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HomeMy WebLinkAboutExh.22_SEPA_Reconsideration.pdfCITY OF RENTON I ;";+FO OCT 0 4 2018 ti-tt) RECEIVED CITY CLERK'S OFFICE Environmental Review Committee Department of Community & Economic Development 1055 South Grady Way Renton, WA 98057 Re: Request for Reconsideration of DNS-M Mitigation Measure 6 Forest Terrace Preliminary Plat, LAU 18-000124, ERC, PP, MOD, Dear ERC Committee members: Pursuant to RMC 4-8-100.I, Pulte Homes, as the applicant for the Forest Terrace Preliminary Plat, requests reconsideration of DNS-M Mitigation Measure 6. It is based on an error of fact and law. MDNS Condition 6 requires: The applicant shall restore the Union Ave NE roadbed (curb to curb) along the subject property's frontage to current City Standards prior to final plat recording. This ERC Report explains the reasoning for this condition as follows: Construction of the street improvements [frontage improvements on Union Avenue using modified minor arterial standards] will require trenching along both sides of Union Ave NE along the site's entire street frontage to accommodate utility installation. The applicant would be required by code to construct those trenched areas to meet the current City standards, leaving the center of the roadway substandard. The volume of dump truck trips to accommodate the large amounts of imported fill will cause degradation to the entire roadbed along the property's frontage; therefore staff recommends as a mitigation measure that the applicant restore the Union Ave NE roadbed (curb to curb) along the subject property's frontage to current City Standards prior to final plat recording. ERC Report, page 9. The ERC Report is based on the erroneous assumption that we will be installing sewer on the east side Union Ave NE. However, that is not possible as there is simply not enough room left on the east side to install a new sewer main while achieving proper clearances from the other utilities. Thus, the Forest Terrace Plat will not be constructing sewer along the east side of Union Ave NE and will not require trenching along both sides of Union Ave NE. We understand that the City prefers that new sewer mains be installed within the right-of-way and be placed either perpendicular to or parallel with the roadway. We learned of that preference on October 2 and are investigating alternatives that satisfy it. See the enclosed sewer and water plan and profile which locates the new sewer main within the right-of-way and has only a short diagonal stretch from Union Avenue NE to the plat road, NE 271h Pl. The concern about the impact of the number of trucks using the haul route is adequately addressed by DNS-M Condition 7 which requires that Pulte Homes video the approved haul route prior to the beginning of construction and following completion of plat infrastructure to identify the existing condition and post -construction condition, respectively. Pulte is required to repair the roadway to a condition equal to or better than the pre -construction condition. SEPA mitigation measures must be related to a specific, adverse environmental impact clearly identified in an environmental document on the proposal. WAC 197-11-660(1)(b), adopted by reference by RMC 4-9-070.M. We have submitted no plans showing, nor do we propose to trench on the east side Union Ave NE. Responsibility for implementing mitigation measures may be imposed upon an applicant only to the extent attributable to the identified adverse impacts of its proposal. WAC 197-11-660(1)(d), adopted by reference by RMC 4-9-070.M. Pulte will construct the required half street improvements for the western half of Union Ave NE following completion of the import of fill material and will repair the eastern half street to a condition equal to or better than the pre -construction condition. There is no basis for requiring restoration of the Union Ave NE roadbed curb to curb. Therefore, we ask that the ERC remove Mitigation Condition 6, Sincerely, Kyle Lublin Pulte Group Manager, Land Planning and Entitlement Enclosure Cc: Alison Moss o Z E A v o v a o Q Er C7 4? O O aa.) 6 p y p .., c3 y . I a+ rCISv a a a lotw 7 G 7 I- Ra '' """ ! a '= p Id G N U to 04 ' 4-- w- 1 1- 4 G 3 W N Ei0 o v wco 3 ' D } , ems in = M 4, = E"' a) y . p 0 0 4 f„ o CA U D w p- I D D+ y a7 • 4? ' O of G a O W 433 R' 0 d]Cr" ctl i Q v mom: File:P:\18000s\I8396\engineering\18396-sw5.dwg Date/Time:10/4/2018 10:37 AM Scale: TSKODA Xre(: - - - - FOREST TERRACE PLAT AAANNNNNNN' 0 2 0 z T O mnrvmi> 1--4 H H D O H Cm a m C 0 Co bt x9 noWmZ> na H 0 4 m x a 03 o e 381.1 0 n 378.9 aq m xy 376.8 a o C r 374.7 o D m m A rn w m Ile 372.5 370.3 r ' m a J- r w 368.1 365.9 3 g di a U 363.6 Y, r IF r 36 0 361.6 N FOREST TERRACE F B.C.E. JOB NO. 18396 N O A SPAMA y Egli 7 3 y_9 NC yvyy Av v yy pQpQpP 21P y Q GHq(Jts i 18215 72ND AVENUE SOUTH mPf& KENT WA 98032 425)251-6222 o 0 _ 425)251-8782 FAX s GtP/* C CIVIL ENGINEERING, LAND PLANNING, ENG%*k SURVEYING, ENVIRONMENTAL SERVICES mpg C0 cm G m D D z 00 o D O -n nm I m 02y zo y Z7< ? 5/Oz 2 o Nco n ? O 1 oAb m zLo, Z mz m z m 0 p of Mm mA N 7R% yF1 p S2 IJ D®© D 9y, 9m V N 9m V y, V pp O • 0 O+ N f0 • m 00 00 O O