buildings
that allow more sunlight to penetrate public
realms and more opportunities for pedestrian
connections. Per RMC 4-4-150.F, modifications to
the City’s mixed-use development standards are
allowed on a case-by-case basis.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 2 ▪ Public Comments & Responses
March 2024 ▪ Final EIS
2-6
Number Comment Summary Response
4.6 Air and Sound Quality:
500-foot “buffer” from I-405 to mitigate air and
sound impacts to residential use - would create
added costs to housing or even make housing
development infeasible, undermining the
purpose of the TOD.
Air quality and sound issues should be addressed
by the new state Building Code, and do not
require any additional mitigation in the zoning
code. No explanation on why buffer should be
500 ft.
Supportive of landscaping within the Subarea to
mitigate air and sound quality issues
The Subarea Plan recommends several
opportunities to mitigate for impacts to air and
noise, including a buffer from I-405 for residential
development, site and building design features,
centralized air filtration systems, air intake vents
located away from polluted areas, continuous
sound walls with vegetation along I-405, and
consideration of the California Environmental
Protection Agency’s – Air Resources Board:
Strategies to Reduce Air Pollution Exposure Near
High Volume Roadways (April 2017, pages 20-39).
The following excerpt from the DEIS is found on
page 3-28.
“Air Quality and Noise Compatibility: Pollution
Sources
The air and noise pollution sources most relevant
to this study include aircraft at the Renton
Municipal Airport and roadway traffic such as
along I-405. Aircraft landing and take-off paths
see concentrated air pollutants and noise
impacts. Roadways see air pollution from vehicle
exhaust and brake/tire/road wear. Pollutant
particle size, topography, and wind patterns affect
the geographic extent of concern, with the
greatest impacts adjacent to and downwind of
major freeways. Some patterns include:
▪ Pollutants are most concentrated within 500 ft
of a roadway. Within that 500 feet, ultrafine
particles “rapidly decay” to a 50%
concentration (UW Mov-Up Report, 2019, p
38).
▪ Areas within 1,000 – 1,600 ft of a busy highway
are most affected by a range of pollutants and
particle sizes (American Lung Association).
▪ Close, long-term exposure (within 165 feet) to
a heavily trafficked roadway has the strongest
association with dementia (American Lung
Association).”
Rainier/Grady Junction TOD Subarea Planned Action Ch. 2 ▪ Public Comments & Responses
March 2024 ▪ Final EIS
2-7
Number Comment Summary Response
4.7 Rolling Hills Creek:
Daylighting Rolling Hills Creek as a mitigation
measure – this is not justifiable since it is a pre-
existing condition. Current zoning would impose
a 75-ft buffer and additional 15 structure setback
on the Triton Tower One site. This would reduce
the size of proposed residential development on
this site, which is also constrained by existing
utilities easements.
DEIS statement is incorrect that daylighting the
creek would not result in reduced development
potential if residential density transfer is allowed.
The allowable density in this location is not a
limiting factor and towers are not feasible in this
location.
The trade-off for daylighting a portion of a creek
in this location near the highway would be to
preclude a significant amount of housing
development within the subarea for minimal
benefit to the public. We ask the City to remove
this recommendation from the Final EIS.
Include off-site or nearby critical areas mitigation
instead of requiring creek daylighting that would
impose significant buffer constraints on the
Property.
The Draft EIS suggests different options for
daylighting of Rolling Hills Creek, with setbacks
already required, and daylighting incentives a
focus, or only a possible requirement if
development is actually moving the creek.
The following is from the DEIS and provides a
summary of the intent for the Planned Action
Ordinance.
Page 1-15 and 1-23: “The City currently restricts
buildings over piped streams and easements to
maintain the piping. Mitigation opportunities for
daylighting Rolling Hills Creek include allowing
transfer of residential density/floor area ratio so
the daylighted stream and any natural buffer
does not reduce the development potential when
the stream is daylighted. The City could also
require daylighting if development would
relocate the creek, as well as incentivize
daylighting where increased heights are allowed.”
Page 1-41, 3-66, or 3-185: “A portion of Rolling
Hills Creek is currently piped underneath
development. It should be noted that daylighting
the creek or portions of the creek would allow for
an increased impervious surface lot coverage per
RMC 4-3-050 section 7f-ii. This is a viable option
to improve existing conditions as well as benefit
the developer. The City code allows for, but does
not specify, incentives for developers to daylight
streams. The City should consider implementing
specific incentives to encourage developers to
daylight portions of Rolling Hills Creek to restore
more natural habitat to the area.”
Rainier/Grady Junction TOD Subarea Planned Action Ch. 2 ▪ Public Comments & Responses
March 2024 ▪ Final EIS
2-8
Number Comment Summary Response
4.8
New Street Network:
Generally supportive of increased connectivity
within the Subarea but it should not have the end
result of precluding housing production. Exact
street locations should be determined as the
Subarea develops based on site-specific
conditions and proposals during project-level
review. The Final EIS should assume that streets
on private property may remain private, and
street sections should also remain flexible and be
reviewed by the City at project-level
entitlements.
The Subarea Plan established the concept of a
new street network within Renton Village. The
Subarea Plan identifies the general location of
future streets as well as the features and
dimensions of the streets, which were designed
specifically for the area. While the exact locations
of the proposed streets will be determined
during the entitlement process, the need for a
street network and streets designed for TOD is
clearly demonstrated by the Subarea Plan and
the Draft EIS.
Similar to all newly created streets in the city, the
exact specifications of new streets are provided
by Renton Municipal Code (See RMC 4-4-060,
Street Standards) which also provides the means
for variations from the adopted standards on a
case-by-case basis.
5 Concerned about the safety and speed of traffic
moving along Grady Way. Future improvements
to the road to include traffic-calming devices such
as chicanes and speed cushions to discourage
speeding.
Paths leading to Benson Rd S is missing. That
should be a priority to keep many of the existing
local businesses in the area (such as Uwajimaya)
supported throughout the construction process.
Speeds were not specifically included in this
study but are not anticipated to increase on
Grady Way due to development with intersection
delays remaining close to the No Action
alternative. Slowing vehicle speeds would induce
additional delays for vehicular traffic on this
arterial roadway that is also a truck route.
Although chicanes and speed cushions are not
appropriate traffic calming treatments for high-
volume roadways, several other safety measures
are proposed. These include updating the
roadway section along Grady Way to provide
wider roadway-separated non-motorized
facilities, as well as performing a study to
determine implementation options to enhance
safety for crossing Grady Way.
The Subarea Plan provides direction for future
improvements of pedestrian and bicycle
connections leading to Benson Rd S, which will
help inform future Capital Improvement Projects.
Additionally, the newly developed streets in
Renton Village will provide complete streets with
buffered bicycle lanes.
Rainier/Grady Junction TOD Subarea Planned Action Ch. 2 ▪ Public Comments & Responses
March 2024 ▪ Final EIS
2-9
Number Comment Summary Response
6 Questions and comments related to height, road
network, parking, mixed-use, zoning, mitigation
and utilities such as:
5 to 10 stories for Alternative 2, and 10 – 14
stories for alternative 3
Road network, loop road, car-unfriendly Main
Street
No separation of commercial and mixed use
Location of light rail along Shattuck Ave
Include pedestrian crossings and roundabouts
Question about Home Depot and the City Hall
being excluded.
500 ft buffer for all uses.
Specific suggestions about zoning on pages 26
and 27.
Mitigation – green space buffer no benefit to
building tenants nor pedestrians; temperature
impact is missing; charge high for parking and
provide bus-only lanes
Utilities - Is this how we want to use 50% of our
remaining tap-water capacity as a city?
The Home Depot site had a major construction
already in the permit pipeline. City Hall, as a
public site, is not under consideration for changes
in use or growth. Therefore, those properties
were excluded from the Planned Action.
However, the broader study area accounts for
cumulative conditions and growth such as
pipeline development or growth under current
zoning.
Other suggestions for zoning, mitigation, and
infrastructure are noted and forwarded to City
decision makers.
7 Fully supports and prefer Alternative 3 over the
other options. Need for more housing, more jobs,
more foot traffic activity. Build a walkable
neighborhood with
restaurants/bars/entertainment. Alternative 3
will produce more revenue for the city that can
be allocated into more similar projects and
accumulate revenue like a snowball effect and
make Renton an economic powerhouse/popular
place.
The comment is noted and forwarded to City
decision makers. Both action alternatives are
expected to create a walkable community.
8 Supports added density in this underutilized area
of Renton. if Renton wants to follow the lead of
upzoning (see Vancouver suburbs and Bellevue)
then there is a real opportunity to create tall
slender residential buildings to allow more light
at ground level. No boxy-bulky buildings. 14
stories is a good start, but can go up to 20-25
floors. As much residential near transit as
possible.
The comment is noted and forwarded to City
decision makers. Development regulations will
ensure good massing and building design.
Proposed building heights are consistent with the
market.
THIS PAGE INTENTIONALLY BLANK.
3-1
3 Appendix
a) Marked Comment Letters
THIS PAGE INTENTIONALLY BLANK.
