HomeMy WebLinkAboutJ_Variance_Justification_220214_v1 Puget Sound Energy P.O. Box 97034 Bellevue, WA 98009-9734 PSE.com February 14, 2022 City of Renton Planning Division RE: PSE Talbot Hill Substation Security Upgrades, Fence Variance Justification PSE is seeking variance approval to exceed the fence height restrictions listed in RMC 4-4-040 FENCES, HEDGES, AND RETAINING WALLS in order to support security upgrades at the Talbot Hill Substation. The substation is located within the R-8 zoning district. RMC 4-4-040.D limits the height of fences within residential zoning districts to 72”. PSE is seeking a fence height around the Talbot Hills Substation yard to include 10’ high fencing along the north and west; 10’ to 12’ on the south side; and a 10 to 20’ high fence along the east side of the substation. The substation is located on a site made up of 2 parcels approximately 48 acres in size. Although situated within a single-family residential zoning district, the substation is located within a regional utility corridor that includes both PSE and BPA substations and linear utility infrastructure. The existing PSE substation and utility corridor were legally established in 1958, prior to adoption of current zoning regulations. The nearest residential development is approximately 450 feet downslope from the southern side of the substation. Due to the large expanse of undeveloped property around the substation and the distance between the substation and the nearest residential properties, the substation is generally not visible from residential uses. 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;
The Talbot Hill Substation 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 substation use. The existing substation facility on the site is currently surrounded by
an 8-foot high chain link fence, which no longer meets PSE safety and security standards.
PSE has determined that a fence taller than the existing 8 feet is needed to meet the security standards of NERC
CIP 014. To meet the NERC Security standards, PSE needs to replace the existing 8’ fence with a fence of
varying height. The additional fence height will block lines of sight into the substation deterring potential
delinquent or unlawful threats to the substation. The driveways and roads, on and surrounding the site, are
commonly used as recreational trails by nearby residents and provide open access to the substation parcel to the
general public. The proposed additional fence height will deter visual and physical access into the substation,
preventing potential damage to substation equipment.
Along the north side of the substation which faces multiple transmission lines, PSE is proposing a 10’ fence, plus
2’ of ribbon strip on top. Along the west side of the substation which faces several acres of undeveloped property
owned by PSE, the fence is also proposed to be 10’ in height, plus 2’ of ribbon strip on top. Along the south side
of the substation, the fence is proposed to be 10’ to 12’ in height with 2’ of ribbon strip on the top. The south side
of the substation faces residential properties downslope, but is buffered from the residential uses by tree buffer
and a parcel used for recreation by the homeowners and owned by PSE
The east side of the substation is particularly vulnerable due to the change in elevation between the interior and
exterior of the substation fence. Along the east side of the substation, PSE is generally proposing a 20’ high
fence with 2’ of ribbon strip. The east side of the substation adjoins an existing enclosed area that houses
Current Limiting Reactors (CLRs). The six CLRs sit on an elevated pad and are approximately 24’ in height. This
area provides an elevated line of sight to critical substation equipment. The proposed 20’ high fence, with 2’ of
ribbon strip on the top, will block this line of sight. The uses to the east of the site include Beacon Way South (a
local gravel access road) and a large regional BPA substation facility. The uses on the site and surrounding area
are not typical of residential development within the R-8 zoning district.
A 20’ high fence (with 2 feet of ribbon strip on top), on the east side of the substation, is needed to meet the
security standards of NERC CIP 014 and block the line of sight into the substation along the eastern side of the
substation. A 20’ fence height in this area is the lowest height that will block the line of sight into the substation
and deter potential unlawful threats to the substation.
To not allow a 10 to12’ high fence on the north, south and west sides of the substation and a 20’ high fence on
the east side of the substation would deprive PSE from the ability to safely and securely operate critical utility
infrastructure. Due to the unique nature of the substation use within the R-8 zone as a critical infrastructure
facility, it is not practical or safe for the substation to be subject to the same use standards as single-family
residential uses in the same zoning district.
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;
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 substation site is within an established utility corridor that includes a
PSE regional substation, 115 kV and 230kV transmission lines, and BPA infrastructure that also includes a
regional substation and transmission lines. Surrounding land uses to the north, south, east and west include other
utility infrastructure, as noted in response to criterion 1, on parcels several acres in size. The PSE substation
property is screened from adjacent residential development approximately 450 feet to the south by a recreation
tract and natural tree buffer. The residences to the southeast, approximately 800 feet from the substation fence,
will be unable to see the fence as the line of sight is blocked by existing trees and a transmission line corridor.
The purpose of installing taller fencing around the substation is to secure the site from potential nefarious
activities, which will in turn prevent large scale outages and 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;
The approval will not constitute a grant of special privilege inconsistent with the limitation upon uses of other
properties in the vicinity and zone. The substation site is within an established utility corridor that includes a PSE
regional substation, 115 kV and 230 kV transmission lines, and BPA infrastructure including a regional substation
and 230 kV and 500 kV transmission lines. Residential uses in the R-8 zoning district in the vicinity of the site do
not include critical utility infrastructure nor pose a need for security fencing; therefore granting of the variance is
not a grant of special privilege.
4. That the approval is a minimum variance that will accomplish the desired purpose.
The approval is a minimum variance that will accomplish the needed purpose, meeting NERC CIP 014 security standards. The 10’ high fencing along the north and west; 10’ to 12’ on the south side; and a 10 to 20’ high fence along the east side of the substation is the minimum fence height that will meet safety and security needs based on NERC security standards applicable to the site.