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HomeMy WebLinkAboutJ_Thunder Hills_Protected Slope Exemption.pdfFrom: Rettmann, Kristi <kristi.rettmann@stantec.com> Sent: Thursday, December 13, 2018 5:40 PM To: Jill Ding Cc: David Christensen; Ann Fowler; Wolf, Brian Subject: RE: Thunder Hills Sewer Rehabilitation Hi Jill, Brian Wolf (PE) delved a bit deeper into the amount of road improvements that actually expand into protected slope areas. We started with identifying all areas where we are expanding the road and then where those areas area actually 40% or greater slopes. The amount of road improvements that actually extends into protected slope areas is only about roughly 1,000 square feet. The remaining expanded impervious area that was described in response to SEPA question you noted below, is grading and rockery improvements and not actually new road expansion or improvements. One note of interest, they looked at that turnaround area closer in CAD. Surprisingly, this area is actually just under 40% grade, so not truly a protected steep slope classification. Please feel free to call me and discuss if you have further questions. Kristi Rettmann, M.Sc., CESCL Environmental Scientist Direct: 425.289.7338 Mobile: 425.214.3901 kristi.rettmann@stantec.com Stantec Consulting Services Inc. 11130 NE 33rd Place Suite 200 Bellevue WA 98004-1465 US The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately. From: Jill Ding <JDing@Rentonwa.gov> Sent: Thursday, December 13, 2018 6:20 AM To: Rettmann, Kristi <kristi.rettmann@stantec.com> Cc: David Christensen <Dchristensen@Rentonwa.gov>; Ann Fowler <AFowler@Rentonwa.gov>; Wolf, Brian <brian.wolf@stantec.com> Subject: RE: Thunder Hills Sewer Rehabilitation Kristi, Since the existing access road totals 27,780 square feet, I would read the code to imply that you could not expand more than 2,778 square feet into protected slope areas. Can you confirm that this is correct? Thanks, Jill From: Rettmann, Kristi [mailto:kristi.rettmann@stantec.com] Sent: Wednesday, December 12, 2018 2:07 PM To: Jill Ding <JDing@Rentonwa.gov> Cc: David Christensen <Dchristensen@Rentonwa.gov>; Ann Fowler <AFowler@Rentonwa.gov>; Wolf, Brian <brian.wolf@stantec.com> Subject: RE: Thunder Hills Sewer Rehabilitation Hi Jill, I just left a voicemail, but thought I’d followup with email in case this gets to you faster. We have identified and quantified the amounts of the road improvements that are within protected slope areas (those at 40% or higher). In the code you cited, it doesn’t seem to indicate of what 10% is meant: “The work does not increase the footprint of the structure, line or street by more than ten percent (10%) within the critical area and/or buffer areas, and occurs in the existing right-of-way boundary or easement boundary.” By that, I mean should we be totaling up all protected slope areas within the construction boundary (project area), or within the entire ravine to compare to the amount we know we’ll be encroaching into the protected slope areas? Please advise or give me (work cell) or Brian Wolf (425 289-7328) a call and we can sort this out ASAP. Thanks, Kristi Kristi Rettmann, M.Sc., CESCL Environmental Scientist Direct: 425.289.7338 Mobile: 425.214.3901 kristi.rettmann@stantec.com Stantec Consulting Services Inc. 11130 NE 33rd Place Suite 200 Bellevue WA 98004-1465 US The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately. From: Jill Ding <JDing@Rentonwa.gov> Sent: Wednesday, December 12, 2018 6:23 AM To: Rettmann, Kristi <kristi.rettmann@stantec.com> Cc: David Christensen <Dchristensen@Rentonwa.gov>; Ann Fowler <AFowler@Rentonwa.gov>; Wolf, Brian <brian.wolf@stantec.com> Subject: RE: Thunder Hills Sewer Rehabilitation Kristi, It looks like most of the areas of widening the road occur where there are turnaround improvements, are those areas within Protected Slopes? Thanks, Jill From: Rettmann, Kristi [mailto:kristi.rettmann@stantec.com] Sent: Tuesday, December 11, 2018 10:38 AM To: Jill Ding <JDing@Rentonwa.gov> Cc: David Christensen <Dchristensen@Rentonwa.gov>; Ann Fowler <AFowler@Rentonwa.gov>; Wolf, Brian <brian.wolf@stantec.com> Subject: RE: Thunder Hills Sewer Rehabilitation Hi Jill, Thank you for clarifying your question/concerns. We have spoken internally and are trying to figure out how to demonstrate these protected slope areas (areas with grades that exceed 40 percent) are or are not greater than 10%. The vast majority of the improvements are within the existing gravel maintenance access road, and some of this road