DUWAMISH TRIBE
dxʷdəwʔabš
Duwamish Tribe | 4705 W. Marginal Way SW, Seattle, WA 98106 | 206-431-1582
www.duwamishtribe.org
02/22/2024
City of Renton
LUA22-000289
Environmental Impact Statement Rainier/Grady Junction Planned Action
Dear Paul Hintz,
Thank you for the opportunity to comment on the project LUA22-000289, the Rainier/Grady Junction
TOD (transit-oriented development) Planned Action EIS (environmental impact statement) for the City of
Renton. The project location is culturally significant for the Duwamish Tribe. We note at least 6
Duwamish placenames within or adjacent to the planned action area including three ancient village
sites, the family home of Mrs. Jimmy Moses (one of our Duwamish ancestors) and the former river
courses of the Cedar and Black Rivers, home and namesake of the Duwamish Tribe, dxʷdəwʔabš – The
People of the Inside. This area is where the Duwamish lived, canoed, fished, traded and managed
resources for daily living. The DAHP WISAARD predictive model indicates that a survey ranges from
highly advised with a high to a very high risk for encountering cultural resources. The DAHP WISAARD
map also shows several known archaeological sites within the vicinity. Previous nearby borehole logs
from the Washington State Geology portal indicate that in general, that near surface soil profiles are
fill/asphalt over alluvium, sand and silt with lenses of organic layers and peat.
The Duwamish Tribe echoes our previous comments on the project submitted August 25, 2022. Based
on the information provided and our understanding of the EIS and subarea location, the Duwamish Tribe
recommends an archaeological survey and monitoring with an IDP (inadvertent discovery plan) for the
development within and around the Rainier/Grady Junction subarea, especially if any ground
disturbance cuts below fill/asphalt/topsoil or other modern and/or impervious surfaces into native soil.
This is in an area the Duwamish Tribe considers culturally significant and has a high probability of having
unknown archaeological deposits. We request that if any archaeological work or monitoring is
performed during construction in the planned action subarea, we would like notification. Cultural and
archaeological resources are non-renewable and are best discovered prior to ground disturbance. The
Tribe would also like the opportunity to be present if or when an archaeologist is on site if an artifact or
cultural resource is encountered.
In addition, the Tribe strongly recommends that only native vegetation be used for any proposed
landscaping and that wetland and stream buffers are maintained to enhance fish habitat, native avian
life and native pollinators as well as to mitigate seasonal urban flooding. Many wetlands and creeks
covered this area including Pa'pxwEtsut (place where the water is swift), a tributary to the Black River
(see Figure 1).
Regarding the three alternatives proposed in the EIS, the Duwamish Tribe recognizes the challenges that
face the City of Renton. The City has seen a growth in population and the need for improved
transportation, access to affordable housing, food, services and education. For the Duwamish, the area
DUWAMISH TRIBE
dxʷdəwʔabš
Duwamish Tribe | 4705 W. Marginal Way SW, Seattle, WA 98106 | 206-431-1582
www.duwamishtribe.org
supported many people and several villages known by the names of Sab'badi'd (crag or little mountain),
Tuxudidu' (little inside river, i.e. the Cedar River), TuwE'bq-o (confluence) and SkEte'lubc (home of the
Moses’ and named after a monster that lived in the Black River). The confluence of the two main rivers
and access to Lake Washington provided a network of trade via water and food abundance. The
Duwamish Tribe hopes that by supporting Alternative 2, Mid-Rise – Incentive Zoning, this will continue
the opportunity for growth for the City of Renton. This alternative received the most positive reviews
out of the 3 alternatives and reflects a modern and steady growth for the city (see the table below). We
are concerned about long- and short-term bike parking requirements as we see that this is an increasing
mode of transportation among people in the general Puget Sound region. In addition, we are also
concerned about the width of pedestrian clear zones. Renton in the recent past has been a city where
people move through to other destinations rather than being a final destination. We would, again, like
to view the City as a home, as it once was for the Duwamish. Of most concern is ensuring that
permitting standards are maintained for development in the Rainier/Grady subarea. While we
understand that we are allowed to comment now on future projects, many times the Duwamish and
other tribes are left out of the details and nuances of planning and design once a planned action is put in
place. This urban planning strategy disregards changes that can occur from the time of adoption to
actual groundbreaking construction. This is still our home and needs to be respected.
Finally, the Duwamish Tribe asks that we be a part of the story and vision of the subarea. The City of
Renton has a unique opportunity with the development plan to honor the abundance of food, aquatic
life, the original courses of the Black and Cedar Rivers, the Pa'pxwEtsut Creek and the marshes that once
occupied the area. This land supported those elements as well as the Duwamish Tribe. One of our
ancestors, the Moses Family, lived in the area along the former course of the Black River in Renton near
what is now Renton High School. We ask that an area be laid out for the Duwamish where our village
sites once were and have a space to practice our traditional lifeways. We would like to see water and
fish flowing through the Black River again.
The Duwamish Tribe would also like to make the following requests and recommendations regarding the
Rainier/Grady Junction:
▪ Be invited to contribute during the decision-making process on planning and/or the design of
development in the subarea.
▪ Be informed of environmental studies and their results around the planned action.
▪ The Duwamish Tribe would like to see included in the planned action area greenspaces with
native plants and a dedicated native plant park with a Duwamish voice.
▪ The Duwamish Tribe would like to see the overall design of the area in Coast Salish or southern
Lushootseed architecture and artwork.
▪ We respectfully recommend that streets and buildings have a southern Lushootseed name.
DUWAMISH TRIBE
dxʷdəwʔabš
Duwamish Tribe | 4705 W. Marginal Way SW, Seattle, WA 98106 | 206-431-1582
www.duwamishtribe.org
Lastly the Duwamish Tribe wishes the City of Renton success in adopting the planned action for the
Rainier/Grady Junction subarea. We hope it can be a vibrant place for citizens, visitors and its ancestral
people.
Thank you,
Nancy A Sackman
Duwamish Tribe
Cultural Preservation Officer
Mobile – 206-856-2564
Email – preservationdept@duwamishtribe.org
DUWAMISH TRIBE
dxʷdəwʔabš
Duwamish Tribe | 4705 W. Marginal Way SW, Seattle, WA 98106 | 206-431-1582
www.duwamishtribe.org
Figure 1. ArcGIS map overlay of the original courses of the Black and Cedar Rivers and Pa'pxwEtsut Creek
(entering from the east into the Black River) onto a current map.
DUWAMISH TRIBE
dxʷdəwʔabš
Duwamish Tribe | 4705 W. Marginal Way SW, Seattle, WA 98106 | 206-431-1582
www.duwamishtribe.org
Figure 2. Location of the EIS study area in black, the Planned Action Subarea in yellow, and location of
the Duwamish Tribe’s highest concern for archaeological potential outlined in red.
DUWAMISH TRIBE
dxʷdəwʔabš
Duwamish Tribe | 4705 W. Marginal Way SW, Seattle, WA 98106 | 206-431-1582
www.duwamishtribe.org
Table 1. Duwamish Tribe Rank of Alternatives, ✓ indicates favorable, X indicates unfavorable.
Features Alternative 1
– No Action
Alternative 2
– Mid Rise
Incentive
Zoning
Alternative 3
High Rise –
Required
Public Benefit
Subarea Goals & Objectives X X ✓
Mixed Use Development Patterns X ✓ X
Height X ✓ X
Density X ✓ X
Affordable Housing Density Bonus X ✓ X
Health – Air Quality X ✓ ✓
Open Space, Landscaping &
Stormwater
X ✓ ✓
Potential Investments in Transportation ✓ X ✓
Core Area – New Streets X X ✓
Process ✓ X X
Department of Natural Resources and Parks
Wastewater Treatment Division
King Street Center, KSC-NR-5505
201 South Jackson Street Seattle, WA 98104-3855
February 21, 2024 sent via email: phintz@rentonwa.gov KC OAP Ref No.: 2104 Paul Hintz City of Renton 1055 South Grady Way Renton, WA 98057 Dear Paul Hintz: The King County Wastewater Treatment Division (WTD) has received the Notice of Availability of Draft Environmental Impact Statement (DEIS) for the Rainier/Grady Junction Transit Oriented
Development (TOD) Subarea Planned Action project (LUA22-000289) that proposes Municipal Code Amendments/Planned Action Ordinance to facilitate growth and implement the land use vision of the Subarea Plan (creation of a vibrant commercial and residential district oriented around near- term bus rapid transit, with potential for light rail service in the long term) to increase mixed- use opportunities and alter density and development standards including height, density, parking, and others. The Planned Action will complete the environmental review upfront and establish environmental performance standards that each development would be required to meet. Development consistent with the ordinance requirements would not require a new threshold determination and could rely on the Planned Action EIS to streamline their permit review. King County has multiple facilities and sewers in the EIS Study Area (See enclosed map “King County WTD Facilities in TOD EIS Study Area” showing the location of the facilities in the EIS Study Area). In order to protect these wastewater facilities and sewers during construction, WTD requires that City of Renton submit construction drawings for proposed project identified as a result of the EIS that lie within 500-feet of the WTD facilities and sewers, so that WTD can assess its potential impacts. Please send drawings to: Local Public Agency Program King County WTD, Engineering and Technical Resources 201 South Jackson Street, KSC-NR-0503 Seattle, WA 98104-3855 (206) 477-5414 / lpa.team@kingcounty.gov King County has permanent easements for facilities and sewers in the EIS study area, and must be assured the right to maintain and repair the facilities and sewers. Please contact King County regarding these easements, at:
February 21, 2024 Page 2 of 2 Bill Wilbert
Permitting Compliance and Property Acquisition King County Wastewater Treatment Division 201 South Jackson Street, KSC-NR-0512 Seattle, WA 98104-3855 (206) 477-5523 / bill.wilbert@kingcounty.gov Thank you for the opportunity to review and comment on this proposal. Sincerely,
Zanna Satterwhite
Zanna Satterwhite Environmental Planner cc: Mark Lampard, Local Public Agency Coordinator Claire Christian, Real Property Agent IV Enclosure
Sources: Esri, HERE, Garmin, USGS, Intermap,INCREMENT P, NRCan, Esri Japan, METI, Esri China (HongKong), Esri Korea, Esri (Thailand), NGCC, (c)OpenStreetMap contributors, and the GIS User Community,King County
Date: 2/15/2024 King County Wastewater Treatment Division
The information included on this map has been compiled by King County staff from a variety of sources and issubject to change without notice. King County makes no representations or warranties, express or implied,as to accuracy, completeness, timeliness, or rights to the use of such information. This document is not intendedfor use as a survey product. King County shall not be liable for any general, special, indirect, incidental, orconsequential damages including, but not limited to, lost revenues or lost profits resulting from the use or misuseof the information contained on this map. Any sale of this map or information on this map is prohibited except bywritten permission of King County.
