HomeMy WebLinkAboutExhibit 8_J_VarianceJustification_Fencing_SSeattleGateStation
Puget Sound Energy
P.O. Box 97034
Bellevue, WA 98009-9734
PSE.com
April 2nd, 2024
City of Renton
Planning Division
RE: PSE South Seattle Gate Station Security Upgrades, Fence Variance Justification
PSE is seeking variance approval under Renton Municipal Code (RMC) 4-9-250-B to exceed the fence height
restrictions listed in RMC 4-4-040 FENCES, HEDGES, AND RETAINING WALLS in order to support security
upgrades at PSE’s South Seattle Gate Station located at 730 S. 21st Street (parcel #s 7222000070 and
7222000071). The gate station is located on the northwest corner of S. 21st Street and Benson Drive S (SR-
515).
Background
The South Seattle Gate Station receives gas from the William’s transmission pipeline which is then transferred to
PSE’s gas distribution pipelines on the site to serve the region. The South Seattle Gate Station has been
operating in its current location since 1957 and has a network of underground pipes that distribute natural gas
across the region. The site is developed with utility accessory buildings that are up to 15 feet in height, above the
existing fence height. The site is also developed with above ground pipelines that are visible from road right-of-
way. This district regulator supports the City of Renton and surrounding region.
The South Seattle Gate Station is situated within a single-family residential zoning district, Residential-8 (R-8) and
is connected to underground gas infrastructure including the Williams pipeline that enters the site from the east and
a number of PSE distribution gas pipelines that go north, east and west from the site. The existing PSE Gate Station
was legally established in 1957, when the property was located in unincorporated King County and prior to adoption
of current zoning regulations. The gas gate station is a conditional use in the R-8 zoning district and is defined as
a “large utility” under RMC 4-11-210 Definitions U. Between 1957 and present day the properties around the gate
station to the north, west and south have undergone residential development consistent with the R-8 zoning. The
several acre property to the east is also developed with a non-residential utility use and is also owned by PSE.
The adjacent parcel to the north includes single-family residential development; however is approximately 280
feet from the developed gate station and is separated from the developed portion of the gate station site by a
large forested area. The property to the west is a City park with tennis courts. The closest residential development
sits approximately 87 feet from the southern fence line of the gate station across S. 21st Street. The housing
across S. 21st was developed in 2008 and the owners purchased the homes with the understanding that the
existing gate station was located to the north of their property.
Benson Drive S. is a state highway and a principal arterial and S. 21st Street is a collector street. The gate station
sits in the southeast corner of the site and is currently surrounded by a 6 foot high chain link fence with (12
inches) of razor wire on top. The site slopes up to S. 21st Street. Benson Drive S. and portions of S. 21st Street
sit above the site and the paved surface is separated from the grass shoulder by a jersey barrier. There is a
slope and rock wall between the grass shoulder and the gate station fence within road right-of-way. As the site
slopes towards S. 21st Street, the surrounding roadways become more elevated above the site and the top of the
fence becomes closer to the grade of the top of the rockery and the same height of the jersey barrier that wraps
around to S. 21st Street. Near the corner of Benson Drive S. and S. 21st Street, the fence sits on an existing
concrete wall of varying heights (see photos in exhibit PN_Site_Photos). The gate station site is accessed via a
driveway off of S. 21st Street.
Request
RMC4-4-040-D limits the height of fences within residential zoning districts to 72 inches (6 feet) above grade. On
the north, west, and south sides of the gate station site PSE is proposing to replace the existing 6 foot tall fence
with an 8 foot tall mesh security fence with 4 inches of anti-climbing ribbon. A section of the fence is proposed to
be 14-feet 4-inches along the east side of the gate station, facing the intersection of Benson Drive S and 21st
Street due to the site sitting significantly lower than the surrounding road rights-of-way. This height includes an
existing 6- foot high concrete retaining wall (height varies from 1-foot to 6-feet along Benson Drive S.) that the
fence will be mounted to that supports soils between the station and Benson Drive S. Along the East side, the
new fence reaches above the existing grade of Benson Drive S. at variable heights as illustrated in the renderings
(see Exhibit PN_Visual_Renderings), resulting in a variable “perceived fence height” of anywhere between 8 feet
and 3 feet above existing adjacent roadway and barrier. Along the east side of the gate station, existing power
lines are located within road right-of-way and the fence faces Benson Drive, which is elevated above the existing
grade of the gate station, separated by a grass covered and partially vegetated 6 foot tall fill slope as well as a
rockery wall that supports Benson Drive S. soils. In addition, an existing concrete barrier at the back of sidewalk
along the corner of Benson Drive S. and S. 21st Street partially obscures the view of the gate station from passing
motorists and pedestrians.