over time (as Dave noted below) was wider but has been altered/reduced naturally. Any improvements are to restore the road to what it was and to make access to the sewer system for periodic maintenance easier and safe. However, in the event that we do need a variance, can you please provide the documentation/permit required and how long this would take to obtain? We just want to be prepared in the event we have to go down this path. Thanks, Kristi Rettmann, M.Sc., CESCL Environmental Scientist Direct: 425.289.7338 Mobile: 425.214.3901 kristi.rettmann@stantec.com Stantec Consulting Services Inc. 11130 NE 33rd Place Suite 200 Bellevue WA 98004-1465 US The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately. From: Jill Ding <JDing@Rentonwa.gov> Sent: Tuesday, December 11, 2018 9:08 AM To: David Christensen <Dchristensen@Rentonwa.gov>; Rettmann, Kristi <kristi.rettmann@stantec.com> Cc: Ann Fowler <AFowler@Rentonwa.gov> Subject: RE: Thunder Hills Sewer Rehabilitation Dave, I just need to verify that where the improvements to the maintenance/access road are expanding within the Protected Slope areas that this portion of the expansion is less than 10 percent. My hope is that the majority of the expansion of the maintenance/access road improvements are in areas that are not classified as protected slopes and that the expansions within the Protected Slope areas are minimal. I just need to be able to make this finding for the Environmental Review Committee. Thanks, Jill From: David Christensen Sent: Tuesday, December 11, 2018 8:43 AM To: Jill Ding <JDing@Rentonwa.gov>; 'Rettmann, Kristi' <kristi.rettmann@stantec.com> Cc: Ann Fowler <AFowler@Rentonwa.gov> Subject: RE: Thunder Hills Sewer Rehabilitation Jill, This is the typical issue we have when we try and compare a utility project with a development. In this case, if we look at the impervious area addition compared to the “site”, the properties that are within where we have our sewer main running, we are probably less than 1% of the total site for impervious, we are running a sewer line and access road adjacent to an existing creek. Again, I think our description may need a tweak, we are actually operating under a maintenance activity, simply re- establishing the maintenance road that previously existed, not adding any new impervious compared to our previous use. We simply did not maintain the existing and mother nature swallowed a portion of the existing, In addition, we are armoring in locations to assure the long term ability for us to utilize this maintenance road. Should we maybe adjust language to clarify? Thanks for all your help! Dave C. From: Jill Ding Sent: Tuesday, December 11, 2018 8:28 AM To: David Christensen; 'Rettmann, Kristi' Cc: Ann Fowler Subject: RE: Thunder Hills Sewer Rehabilitation The reason for my concern was this description within the SEPE checklist, which indicates at 23% increase in access road area: g. About what percent of the site will be covered with impervious surfaces after project construction (for example, asphalt or buildings)? The existing gravel maintenance access road/trail is approximately 27,780 square feet (sf). Proposed gravel improvements will expand this to approximately 34,161 sf, adding approximately 6,981 sf of new gravel maintenance access road/trail. The existing portion of the maintenance access road/trail that is paved (asphalt) is approximately 1,713 sf. Proposed improvements will expand this paved (asphalt) surface to approximately 5,439 sf, adding approximately 3,726 sf of new asphalt. The percent of impervious surfaces (asphalt) after project construction is approximately 5%. From: David Christensen Sent: Monday, December 10, 2018 3:30 PM To: Jill Ding <JDing@Rentonwa.gov>; 'Rettmann, Kristi' <kristi.rettmann@stantec.com> Cc: Ann Fowler <AFowler@Rentonwa.gov> Subject: RE: Thunder Hills Sewer Rehabilitation We should qualify for this exemption as our footprint for the utility will not grow at all, this is a repair/maintenance project, not new or enlargement. The grading/walls are only needed to assure that our access road is maintainable and safe. Dave C. From: Jill Ding Sent: Monday, December 10, 2018 2:29 PM To: 'Rettmann, Kristi'; David Christensen Cc: Ann Fowler Subject: RE: Thunder Hills Sewer Rehabilitation Hi Kristi, The challenge is that alterations (i.e. grading and the installation of retaining walls) to slopes that exceed a grade of 40 percent are not permitted in our code without a variance, unless you qualify for an exemption. I found an exemption in our