Legend
Major Facilities
Treatment Plant
Wet WeatherTreatmentFacility
Pump Station
Regulator Station
Sewer Lines
Gravity
Pressure
Siphon
Force Main
Outfall
Overflow
Chiller
Vent
Water Reuse
Gravity
King County WTD Facilities in TOD EIS Study Area
±
1
From:Jennifer Cisneros
Sent:Thursday, February 8, 2024 1:53 PM
To:Paul Hintz
Subject:RE: City of Renton Notice of Availability: Draft Environmental Impact Statement (Draft
EIS) for the Rainier/Grady Junction Transit Oriented Development (TOD) Subarea
Planned Action, LUA22-000289
Paul
I have added them to the Party of Record list in Laserfiche and save a copy to the file.
https://laserfiche.rentonwa.gov/InternalPortal/DocView.aspx?id=10652714&dbid=0&repo=CityofRenton
JENNY CISNEROS, Planning Technician
City of Renton | CED | Planning Division
1055 S Grady Way | 6th Floor | Renton, WA 98057
Virtual Permit Center | Online Applications and Inspections
(425) 430-6583 | jcisneros@rentonwa.gov
From: Jennifer Cisneros
Sent: Thursday, February 8, 2024 1:48 PM
To: Markwell, Thi <tmarkwell@kingcounty.gov>
Cc: Paul Hintz <PHintz@Rentonwa.gov>
Subject: RE: City of Renton Notice of Availability: Draft Environmental Impact Statement (Draft EIS) for the Rainier/Grady
Junction Transit Oriented Development (TOD) Subarea Planned Action, LUA22-000289
Hi Thi,
Thank you for your comments. Your comments have been added to the official file for considera on and you have been
added as a party of record for this project. Paul Hintz is the project manager and is cc’d in this email. If you have any
further comments you can direct them to him personally.
Best,
JENNY CISNEROS, Planning Technician
City of Renton | CED | Planning Division
1055 S Grady Way | 6th Floor | Renton, WA 98057
Virtual Permit Center | Online Applica ons and Inspec ons
(425) 430-6583 | jcisneros@rentonwa.gov
From: Markwell, Thi <tmarkwell@kingcounty.gov>
Sent: Wednesday, February 7, 2024 2:00 PM
To: Jennifer Cisneros <JCisneros@Rentonwa.gov>
Subject: City of Renton Notice of Availability: Draft Environmental Impact Statement (Draft EIS) for the Rainier/Grady
Junction Transit Oriented Development (TOD) Subarea Planned Action, LUA22-000289
2
Good Afternoon,
King County Metro received the notice, "City of Renton Notice of Availability: Draft Environmental Impact
Statement (Draft EIS) for the Rainier/Grady Junction Transit Oriented Development (TOD) Subarea
Planned Action, LUA22-000289" and have routed it for internal review. Please see the below
comment/request:
All construction and other work activity affecting King County Metro Transit Operations or Facilities must be coordinated
through the KCM System Impacts workgroup. Please contact them to provide specific information related to the activity
and allow the required lead time necessary for responding to any impacts caused by it. For notification information and
guidelines please visit: http://www.kingcounty.gov/transportation/kcdot/MetroTransit/Construction.aspx or phone
206.477.1140 or 206.477.1150 for Trolley-related activities.
For all contractors:
After we receive your project information, we require a minimum five business days’ notice before the
start of work. Ten days are required for street closures or transit detours. Please note that different
requirements apply if your work impacts trolley or streetcar lines.
This allows us to plan mitigation, coordinate with other projects, and notify our customers.
Please see our website for notification guidelines and other resources.
We require the following information for each project:
1. The approved Street Use Permit and Traffic Control Plan (TCP that includes the reviewer's
name and approved date) for the project (please attach a pdf) – Please provide
2. Location of the project – Please Provide
3. Is this work part of multiple phases? If so, please send a separate email for each phase.
4. Locations of any bus stops that will need to be relocated, whether they need to be closed
during the entire duration of your project or if they can safely be used when you are not
working – Please Provide
5. Name and cell phone numbers of the primary and alternate onsite contacts – Please Provide
6. Start and end dates of the project. – Please Provide
a. Weekdays only? – Please Provide
7. Daily start and end time of work – Please Provide
8. Is your work weather dependent? - Please provide
9. Nature of the work – Please Provide
10. Company name – Please Provide
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.
3
Your project is not approved. You will be notified in writing after your project is approved. We
will contact you if we require additional information or T-39 No Parks.
If your project is located in a SDOT Construction Hub, you must receive Hub approval.
=====
If you have any questions or concerns, please reach out.
Thank you.
Thi Markwell (She/Her)
Transit Environmental Planner II
Transit Real Estate and Environmental (TREE)
P 206-263-2659
tmarkwell@kingcounty.gov
From: Jennifer Cisneros <JCisneros@Rentonwa.gov>
Sent: Wednesday, January 24, 2024 4:09 PM
Cc: Paul Hintz <PHintz@Rentonwa.gov>
Subject: City of Renton Notice of Availability: Draft Environmental Impact Statement (Draft EIS) for the
Rainier/Grady Junction Transit Oriented Development (TOD) Subarea Planned Action, LUA22-000289
[EXTERNAL Email Notice! ] External communication is important to us. Be cautious of phishing attempts. Do not click or open
suspicious links or attachments.
Hello,
Please see linked below Notice of Availability for - Draft Environmental Impact Statement (Draft EIS)
for the Rainier/Grady Junction Transit Oriented Development (TOD) Subarea Planned Action,
LUA22-000289.
https://edocs.rentonwa.gov/Documents/Browse.aspx?id=9799866&dbid=0&repo=CityofRenton
4
Regards,
JENNY CISNEROS, Planning Technician
City of Renton | CED | Planning Division
1055 S Grady Way | 6th Floor | Renton, WA 98057
Virtual Permit Center | Online Applications and Inspections
(425) 430-6583 | jcisneros@rentonwa.gov
______________________________________________________________________
701 Fifth Avenue • Suite 6600 • Seattle, Washington 98104 • 206.812.3388 • Fax 206.812.3389 • www.mhseattle.com
February 28, 2024
VIA EMAIL
Paul Hintz
City of Renton 1055 S. Grady Way
Renton, WA 98057 Email: PHintz@Rentonwa.gov
Re: Rainier/Grady Junction Transit Oriented Development Subarea Planned Action Draft
Environmental Impact Statement
Mr. Hintz,
We appreciate the opportunity to comment Draft Environmental Impact Statement (“DEIS”) for the Rainier/Grady Junction Transit Oriented Development (“TOD”) Subarea Planned Action on
behalf of Innovatus Capital (“Innovatus” or “Owner”).
Innovatus owns the Triton Towers property bounded by South Grady Way,
Talbot Road South, and I-405, consisting of three office towers and surface parking
(APN’s 1923059023; 1923059001; 7231600542; 7231600595, also referred to
herein as the “Property”). The Triton Towers site is approximately 861,125 s.f.
(19.76 acres) in size, making up a significant portion of the land area in the proposed
Grady Junction Subarea. The existing three office towers are seven-level structures
totaling 437,850 s.f. with approximately 1,284 surface vehicle parking spaces. The
Property’s general location is shown in the image below.
In general, we applaud the City’s initiative to implement a plan for transit-oriented development that
connects the Subarea to the City’s downtown core and we share the City’s overall vision for the Subarea. We agree with the four Core Goals stated in section 1.4 of the DEIS, especially number
four: “Catalyze Desired Changes: Leverage the recent and planned public investment in the area for the private investment to follow.” We appreciate the City’s efforts to incorporate our input to date
on this topic.