PSE is proposing a new black powder-coated fence, that is 14 feet 4 inches tall at its tallest height (height
includes an existing concrete wall that the fence will be mounted to that supports soils between the station and
Benson Drive), with 4 inches of ribbon strip on top. Along the East side of the gate station, the new fence reaches
above the existing grade of Benson Drive S. at variable heights as illustrated in the visual simulations below,
resulting in a variable “perceived fence height” of anywhere between 8 feet and 3 feet above existing adjacent
roadway and barrier features.
The requested variance is essential for security of the existing South Seattle Gate Station. The Gate Station
serves a critical function in the areas gas distribution and pressure regulation system that serves the region. The
Transportation Security Administration (TSA) and PSE personnel have established a process to identify and
evaluate infrastructure vulnerabilities. As a result of this process, TSA recommended that PSE add height above
the existing fence height in order to better protect this valuable asset.
The additional fence height will obscure lines of sight and access into the gate station deterring potential
delinquent or unlawful threats to the gate station, while still providing enough transparency to see potential illegal
encampments surrounding the gate station on the undeveloped portion of the site. The dental strip (about 4-
inches) on top of the fence will prevent any potential threat of climbing over the fence into the gate station. PSE
will not be impacting the existing landscaping and rockery, which the mature ornamental landscaping provides
screening from public roadways and walkways.
Figure 1 (above) and 2 (below) are visual simulations of the proposed fencing with the additional two feet.
RMC 4-9-250 VARIANCES, WAIVERS, MODIFICATIONS, AND ALTERNATIVES
B. VARIANCE PROCEDURES:
6. Decision Criteria: Except for variances from critical areas regulations, a determination shall be made in writing
that the conditions specified below have been found to exist:
1. That the applicant suffers practical difficulties and unnecessary hardship and the variance is necessary
because of special circumstances applicable to subject property, including size, shape, topography,
location or surroundings of the subject property, and the strict application of the Zoning Code is found to
deprive subject property owner of rights and privileges enjoyed by other property owners in the vicinity
and under identical zone classification;
Response: The South Seattle Gate station is located within the R-8 zoning district, which limits fence
height to 72 inches (6-feet). The strict application of the zoning code, which imposes a fence height
applicable to the residential development, is not practical or safe for a gas utility gate station use, which is
a conditional use in the R-8 zoning district and establishes special circumstances on the subject property
not typical of residential development. The existing gate station facility on the site is currently surrounded
by a 6-foot high chain link fence, which no longer meets Transportation Security Administration (TSA) and
PSE safety, security, and compliance standards; standards of which are unique to this type of use and do
not apply to residential development. In response to the need for heighten security at this location, TSA
has recommended additional fencing height.
Without the variance, PSE would not be able to securely operate critical utility infrastructure and
implement federal recommendations for safety. Due to the unique nature of the gate station as an
established use within the R-8 zone; it is not practical or safe for this critical gas utility infrastructure to be
subject to the same use standards as single-family residential uses in the same zoning district.
The gate station site sits below the grade of the surrounding road rights-of-way, in some areas 6 feet or
more, with the property line being at the base of the slope or rockery located within the adjacent road
right-of-way. The purpose of the fence is for screening and security. A fence that is installed at the base
of the slope/rockery, like the existing 6 foot fence, does not provide site screening due to the difference in
elevation of the surrounding road rights-of-way that sit above the site. Residential fencing in the area,
including fencing around the development to the south of the site, is constructed from grade that is closer
in elevation to the surrounding rights-of-way, including Benson Drive S., a state highway, which is not
indicative of a residential street. Some residential fencing is also installed atop rockeries adjacent to the
right-of-way. Allowing PSE to install a fence that is 8 – 14 feet from grade will result in a fence height that
is similar in height along the road rights-of-way to fences in the vicinity of the site.
