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HomeMy WebLinkAboutFEISConsultant Team: BERK Consulting Perteet The Transpo Group Prepared For: Rainier/Grady Junction TODSubarea Planned Action Final Environmental Impact Statement March 2024 THIS PAGE INTENTIONALLY BLANK. 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 Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-15 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-16 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 Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-17 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) Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-18 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-19 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-20 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 Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-21 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 Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-22 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-23 Exhibit 1-13. Alternative 2 Shadow Analysis, 3PM Source: BERK, 2023. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-24 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-25 Exhibit 1-14. Alternative 3 Shadow Analysis, 3PM Source: BERK, 2023. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-26 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-27 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-28 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-29 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 Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-30 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-31 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-32 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-33 ▪ 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-34 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-35 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-36 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 Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-37 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-38 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 Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-39 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-40 ▪ 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-41 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-42 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-43 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. Rainier/Grady Junction TOD Subarea Planned Action Ch. 1 ▪ Summary March 2024 ▪ Final EIS 1-44 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 consideraon 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 Applicaons and Inspecons (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 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. 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 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. 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. 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. 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: Page 9 of 10 March 4, 2024 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 VIA EMAIL See Attachment 3 Testimony #7 From: Ion Tamasan Date: January 30, 2024 VIA EMAIL 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 Page 10 of 10 March 4, 2024 VIA EMAIL 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.