February 28, 2024
Page 2
The Property is likely the largest site in the proposed subarea core under single ownership, located within walking distance to the future transit center. The Property has viable redevelopment
potential in the near term by adding multifamily residential units to the existing office buildings. Innovatus has participated in a pre-application meeting with the City of Renton (“City”) Department
for Community and Economic Development (“CED”) to add four new multifamily residential buildings to the site and a parking structure (the “Project”). The Project would provide
approximately 400 new units directly across from the new Transit Center. The Project also contemplates providing a pedestrian-friendly environment including landscaping and lighting, that
increases safety and pedestrian connectivity throughout the site. The existing office towers would remain; they are well-functioning buildings in good condition. The Triton Towers offer the City the
opportunity to attract well-paying jobs near transit; adding residential alongside office is wholly consistent with the Subarea Plan’s vision to encourage mixed-use development.
We believe our development plans for the Triton Tower site is well-aligned with the overall vision of
the adopted Subarea Plan to encourage dense, mixed-use development with improved pedestrian and bike connections near the Transit Center. Since the Subarea Plan states the City seeks
transformation of the Subarea within the next 20 years, the policy objective of catalyzing desired changes through zoning incentives will be vitally important. To that end, please find our specific
comments on the Draft EIS below.
Flexibility and Incentives: The Subarea is developed with an auto-centric land use pattern, meaning that redevelopment will need to contend with unique nonconforming issues on each site.
The Triton Towers site has a number of utilities easement and other site constraints that limit development options and raise costs. For that reason, the FEIS should remain as flexible as possible
to allow for site-specific modifications during the entitlement process. Also, public benefits such as open spaces and pedestrian connections should be based upon incentives (not inclusionary
requirements), and should be flexible in their implementation. Therefore, we support Alternative 2 to the extent that it studies the same amount of height and density but would provide for voluntary
incentives for extra development capacity. If Alternative 3 is intended include mandatory inclusionary requirements such as for affordable housing or other public benefits, we do not support
that approach because we do not believe it will result in more development, but rather the opposite. Over the short to medium term, voluntary incentives should be used in this location to achieve the
City’s goal of catalyzing development. We are happy to provide more specific information about this.
Typologies: The Preferred Alternative should study mixed-use and a flexible range of height
throughout the Subarea. On the Triton site, the Preferred Alternative should study height limits up to at least 85 feet, or seven stories to accommodate the most likely residential typology in this
location: midrise, modular or five-over-two construction.
The Mixed-Use Base and Mixed-Use Maximum Typologies shown in Exhibit 1-3 (pg. 1-5); Exhibit 2-8 (pg. 2-10) are too specific as to the number of floors and should not exclude seven-story
buildings. By defining the “Mixed-Use Base” category as four to five floors, and the “Mixed-Use Maximum” category as “towers eight to thirteen floors,” the DEIS appears to omit the most likely
residential typology to be developed in the new Subarea. To be clear, residential tower development on the Triton Towers Property is unlikely to be financially feasible in the foreseeable future. The
4.1
February 28, 2024
Page 3
Preferred Alternative should remain flexible and study a variety of typologies, but the most likely typology of approximately 85 feet should be clearly studied.
Height: We support the 70-150 foot height ranges reflected in Alternatives 2 and 3 in Exhibit 2-20.
The studied building typologies should be revised to include these height ranges.
Uses: A mix of uses should be studied throughout the Subarea, including on the Triton Towers Property. Since this is a TOD Subarea, residential uses should be allowed throughout. Limiting
significant parts of the Subarea to commercial uses as shown in Alternatives 2 and 3 seems contrary to the City’s mixed-use vision. Specifically, Alternative 2 designates the Triton Tower One parcel as
all commercial; the entire Triton Towers site should be studied in the FEIS as mixed-use to allow for flexibility and without any minimum story height requirements.
Ground-floor commercial: We are supportive of the City’s vision for mixed-use buildings that
contain ground-floor commercial uses to support an active 18-hour environment. The FEIS should study a range or flexible amount of ground-floor retail in new buildings. At present, the cost of
development of any required ground-floor commercial space in this location would be assigned to residential units for the purposes of underwriting due to current lack of demand for retail space.
However, demand will grow over time as the subarea develops, and new residents move in. The FEIS and future zoning should reflect this reality by containing flexible ground-floor requirements.
Note that the mixed-use development standards in the current Code contain a 40% ground-floor
commercial requirement. This threshold is not financially feasible in buildings with larger floor plates. The FEIS should study some amount of commercial uses at the ground-level focused on
street frontages on large sites, but implementing zoning should allow the City to approve less than 40% ground floor commercial on a case-by-case basis.
Also, the 20-foot ground-floor story height articulated in the Draft EIS (pg. 1-5) is not realistic or
feasible. The Final EIS should assume 15-foot ground-floor story heights.
Air and Sound Quality: The DEIS describes a 500-foot “buffer” from I-405 to mitigate air and sound impacts to residential uses. Pg. 1-12; 1-18. We are concerned that future requirements with in
this buffer would create added costs to housing or even make housing development infeasible, undermining the purpose of the TOD.
Air quality and sound issues are adequately addressed by the new state Building Code, and do not
require any additional mitigation in the zoning code. There is no explanation in the DEIS for why the buffer should be 500-feet from I-405, but we note this would encompass the majority of the
Triton Tower One site where we contemplate possible residential development. The DEIS does not identify existing conditions that require any such buffer, nor does it identify the impacts to housing
development. The TOD Subarea is, by its nature, near major transit corridors. Since the primary purpose of the TOD Subarea is to leverage transit investments by locating dense multifamily
housing within the subarea, the City should avoid imposing additional costs or restrictions on residential development. We are supportive of landscaping within the Subarea to mitigate air and
sound quality issues.
4.3
4.4
4.5
4.6
February 28, 2024
Page 4
Rolling Hills Creek: The DEIS identifies daylighting Rolling Hills Creek as a mitigation measure for “the unintended effects of burying or covering rivers and streams including an increase in
nutrient contamination, the degradation of ecosystems and an increase in downstream floods.” Pg. 1-23. Since Rolling Hills Creek has a been a piped stream for decades, it is a pre-existing condition
that does not justify SEPA mitigation such as daylighting as a condition of new development. Under the current zoning code, daylighting would impose a 75-foot buffer, and additional 15 structure
setback on the Triton Tower One site. This would reduce the size of proposed residential development on this site, which is also constrained by existing utilities easements.
The DEIS states daylighting the creek would not result in reduced development potential if
residential density transfer is allowed. That assumption is incorrect since the allowable density in this location is not a limiting factor and towers are not feasible in this location. We encourage the City to
incentivize environmental improvements including landscaping, and which may include off-site or nearby critical areas mitigation instead of requiring creek daylighting that would impose significant
buffer constraints on the Property. The trade-off for daylighting a portion of a creek in this location near the highway would be to preclude a significant amount of housing development within the
Subarea for minimal benefit to the public. We ask the City to remove this recommendation from the Final EIS.
New Street Network: We are generally supportive of increased connectivity within the Subarea
but it should not have the end result of precluding housing production. We appreciate and continue to support the note on the Conceptual Illustration of New Street Network Map (Exhibit 3-71) that
new street locations are conceptual only. Exact street locations should be determined as the Subarea develops based on site-specific conditions and proposals during project-level review. The Final EIS
should assume that streets on private property may remain private, and street sections should also remain flexible and be reviewed by the City at project-level entitlements.
Thank you for considering our comments. Please do not hesitate to contact me with any questions.
Sincerely,
s/ John McCullough s/ Jessica Roe
On behalf of the Owner
Cc: Brad Seiden, Innovatus Capital
4.7
4.8
______________________________________________________________________
701 Fifth Avenue • Suite 6600 • Seattle, Washington 98104 • 206.812.3388 • Fax 206.812.3389 • www.mhseattle.com
February 23, 2024
VIA EMAIL
Paul Hintz
City of Renton 1055 S. Grady Way
Renton, WA 98057 Email: PHintz@Rentonwa.gov
Re: Rainier/Grady Junction Transit Oriented Development Subarea Planned Action Draft
Environmental Impact Statement
Mr. Hintz,
We appreciate the opportunity to comment Draft Environmental Impact Statement (“DEIS”) for the Rainier/Grady Junction Transit Oriented Development (“TOD”) Subarea Planned Action on
behalf of Innovatus Capital (“Innovatus” or “Owner”).
Innovatus owns the Triton Towers property bounded by South Grady Way,
Talbot Road South, and I-405, consisting of three office towers and surface parking
(APN’s 1923059023; 1923059001; 7231600542; 7231600595, also referred to
herein as the “Property”). The Triton Towers site is approximately 861,125 s.f.
(19.76 acres) in size, making up a significant portion of the land area in the proposed
Grady Junction Subarea. The existing three office towers are seven-level structures
totaling 437,850 s.f. with approximately 1,284 surface vehicle parking spaces. The
Property’s general location is shown in the image below.