2. That the granting of the variance will not be materially detrimental to the public welfare or injurious to the
property or improvements in the vicinity and zone in which subject property is situated;
Response: The granting of the variance will not be materially detrimental to the public welfare or injurious
to the property or improvements in the vicinity or zone. The goal of the project is replace the existing
fence in its existing location with a taller fence based on security recommendations from the TSA. The
black powder coating will also minimize the new fencing while providing the additional security needed.
There will not be any expansion of the gas gate station. The new fence will be installed in the same
location as the existing fence. The gas gate station has been at this location since 1957 when the
property was within unincorporated King County. The closest single-family residential development is to
the south of the site across S. 21st Street, which was constructed in 2008. The gate station is screened
from surrounding development to the north and west by large forested areas on the site. PSE is not
changing the use of the site and since the fence will be taller and of a mesh material, will screen the gate
station site more than the existing 6 foot tall chain link fence. The purpose of installing taller fencing
around the gate station is to secure the site from potential nefarious activities, which is in the best interest
of the public welfare.
3. That approval shall not constitute a grant of special privilege inconsistent with the limitation upon uses of
other properties in the vicinity and zone in which the subject property is situated;
Response: The granting of the variance will not constitute a special privilege inconsistent with other
properties in the vicinity. The gate station site sits lower in elevation from the surrounding road rights-of-
way than surrounding residential properties. Residential properties to the south of the site across S. 21st
Street have yards that face S. Benson Drive, a state highway, that are fenced for privacy and screening.
PSE is requesting to replace an existing fence with a fence that is taller, but will be set below the grade of
the surrounding rights-of-way, making the roadside fence elevation lower in height than the property side
fence elevation and similar in height to fences on residential properties that are adjacent to Benson Drive
S. The replacement fence will be a mesh material for security of the site, but will also serve to screen the
site better than the existing chain link fence which is more transparent.
4. That the approval is a minimum variance that will accomplish the desired purpose.
Response: The proposed height is the minimum height to most effectively protect and secure the gate
station, meeting TSA recommendations and PSE security standards.
Based on a pre-application letter issued by the City of Renton Department of Community and Economic
Development on August 10, 2023 for the proposed fence replacement project, PSE has been asked to
address the following additional criteria:
1. Landscaping: Please note that residential zones require 10 feet of onsite landscaping along all public
street frontages. Any variance to the fence standards may require a landscape screen between the right-
of-way and proposed fence.
Response: Per RMC 4-10-020 NONCOMFORMING SITE DEVELOPMENT STANDARDS, subsection
C, “Remodels or other alterations within any three (3) year period that do not exceed thirty percent (30%)
of the assessed or appraised value shall not be required to comply with the requirements of this
subsection.” The fence replacement will not exceed 30 % of the assessed or appraised value of the
existing site improvements, therefore the landscaping does not need to be brought into conformance with
the current landscape regulations.
2. Clear Vision Area: The fence proposed for special permits shall have no portion in the clear vision area
over forty-two inches (42”) in height. The location and height of the fence must not obstruct views of
oncoming traffic, or views from the driveway. The applicant will be required to show compliance with
this requirement in the variance application.
Response: Per RMC 4-2-110B DEVELOPMENT STANDARDS FOR RESIDENTIAL DEVELOPMENT
(DETACHED ACCESSORY BUILDINGS), no structures over 42 inches in height can intrude into the 20
foot clear vision area defined in RMC 4-11-30 in residential zoning districts, including R-8. RMC 4-11-30
defines clear vision area as, “the area bounded by the street property lines of corner lots and a line joining
points along said street lines twenty feet (20’) from their point of intersection.” PSE has depicted the Clear
vision triangle on the submitted plans with this application. The 20 foot clear vision area on the Gate
Station property is located at the intersection of Benson Drive S. and S. 21st Street. Since the property
line is at an angle at the intersection, the 20 foot clear vision area falls outside the property lines and is
located within road right-of-way, so no portion of the proposed fence will fall within the clear vision area.
References:
TSA 2018. U.S Department of Homeland Security, Transportation Security Administration, Pipeline Security
Guidelines, March 2018 (with Change 1 (April 2021).