code that states the following: 16. Overbuilding (enlargement beyond existing project needs) or replacement of existing utility systems and replacement and/or rehabilitation of existing streets, provided: a. The work does not increase the footprint of the structure, line or street by more than ten percent (10%) within the critical area and/or buffer areas, and occurs in the existing right-of-way boundary or easement boundary. b. Restoration shall be conducted where feasible. Compensation for impacts to buffers shall include enhancement of the remaining buffer area along the impacted area where there is enhancement opportunity. c. The Administrator determines that, based on best judgment, a person would not: (i) be able to meaningfully measure, detect, or evaluate insignificant effects; or (ii) expect discountable effects to occur. d. This exemption allows for ten percent (10%) maximum expansion total, life of the project. After the ten percent (10%) expansion cap is reached, future improvements are subject to all applicable provisions of this Section. Based on the information provided, I am unable to verify whether this project meets the exemption criteria within the protected slope areas or not. I am fairly confident that your proposal would be exempt from the stream and wetland requirements as it doesn’t appear that any expansions would exceed 10 percent within these areas. I was hoping you could tell me whether or not you qualify for this exemption within the protected slope areas. If you do not, I will need to put the review of this project on hold and have you apply for a Reasonable Use Exception.\ Let me know if you need further clarification and we can discuss via phone tomorrow. Thanks, Jill From: Rettmann, Kristi [mailto:kristi.rettmann@stantec.com] Sent: Monday, December 10, 2018 2:04 PM To: Jill Ding <JDing@Rentonwa.gov>; David Christensen <Dchristensen@Rentonwa.gov> Cc: Ann Fowler <AFowler@Rentonwa.gov> Subject: RE: Thunder Hills Sewer Rehabilitation Hi Jill, I got some feedback. Where we have steep slopes in the project, we are either doing some grading work or we are installing a rock wall. Would it be easier if we were to take our plans and somehow highlight those areas and make note of (or show in two different colors) these areas and what we are doing (either rock wall or grading)? Just trying to get a sense of exactly what we can do to answer your question or make the improvements we are proposing in steep slope areas more clear. We can also be available for a call to discuss further, so let us know. Thanks, Kristi Kristi Rettmann Environmental Scientist Direct: 425 289-7338 kristi.rettmann@stantec.com Stantec 11130 NE 33rd Place Suite 200 Bellevue WA 98004-1465 The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately. From: Jill Ding <JDing@Rentonwa.gov> Sent: Monday, December 10, 2018 12:54 PM To: Rettmann, Kristi <kristi.rettmann@stantec.com>; David Christensen <Dchristensen@Rentonwa.gov> Cc: Ann Fowler <AFowler@Rentonwa.gov> Subject: RE: Thunder Hills Sewer Rehabilitation Thanks Kristi! From: Rettmann, Kristi [mailto:kristi.rettmann@stantec.com] Sent: Monday, December 10, 2018 12:52 PM To: Jill Ding <JDing@Rentonwa.gov>; David Christensen <Dchristensen@Rentonwa.gov> Cc: Ann Fowler <AFowler@Rentonwa.gov> Subject: RE: Thunder Hills Sewer Rehabilitation Hi Jill, My ears were not burning but I guess they should have been. I literally just left you a voicemail about SEPA determination status. I will chat with our EITs so that I can answer your question. Thanks, Kristi Kristi Rettmann, M.Sc., CESCL Environmental Scientist Direct: 425.289.7338 Mobile: 425.214.3901 kristi.rettmann@stantec.com Stantec Consulting Services Inc. 11130 NE 33rd Place Suite 200 Bellevue WA 98004-1465 US The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately. From: Jill Ding <JDing@Rentonwa.gov> Sent: Monday, December 10, 2018 12:10 PM To: David Christensen <Dchristensen@Rentonwa.gov>; Rettmann, Kristi <kristi.rettmann@stantec.com> Cc: Ann Fowler <AFowler@Rentonwa.gov> Subject: Thunder Hills Sewer Rehabilitation Dave/Kristi, Could you outline for me what improvements are proposed within the protected slope areas (areas with grades that exceed 40 percent)? I am concerned that the proposed retaining walls and improvements to the access road would exceed the 10 percent exemption allowance and would instead trigger a variance. Jill Ding Senior Planner City of Renton Community and Economic Development 6th floor 1055 S Grady Way Renton, WA 98057 425-430-6598 jding@rentonwa.gov