In general, we applaud the City’s initiative to implement a plan for transit-oriented development that
connects the Subarea to the City’s downtown core and we share the City’s overall vision for the Subarea. We agree with the four Core Goals stated in section 1.4 of the DEIS, especially number
four: “Catalyze Desired Changes: Leverage the recent and planned public investment in the area for the private investment to follow.” We appreciate the City’s efforts to incorporate our input to date
on this topic.
February 23, 2024
Page 2
The Property is likely the largest site in the proposed subarea core under single ownership, located within walking distance to the future transit center. The Property has viable redevelopment
potential in the near term by adding multifamily residential units to the existing office buildings. Innovatus has participated in a pre-application meeting with the City of Renton (“City”) Department
for Community and Economic Development (“CED”) to add four new multifamily residential buildings to the site and a parking structure (the “Project”). The Project would provide
approximately 400 new units directly across from the new Transit Center. The Project also contemplates providing a pedestrian-friendly environment including landscaping and lighting, that
increases safety and pedestrian connectivity throughout the site. The existing office towers would remain; they are well-functioning buildings in good condition. The Triton Towers offer the City the
opportunity to attract well-paying jobs near transit; adding residential alongside office is wholly consistent with the Subarea Plan’s vision to encourage mixed-use development.
We believe our development plans for the Triton Tower site is well-aligned with the overall vision of
the adopted Subarea Plan to encourage dense, mixed-use development with improved pedestrian and bike connections near the Transit Center. Since the Subarea Plan states the City seeks
transformation of the Subarea within the next 20 years, the policy objective of catalyzing desired changes through zoning incentives will be vitally important. To that end, please find our specific
comments on the Draft EIS below.
Flexibility and Incentives: The Subarea is developed with an auto-centric land use pattern, meaning that redevelopment will need to contend with unique nonconforming issues on each site.
The Triton Towers site has a number of utilities easement and other site constraints that limit development options and raise costs. For that reason, the FEIS should remain as flexible as possible
to allow for site-specific modifications during the entitlement process. Also, public benefits such as open spaces and pedestrian connections should be based upon incentives (not inclusionary
requirements), and should be flexible in their implementation.
Typologies: The Preferred Alternative should study mixed-use and a flexible range of height throughout the Subarea. On the Triton site, the Preferred Alternative should study height limits up
to at least 85 feet, or seven stories to accommodate the most likely residential typology in this location: midrise, modular or five-over-two construction.
The Mixed-Use Base and Mixed-Use Maximum Typologies shown in Exhibit 1-3 (pg. 1-5); Exhibit
2-8 (pg. 2-10) are too specific as to the number of floors and should not exclude seven-story buildings. By defining the “Mixed-Use Base” category as four to five floors, and the “Mixed-Use
Maximum” category as “towers eight to thirteen floors,” the DEIS appears to omit the most likely residential typology to be developed in the new Subarea. To be clear, residential tower development
on the Triton Towers Property is unlikely to be financially feasible in the foreseeable future. The Preferred Alternative should remain flexible and study a variety of typologies, but the most likely
typology of approximately 85 feet should be clearly studied.
Height: We support the 70-150 foot height ranges reflected in Alternatives 2 and 3 in Exhibit 2-20. The studied building typologies should be revised to include these height ranges.
Uses: A mix of uses should be studied throughout the Subarea, including on the Triton Towers
Property. Since this is a TOD Subarea, residential uses should be allowed throughout. Limiting
February 23, 2024
Page 3
significant parts of the Subarea to commercial uses as shown in Alternatives 2 and 3 seems contrary to the City’s mixed-use vision. Specifically, Alternative 2 designates the Triton Tower One parcel as
all commercial; the entire Triton Towers site should be studied in the FEIS as mixed-use to allow for flexibility and without any minimum story height requirements.
Ground-floor commercial: We are supportive of the City’s vision for mixed-use buildings that
contain ground-floor commercial uses to support an active 18-hour environment. The FEIS should study a range or flexible amount of ground-floor retail in new buildings. At present, the cost of
development of any required ground-floor commercial space in this location would be assigned to residential units for the purposes of underwriting due to current lack of demand for retail space.
However, demand will grow over time as the subarea develops, and new residents move in. The FEIS and future zoning should reflect this reality by containing flexible ground-floor requirements.
Note that the mixed-use development standards in the current Code contain a 40% ground-floor
commercial requirement. This threshold is not financially feasible in buildings with larger floor plates. The FEIS should study some amount of commercial uses at the ground-level focused on
street frontages on large sites, but implementing zoning should allow the City to approve less than 40% ground floor commercial on a case-by-case basis.
Also, the 20-foot ground-floor story height articulated in the Draft EIS (pg. 1-5) is not realistic or
feasible. The Final EIS should assume 15-foot ground-floor story heights.
Air and Sound Quality: The DEIS describes a 500-foot “buffer” from I-405 to mitigate air and sound impacts to residential uses. Pg. 1-12; 1-18. We are concerned that future requirements with in
this buffer would create added costs to housing or even make housing development infeasible, undermining the purpose of the TOD.
Air quality and sound issues are adequately addressed by the new state Building Code, and do not
require any additional mitigation in the zoning code. There is no explanation in the DEIS for why the buffer should be 500-feet from I-405, but we note this would encompass the majority of the
Triton Tower One site where we contemplate possible residential development. The DEIS does not identify existing conditions that require any such buffer, nor does it identify the impacts to housing
development. The TOD Subarea is, by its nature, near major transit corridors. Since the primary purpose of the TOD Subarea is to leverage transit investments by locating dense multifamily
housing within the subarea, the City should avoid imposing additional costs or restrictions on residential development. We are supportive of landscaping within the Subarea to mitigate air and
sound quality issues.
Rolling Hills Creek: The DEIS identifies daylighting Rolling Hills Creek as a mitigation measure for “the unintended effects of burying or covering rivers and streams including an increase in
nutrient contamination, the degradation of ecosystems and an increase in downstream floods.” Pg. 1-23. Since Rolling Hills Creek has a been a piped stream for decades, it is a pre-existing condition
that does not justify SEPA mitigation such as daylighting as a condition of new development. Under the current zoning code, daylighting would impose a 75-foot buffer, and additional 15 structure
setback on the Triton Tower One site. This would reduce the size of proposed residential development on this site, which is also constrained by existing utilities easements.
February 23, 2024
Page 4
The DEIS states daylighting the creek would not result in reduced development potential if residential density transfer is allowed. That assumption is incorrect since the allowable density in this
location is not a limiting factor and towers are not feasible in this location. We encourage the City to incentivize environmental improvements including landscaping, and which may include off-site or
nearby critical areas mitigation instead of requiring creek daylighting that would impose significant buffer constraints on the Property. The trade-off for daylighting a portion of a creek in this location
near the highway would be to preclude a significant amount of housing development within the Subarea for minimal benefit to the public. We ask the City to remove this recommendation from the
Final EIS.
New Street Network: We are generally supportive of increased connectivity within the Subarea but it should not have the end result of precluding housing production. We appreciate and continue
to support the note on the Conceptual Illustration of New Street Network Map (Exhibit 3-71) that new street locations are conceptual only. Exact street locations should be determined as the Subarea
develops based on site-specific conditions and proposals during project-level review. The Final EIS should assume that streets on private property may remain private, and street sections should also
remain flexible and be reviewed by the City at project-level entitlements.
Thank you for considering our comments. Please do not hesitate to contact me with any questions.
Sincerely,
s/ John C. McCullough
On behalf of the Owner
Cc: Brad Seiden, Innovatus Capital
1
From:Andy Artze <andyartze@gmail.com>
Sent:Wednesday, February 21, 2024 7:29 PM
To:Paul Hintz
Subject:Public Feedback for South Renton Transit Center TOD
Good Evening,
My name is Andres Artze and I'm a resident of Renton, WA (98055). I called into the Planning Committee
meeting this evening, but was unable to leave a comment on the call. I just wanted to voice my support
for the Renton Village TOD concept and hope you move forward with Alternative 3 to support the
sustainable addition of new housing and businesses to the downtown Renton area.
As mentioned by one of the council members during the meeting, I'm also concerned about the safety
and speed of traffic moving along Grady Way. However, I think that moving the Transit Center is more
focused on accommodating the effects without addressing the cause. Instead, I would hope to see
future improvements to the road that would include traffic-calming devices such as chicanes and speed
cushions to discourage speeding altogether.
Beyond that, as part of the improvements it would be great to see bike connections to the Burnett Linear
Park and the Benson Rd S bike lanes. While Burnett connections were addressed, I didn't see any paths
leading to Benson Rd S. I'd also hope that it's a priority to keep many of the existing local businesses in
the area (such as Uwajimaya) supported throughout the construction process, as many have been a
staple of our community for some time.
Thank you for you and your team's work on developing this EIS. It's clear the document was crafted with a
lot of concern and consideration for the community. It's great to see such meaningful development
come to our city and it makes me proud to live in such a thoughtful and forward-thinking community.
Very Respectfully,
Andres Artze
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Jeff’s Context Notes
●Alternative 2:5-10 stories
●Alternative 3:10-14 stories
Big picture:
●Does this height increase move north into the South Renton neighborhood in the future?
It’s going to be really really odd to go from 3 story multi-residential to 150 buildings in 1
block
Crazy Ideas:
●These are a little outside the EIS scope but could guide consideration of mitigation
measures and traffic considerations.
●“The Loop”.It would be exciting to create a looping road highly friendly to non-car use (or
Cruz The Loop use)consisting of Talbot,Renton Village Pl,Shattuck,and 7th.
●“Outside Parking”.Push the parking lots to the main streets and put the buildings in the
middle so that the pedestrian/bike/scooter experience is enhanced for those that live and
work there.Consider the Downtown Disney in Florida model with cars to the outside.
●“Main Street”should be no-cars or a skinny 2-way curving car-unfriendly street that
people don’t want to drive on unless they are delivering /picking up /dropping off
Both Alternatives:
●Why are we forcing separation of commercial and mixed use?
○I think wherever we have commercial Tower we should allow Mixed Use Max
●Potential light rail station
○If this really is a potential station we need to bring the park/pedestrian corridor to
the station instead of to the sidewalk on Rainier.I think this would make the most
sense along Shattuck Ave since Rainier and the properties along it are probably
immovable objects
●Pedestrian Oriented Development
○Grady and S 7t:Since this is a pedestrian-focused area I want to see large
elevated crossings,particularly over Grady and 7th.Consider the wildlife
“underpasses”created on I90.No pedestrian,cyclist,scooter rider,family with
strollers wants to cross these roads on the street.
○Let’s push parking to the major streets and force internal streets to be no-cars.
Delivery trucks and vans,pedestrians,bikes,scooters would all be fine
●Where are the roundabouts?
○This should be a roundabout-only zone except for the obvious immovable objects
of Grady and Rainier.Plan for the additional space at the intersections now if the
transportation team will “require”that to consider them.
●Left-out parcels
○Home Depot and City Hall should be in the same plan.It’s really,really weird to
leave them out
●Page 32:Health-Air Quality:The 500’mitigation buffer should apply to all
use/development,not just residential.
●Page 32:Open Space:The green zone should become city park and be a
coordinated/dedicated corridor of really enjoyable park.We could call it “Central Park”or
“The Line”
Page 26:Alternative 2 showing map of zoning
●Page 30 Comparison:
○South of Grady should all be 120’in Alternative 2.It’s really odd to have a 20 and
70 foot section in the middle of that if I’m a pedestrian moving east-west
Page 27:Alternative 3 showing map of zoning
●Height consideration
○Creating 10-14 story development necessitates more vehicle traffic for commerce
and residents.If we’re going this direction with a pedestrian focused development
we need to push the parking to the outsides and make the streets non-car only.
●Page 30 Comparison:
○Area from 7th to Grady should all be 120’and higher rather than pushing it down
to 70’moving west for consistency in the neighborhood.Currently it’s an odd
experience going from southeast to northwest and having heights drop 50%
across Grady
●BAD TRADE FOR AFFORDABLE HOUSING
○I really,really do not like the trade being offered for “no commercial”if it’s
affordable housing.We NEED the jobs space to warrant people moving into this
area and WORKING in the neighborhood too.
Page 43-49:Migitations
●We should not buffer from the freeway to help reduce noise and air pollution for building
users.350-feet of air space between a freeway and a building is no different than being
right next to it from a pollution standpoint.Pedestrians don’t want to be next to the
freeway at all so we don’t want a green space there that’s bad for pedestrians for no real
benefit to building tenants.
●TEMPERATURE IMPACT IS MISSING.I presume Alternatives 2 and 3 will bring
increased daily temperatures to the area.We should be specifically planning to mitigate
the heat!
●Vehicles:We should charge high parking rates!We should use roundabouts everywhere.
We should not add any more square feet of road or “lanes”anywhere.Bus only lanes
should be bus-only.When the bus service is fast and on time people ride it.When buses
must share with cars they are unpredictable and people don’t ride them.Consider an
internal Renton Shuttle that travels “The Loop”or something like it so people can more
easily move around without vehicles.
Page 59:Utilities
●Water:Is this how we want to use 50%of our remaining tap-water capacity as a city?
1
From:Ion Tamasan <paultamasan@outlook.com>
Sent:Tuesday, January 30, 2024 8:00 AM
To:Paul Hintz
Subject:Rainier/Grady Junction TOD Subarea Planned Action Draft EIS Comments.
Follow Up Flag:Follow up
Flag Status:Completed
Paul,
As a resident of Renton, I fully support and prefer Alternative 3 over the other options. We need more
housing, more jobs, more foot traffic activity, and we have an excellent opportunity to build a walkable
neighborhood with restaurants/bars/entertainment. Alternative 3 will produce more revenue for the city
that can be allocated into more similar projects and accumulate revenue like a snowball effect and make
Renton an economic powerhouse/popular place.
Please move forward with Alternative 3.
Thank you,
Get Outlook for iOS
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1
From:Philip R. LaFranchi <plafranchi@ymail.com>
Sent:Saturday, January 27, 2024 8:33 AM
To:Paul Hintz
Subject:Rainier/Grady Junction TOD Subarea Planned Action Draft EIS Comments
Follow Up Flag:Follow up
Flag Status:Completed
Hello,
I’m looking forward to added density in this underutilized area of Renton. I think it would serve the city
well to have closed pedestrian streets where retail is located, especially with outdoor activities, parks,
fountains, dining.
Also, if Renton wants to follow the lead of upzoning (see Vancouver suburbs and Bellevue) then there
is a real opportunity to create tall slender residential buildings to allow more light at ground level. One
thing I don’t want to see is boxy-bulky buildings. Ones that have good character and design will do
well for the image of Renton. 14 stories is a good start, I wouldn’t mind seeing buildings up to 20-25
floors. Get as much residential in near transit as possible. It will create a real destination in Renton
and keep the area active.
Thanks for your time.
Philip L.
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Page 1 of 10
CITY OF RENTON
Community and Economic Development Department
Draft Rainier/Grady Junction TOD Subarea Planned Action EIS
Staff: Paul Hintz, Principal Planner
Date: March 4, 2024
Applicant or Requestor: Staff
GENERAL DESCRIPTION
The City’s Environmental Review Committee released the draft Rainier/Grady Junction TOD Subarea
Planned Action Environmental Impact Statement (EIS) for a 30-day public comment, which ended on
February 24, 2024. The EIS evaluates three development alternatives for implementing the
Rainier/Grady Junction TOD Subarea Plan (“Subarea Plan”) and the potential impacts on the natural
environment, land use and future growth, transportation systems and facilities, utilities systems and
facilities, and public services. Likely adverse impacts are identified along with proposed mitigation
measures. Staff are seeking input on the community’s preferred alternative and whether all likely
adverse impacts are identified, and appropriate mitigation provided.
BACKGROUND
City staff received the following written public comments in response to the Draft EIS. Staff have
provided written responses in this staff report for some comments that necessitate a detailed and
thorough response; other comments will addressed during staff’s presentation on March 6, 2024.
Testimony #1
From: McCullough Hill PLLC, on behalf of Innovatus Capital
Date: February 28, 2024
VIA EMAIL
Re: Rainier/Grady Junction Transit Oriented Development Subarea Planned Action Draft Environmental
Impact Statement
We appreciate the opportunity to comment Draft Environmental Impact Statement (“DEIS”) for the
Rainier/Grady Junction Transit Oriented Development (“TOD”) Subarea Planned Action on behalf of
Innovatus Capital (“Innovatus” or “Owner”).
Innovatus owns the Triton Towers property bounded by South Grady Way, Talbot Road South, and I-
405, consisting of three office towers and surface parking (APN’s 1923059023; 1923059001;
7231600542; 7231600595, also referred to herein as the “Property”). The Triton Towers site is
approximately 861,125 s.f. (19.76 acres) in size, making up a significant portion of the land area in the
proposed Grady Junction Subarea. The existing three office towers are seven-level structures totaling
437,850 s.f. with approximately 1,284 surface vehicle parking spaces. The Property’s general location is
shown in the image below.
Page 2 of 10 March 4, 2024
In general, we applaud the City’s initiative to implement a plan for transit-oriented development that
connects the Subarea to the City’s downtown core and we share the City’s overall vision for the Subarea.
We agree with the four Core Goals stated in section 1.4 of the DEIS, especially number four: “Catalyze
Desired Changes: Leverage the recent and planned public investment in the area for the private
investment to follow.” We appreciate the City’s efforts to incorporate our input to date on this topic.
The Property is likely the largest site in the proposed subarea core under single ownership, located
within walking distance to the future transit center. The Property has viable redevelopment potential in
the near term by adding multifamily residential units to the existing office buildings. Innovatus has
participated in a pre-application meeting with the City of Renton (“City”) Department for Community
and Economic Development (“CED”) to add four new multifamily residential buildings to the site and a
parking structure (the “Project”). The Project would provide approximately 400 new units directly across
from the new Transit Center. The Project also contemplates providing a pedestrian-friendly environment
including landscaping and lighting, that increases safety and pedestrian connectivity throughout the site.
The existing office towers would remain; they are well-functioning buildings in good condition. The
Triton Towers offer the City the opportunity to attract well-paying jobs near transit; adding residential
alongside office is wholly consistent with the Subarea
Plan’s vision to encourage mixed-use development.
We believe our development plans for the Triton
Tower site is well-aligned with the overall vision of the
adopted Subarea Plan to encourage dense, mixed-use
development with improved pedestrian and bike
connections near the Transit Center. Since the Subarea
Plan states the City seeks transformation of the
Subarea within the next 20 years, the policy objective
of catalyzing desired changes through zoning
incentives will be vitally important. To that end, please
find our specific comments on the Draft EIS below.
Flexibility and Incentives: The Subarea is developed with an auto-centric land use pattern, meaning that
redevelopment will need to contend with unique nonconforming issues on each site. The Triton Towers
site has a number of utilities easement and other site constraints that limit development options and
raise costs. For that reason, the FEIS should remain as flexible as possible to allow for site-specific
modifications during the entitlement process. Also, public benefits such as open spaces and pedestrian
connections should be based upon incentives (not inclusionary requirements), and should be flexible in
their implementation. Therefore, we support Alternative 2 to the extent that it studies the same amount
of height and density but would provide for voluntary incentives for extra development capacity. If
Alternative 3 is intended include mandatory inclusionary requirements such as for affordable housing or
other public benefits, we do not support that approach because we do not believe it will result in more
development, but rather the opposite. Over the short to medium term, voluntary incentives should be
used in this location to achieve the City’s goal of catalyzing development. We are happy to provide more
specific information about this.
Page 3 of 10 March 4, 2024
Staff Response:
The DEIS and resulting development standards provided by the Planned Action Ordinance will be as
flexible as possible; however, mitigation measures are necessary to lessen or avoid adverse impacts.
While open space dedication beyond current Renton Municipal Code (RMC) requirements was
identified as a public benefit to be derived as either an incentive for greater building height or
density under Alternative 2 or as a requirement under Alternative 3, pedestrian connections such as
“thru-block connections” identified in the Subarea Plan are necessary to create transit-oriented
development (TOD) and will be required under either of the Action Alternatives.
(McCullough Hill PLLC public comment, continued)
Typologies: The Preferred Alternative should study mixed-use and a flexible range of height throughout
the Subarea. On the Triton site, the Preferred Alternative should study height limits up to at least 85
feet, or seven stories to accommodate the most likely residential typology in this location: midrise,
modular or five-over-two construction.
The Mixed-Use Base and Mixed-Use Maximum Typologies shown in Exhibit 1-3 (pg. 1-5); Exhibit 2-8 (pg.
2-10) are too specific as to the number of floors and should not exclude seven-story buildings. By
defining the “Mixed-Use Base” category as four to five floors, and the “Mixed-Use Maximum” category
as “towers eight to thirteen floors,” the DEIS appears to omit the most likely residential typology to be
developed in the new Subarea. To be clear, residential tower development on the Triton Towers
Property is unlikely to be financially feasible in the foreseeable future. The Preferred Alternative should
remain flexible and study a variety of typologies, but the most likely typology of approximately 85 feet
should be clearly studied.
Staff Response:
The “typologies” identified in the DEIS were used to model a range of possible development for
analysis of impacts, but these modeled typologies will not be used to limit use or building height on
any of the parcels in the Planned Action Area to be the typology shown. In other words, the adopted
development standards will not require or limit land uses or building height to reflect what was
modeled. Please refer to Exhibit 1-9, Alternative Features Compared, for a summary of the proposed
development standards for each alternative.
(McCullough Hill PLLC public comment, continued)
Height: We support the 70-150 foot height ranges reflected in Alternatives 2 and 3 in Exhibit 2-20. The
studied building typologies should be revised to include these height ranges.
Staff Response:
The “typologies” identified in the DEIS were used to model a range of possible development for
analysis of impacts, but these modeled typologies will not be used to limit use or building height on
any of the parcels in the Planned Action Area to be the typology shown. In other words, the adopted
development standards will not require or limit land uses or building height to reflect what was
modeled. Please refer to Exhibit 1-9, Alternative Features Compared, for a summary of the proposed
development standards for each alternative.
Page 4 of 10 March 4, 2024
(McCullough Hill PLLC public comment, continued)
Uses: A mix of uses should be studied throughout the Subarea, including on the Triton Towers Property.
Since this is a TOD Subarea, residential uses should be allowed throughout. Limiting significant parts of
the Subarea to commercial uses as shown in Alternatives 2 and 3 seems contrary to the City’s mixed-use
vision. Specifically, Alternative 2 designates the Triton Tower One parcel as all commercial; the entire
Triton Towers site should be studied in the FEIS as mixed-use to allow for flexibility and without any
minimum story height requirements.
Staff Response:
The “typologies” identified in the DEIS were used to model a range of possible development for
analysis of impacts, but these modeled typologies will not be used to limit use or building height on
any of the parcels in the Planned Action Area to be the typology shown. In other words, the adopted
development standards will not require or limit land uses or building height to reflect what was
modeled. Please refer to Exhibit 1-9, Alternative Features Compared, for a summary of the proposed
development standards for each alternative.
(McCullough Hill PLLC public comment, continued)
Ground-floor commercial: We are supportive of the City’s vision for mixed-use buildings that contain
ground-floor commercial uses to support an active 18-hour environment. The FEIS should study a range
or flexible amount of ground-floor retail in new buildings. At present, the cost of development of any
required ground-floor commercial space in this location would be assigned to residential units for the
purposes of underwriting due to current lack of demand for retail space. However, demand will grow
over time as the subarea develops, and new residents move in. The FEIS and future zoning should reflect
this reality by containing flexible ground-floor requirements.
Note that the mixed-use development standards in the current Code contain a 40% ground-floor
commercial requirement. This threshold is not financially feasible in buildings with larger floor plates.
The FEIS should study some amount of commercial uses at the ground-level focused on street frontages
on large sites, but implementing zoning should allow the City to approve less than 40% ground floor
commercial on a case-by-case basis.
Also, the 20-foot ground-floor story height articulated in the Draft EIS (pg. 1-5) is not realistic or feasible.
The Final EIS should assume 15-foot ground-floor story heights.
Staff Response:
While a substantial amount of housing is anticipated in the area, the area is zoned for commercial
land uses and it is important for the city to require commercial space be created for the sake of
economic development, livability, and creating a vibrant mixed-use district envisioned by the
Subarea Plan. Commercial uses are necessary for successful TOD so residents can use a variety of
transportation modes to access services, shopping, and other commercial uses (i.e., commercial uses
in TOD is critical to promote less auto-dependence for residents). While the vision of the area as a
vibrant mixed-use district will not be realized in the near-term, the cumulative effects of requiring
development to provide ground floor commercial, public open spaces, mixed-income housing, and
Page 5 of 10 March 4, 2024
quality urban design, are critical to help make the vision a reality; however, if such aspects of
development are not required (in addition to identified mitigation measures) the potential of
realizing the vision of the Subarea Plan is severely diminished.
The city’s current mixed-use development standards (e.g., 40% floor plate requirement, 20-foot tall
podium height, etc.), applied to all commercial zones, were carefully considered before they were
adopted in 2018 and were in response to commercial zones being developed with only a modicum of
commercial space. The decision to base the amount of commercial space required on a percentage of
the building footprint was chosen, in part, because it can be applied uniformly and it incentivizes
smaller building footprints, which can result in buildings that allow more sunlight to penetrate public
realms and more opportunities for pedestrian connections. Per RMC 4-4-150.F, modifications to the
city’s mixed-use development standards are allowed on a case-by-case basis.
(McCullough Hill PLLC public comment, continued)
Air and Sound Quality: The DEIS describes a 500-foot “buffer” from I-405 to mitigate air and sound
impacts to residential uses. Pg. 1-12; 1-18. We are concerned that future requirements with in this
buffer would create added costs to housing or even make housing development infeasible, undermining
the purpose of the TOD.
Air quality and sound issues are adequately addressed by the new state Building Code, and do not
require any additional mitigation in the zoning code. There is no explanation in the DEIS for why the
buffer should be 500-feet from I-405, but we note this would encompass the majority of the Triton
Tower One site where we contemplate possible residential development. The DEIS does not identify
existing conditions that require any such buffer, nor does it identify the impacts to housing
development. The TOD Subarea is, by its nature, near major transit corridors. Since the primary purpose
of the TOD Subarea is to leverage transit investments by locating dense multifamily housing within the
subarea, the City should avoid imposing additional costs or restrictions on residential development. We
are supportive of landscaping within the Subarea to mitigate air and sound quality issues.
Staff Response:
The following excerpt from the DEIS is found on page 3-28. The Subarea Plan recommends a buffer
from I-405 for residential development, site and building design features to mitigate impacts,
centralized air filtration systems, air intake vents located away from polluted areas, continuous
sound walls with vegetation along I-405, and consideration of the California Environmental
Protection Agency’s – Air Resources Board: Strategies to Reduce Air Pollution Exposure Near High-
Volume Roadways (April 2017, pages 20-39).
Air Quality and Noise Compatibility
Pollution Sources
The air and noise pollution sources most relevant to this study include aircraft at the Renton
Municipal Airport and roadway traffic such as along I-405. Aircraft landing and take-off paths see
concentrated air pollutants and noise impacts. Roadways see air pollution from vehicle exhaust and
brake/tire/road wear. Pollutant particle size, topography, and wind patterns affect the geographic
Page 6 of 10 March 4, 2024
extent of concern, with the greatest impacts adjacent to and downwind of major freeways. Some
patterns include:
▪ Pollutants are most concentrated within 500 ft of a roadway. Within that 500 feet,
ultrafine particles “rapidly decay” to a 50% concentration (UW Mov-Up Report, 2019, p 38).
▪ Areas within 1,000 – 1,600 ft of a busy highway are most affected by a range of pollutants
and particle sizes (American Lung Association).
▪ Close, long-term exposure (within 165 feet) to a heavily trafficked roadway has the
strongest association with dementia (American Lung Association).
(McCullough Hill PLLC public comment, continued)
Rolling Hills Creek: The DEIS identifies daylighting Rolling Hills Creek as a mitigation measure for “the
unintended effects of burying or covering rivers and streams including an increase in nutrient
contamination, the degradation of ecosystems and an increase in downstream floods.” Pg. 1-23. Since
Rolling Hills Creek has a been a piped stream for decades, it is a pre-existing condition that does not
justify SEPA mitigation such as daylighting as a condition of new development. Under the current zoning
code, daylighting would impose a 75-foot buffer, and additional 15 structure setback on the Triton
Tower One site. This would reduce the size of proposed residential development on this site, which is
also constrained by existing utilities easements.
The DEIS states daylighting the creek would not result in reduced development potential if residential
density transfer is allowed. That assumption is incorrect since the allowable density in this location is not
a limiting factor and towers are not feasible in this location. We encourage the City to incentivize
environmental improvements including landscaping, and which may include off-site or nearby critical
areas mitigation instead of requiring creek daylighting that would impose significant buffer constraints
on the Property. The trade-off for daylighting a portion of a creek in this location near the highway
would be to preclude a significant amount of housing development within the Subarea for minimal
benefit to the public. We ask the City to remove this recommendation from the Final EIS.
Staff Response:
The DEIS does not propose requiring daylighting of Rolling Hills Creek. The following is from the DEIS
and provides a summary of the intent for the Planned Action Ordinance.
“A portion of Rolling Hills Creek is currently piped underneath development. It should be noted that
daylighting the creek or portions of the creek would allow for an increased impervious surface lot
coverage per RMC 4-3-050 section 7f-ii. This is a viable option to improve existing conditions as well
as benefit the developer. The City code allows for, but does not specify, incentives for developers to
daylight streams. The City should consider implementing specific incentives to encourage developers
to daylight portions of Rolling Hills Creek to restore more natural habitat to the area.”
(McCullough Hill PLLC public comment, continued)
New Street Network: We are generally supportive of increased connectivity within the Subarea but it
should not have the end result of precluding housing production. We appreciate and continue to
Page 7 of 10 March 4, 2024
support the note on the Conceptual Illustration of New Street Network Map (Exhibit 3-71) that new
street locations are conceptual only. Exact street locations should be determined as the Subarea
develops based on site-specific conditions and proposals during project-level review. The Final EIS
should assume that streets on private property may remain private, and street sections should also
remain flexible and be reviewed by the City at project-level entitlements.
Staff Response:
The Subarea Plan established the concept of a new street network within Renton Village. The
Subarea Plan identifies the general location of future streets as well as the features and dimensions
of the streets, which were designed specifically for the area. While the exact locations of the
proposed streets will be determined during the entitlement process, the need for a street network
and streets designed for TOD is clearly demonstrated by the Subarea Plan and the DEIS. Similar to all
newly created streets in the city, the exact specifications of new streets are provided by Renton
Municipal Code (See RMC 4-4-060, Street Standards) which also provides the means for variations
from the adopted standards on a case-by-case basis.
Testimony #2
From: Nancy Sackman, Cultural Preservation Officer, on behalf of the Duwamish Tribe
Date: February 22, 2024
VIA EMAIL
See Attachment 1
Testimony #3
From: Andres Artze
Date: February 21, 2024
VIA EMAIL
My name is Andres Artze and I'm a resident of Renton, WA (98055). I called into the Planning Committee
meeting this evening, but was unable to leave a comment on the call. I just wanted to voice my support
for the Renton Village TOD concept and hope you move forward with Alternative 3 to support the
sustainable addition of new housing and businesses to the downtown Renton area.
As mentioned by one of the council members during the meeting, I'm also concerned about the safety
and speed of traffic moving along Grady Way. However, I think that moving the Transit Center is more
focused on accommodating the effects without addressing the cause. Instead, I would hope to see
future improvements to the road that would include traffic-calming devices such as chicanes and speed
cushions to discourage speeding altogether.
Beyond that, as part of the improvements it would be great to see bike connections to the Burnett
Linear Park and the Benson Rd S bike lanes. While Burnett connections were addressed, I didn't see any
paths leading to Benson Rd S. I'd also hope that it's a priority to keep many of the existing local
businesses in the area (such as Uwajimaya) supported throughout the construction process, as many
have been a staple of our community for some time.
Page 8 of 10 March 4, 2024
Thank you for you and your team's work on developing this EIS. It's clear the document was crafted with
a lot of concern and consideration for the community. It's great to see such meaningful development
come to our city and it makes me proud to live in such a thoughtful and forward-thinking community.
Testimony #4
From: Zanna Satterwhite (she/her), Environmental Planner, on behalf of King County Wastewater
Treatment Division
Date: February 21, 2024
VIA EMAIL
See Attachment 2
Testimony #5
From: Thi Markwell (She/Her), Transit Environmental Planner II, on behalf of King County Metro
Date: February 8, 2024
VIA EMAIL
King County Metro received the notice, "City of Renton Notice of Availability: Draft Environmental
Impact Statement (Draft EIS) for the Rainier/Grady Junction Transit Oriented Development (TOD)
Subarea Planned Action, LUA22-000289" and have routed it for internal review. Please see the below
comment/request:
All construction and other work activity affecting King County Metro Transit Operations or Facilities
must be coordinated through the KCM System Impacts workgroup. Please contact them to provide
specific information related to the activity and allow the required lead time necessary for responding to
any impacts caused by it. For notification information and guidelines please visit:
http://www.kingcounty.gov/transportation/kcdot/MetroTransit/Construction.aspx or phone
206.477.1140 or 206.477.1150 for Trolley-related activities.
For all contractors:
After we receive your project information, we require a minimum five business days’ notice before the
start of work. Ten days are required for street closures or transit detours. Please note that different
requirements apply if your work impacts trolley or streetcar lines.
This allows us to plan mitigation, coordinate with other projects, and notify our customers.
Please see our website for notification guidelines and other resources.
We require the following information for each project:
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1. The approved Street Use Permit and Traffic Control Plan (TCP that includes the reviewer's name
and approved date) for the project (please attach a pdf) – Please provide
2. Location of the project – Please Provide
3. Is this work part of multiple phases? If so, please send a separate email for each phase.
4. Locations of any bus stops that will need to be relocated, whether they need to be closed during
the entire duration of your project or if they can safely be used when you are not working – Please
Provide
5. Name and cell phone numbers of the primary and alternate onsite contacts – Please Provide
6. Start and end dates of the project. – Please Provide
a. Weekdays only? – Please Provide
7. Daily start and end time of work – Please Provide
8. Is your work weather dependent? - Please provide
9. Nature of the work – Please Provide
10. Company name – Please Provide
Your project is not approved. You will be notified in writing after your project is approved. We will
contact you if we require additional information or T-39 No Parks.
If your project is located in a SDOT Construction Hub, you must receive Hub approval.
Testimony #6
From: Jeff Kelly
Date: January 26, 2024
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See Attachment 3
Testimony #7
From: Ion Tamasan
Date: January 30, 2024
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As a resident of Renton, I fully support and prefer Alternative 3 over the other options. We need more
housing, more jobs, more foot traffic activity, and we have an excellent opportunity to build a walkable
neighborhood with restaurants/bars/entertainment. Alternative 3 will produce more revenue for the
city that can be allocated into more similar projects and accumulate revenue like a snowball effect and
make Renton an economic powerhouse/popular place.
Please move forward with Alternative 3.
Testimony #8
From: Philip R. LaFranchi
Date: January 27, 2024
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I’m looking forward to added density in this underutilized area of Renton. I think it would serve the city
well to have closed pedestrian streets where retail is located, especially with outdoor activities, parks,
fountains, dining.
Also, if Renton wants to follow the lead of upzoning (see Vancouver suburbs and Bellevue) then there is
a real opportunity to create tall slender residential buildings to allow more light at ground level. One
thing I don’t want to see is boxy-bulky buildings. Ones that have good character and design will do well
for the image of Renton. 14 stories is a good start, I wouldn’t mind seeing buildings up to 20-25 floors.
Get as much residential in near transit as possible. It will create a real destination in Renton and keep
the area active.
STAFF RECOMMENDATION
Staff recommends Alternative 2, Incentive-Based Growth, be considered as the preferred alternative.