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Home My WebLink AboutPN_Civil_Exemption Request Letter_221129 255 S. King Street, Suite 800, Seattle, WA 98104 | 206.426.2600 | JACOBSONENGINEERS.COM November 29, 2022 Jill Ding Senior Planner City of Renton Planning Division 1055 S Grady Way, 6th Floor Renton, WA 98057 Re: Honey Dew ES Safety Upgrades – Critical Areas Exemption Request Letter - Wetlands Dear Ms. Ding, The Renton School District is proposing a project to recondition the existing athletic field at Honey Dew Elementary School located at 800 Union Ave NE on the east side of the campus. The athletic field is bound by NE 8th ST to the south and Bremerton Ave NE to the east, the existing Next-Door Church property (Parcel #1023059078), a residential parcel (Parcel #1023059512), as well as parcel containing a wetland tract (Parcel #102305TR-A) to the north, and Honey Dew Elementary School to the west. Two parcels (Parcel #1023059121 & Parcel #1023059007) make up the school property. Reconditioning of the existing athletic field will consist of stripping and removing the top 2-inches of sod, organics, and debris that has accumulated over the years. Once stripping activity is complete, 2- inches of sand and a ¾-inch thick layer of new grass sod will be placed. The approximate 9.25-inch to 11-inch layer of root zone mix and sand below, including sub-grade and perforated field sub-drainage, will remain undisturbed. Existing grades along the perimeter of the athletic field will remain unchanged. The existing storm drainage system, including perforated field underdrain piping, and 18-inch conveyance pipe and associated drainage structures will also remain undisturbed and are not proposed to be modified as part of the project. See Civil Sheets C100 and C200 included with this submittal. A portion of the field is located within an existing 200-ft wetland buffer for the wetland that is located north of the field on separate property parcels (102305TR-A & 1023059078). To the best of our knowledge, according to the City of Renton (GIS) COR Maps available online, the 18-inch conveyance storm pipe that runs north-south through the approximate middle of the athletic field is used for stormwater overflows from the existing wetland. The stormwater continues to be conveyed south and offsite through a series of 18-inch and 24-inch storm pipes, until it discharges to a regional stormwater facility located roughly 700 south of the field. See attached Offsite Drainage Exhibit. The project is not impacting the existing adjacent Wetland, including existing grades and storm system associated with Wetland, which will remain and be undisturbed. Since the project will not impact the functioning of the existing Wetland, but is performing work within the 200-ft Wetland Buffer, the project proposes to request a Critical Areas Exemption be granted by the City of Renton to waive the requirement for the project to perform a Wetland Study and submit and Wetland Delineation Report. 255 S. King Street, Suite 800, Seattle, WA 98104 | 206.426.2600 | JACOBSONENGINEERS.COM As stated in the City of Renton Municipal Code Section RMC 4-3-050C.3.g.i, we believe the project can be categorized under exempt activity of “Remodeling, Replacing, Removing Existing Structures, Facilities, and Improvements20” with footnote 20 stating “Remodeling, restoring, replacing or removing structures, facilities and other improvements in existence or vested on the date this Section becomes effective and that do not meet the setback or buffer requirements of this section provided the work complies with the criteria in RMC 4-10-090.” Section 4-10-090 is listed below with our responses addressing each item in blue. 4-10-090 CRITICAL AREAS REGULATIONS – NONCONFORMING ACTIVITIES AND STRUCTURES: A legally nonconforming, regulated activity or structure that was in existence or approved or vested prior to the passage of the Critical Area Regulations, RMC 4-3-050, and to which significant economic resources have been committed pursuant to such approval but which is not in conformity with the provisions of RMC 4-3-050 may be continued; provided, that: 1. No such legal nonconforming activity or structure shall be expanded, changed, enlarged or altered in any way that infringes further on the critical area that increases the extent of its nonconformity with this Section without a permit issued pursuant to the provisions of RMC 4-3-050; To the best of our knowledge, the project does not propose to expand, change, enlarge, or alter any grading or storm drainage structure, storm pipe, or system directly within existing the Wetland (critical area) or adjacent 200-ft buffer that is located on a portion of the existing Honey Dew Elementary School’s athletic field. 2. Except for cases of ongoing agricultural uses, if a nonconforming activity is discontinued pursuant to RMC 4-10-060, any resumption of the activity shall conform to this Section; To the best of our knowledge, the proposed field reconditioning is maintaining an existing condition that was legally established but deemed non-conforming due to establishment within an existing Wetland Buffer. The work associated with the field activity is not altering, extending, enlarging, or relocating any portion of the existing field that would impact the existing Wetland. 255 S. King Street, Suite 800, Seattle, WA 98104 | 206.426.2600 | JACOBSONENGINEERS.COM 3. Except for cases of ongoing agricultural use, if a nonconforming use or activity or structure is destroyed by human activities or an act of God, it shall not be resumed or reconstructed except in conformity with the provisions of RMC 4-3-050, 4-10-050 and 4-10-060; The existing athletic field is being reconditioned by replacing the top 2-inch layer of sand, organics, and debris, with a new 2-inch layer of sand overlaid by 3/4-inch-thick grass sod. The proposed work associated with the field is considered maintenance and will closely match existing conditions, and to the best of our knowledge, will not impact the existing adjacent Wetland. 4. Activities or adjuncts thereof that are or become nuisances shall not be entitled to continue as nonconforming activities. The proposed work associated with the field is considered maintenance that will closely match existing conditions and should not be considered nuisance activity, and to the best of our knowledge, will not impact the existing adjacent Wetland. Based on our review of the criteria outlined above of RMC 4-3-050 of the City of Renton Municipal Code, we feel the work associated with reconditioning the existing Honey Dew Elementary School’s athletic field will not impact the adjacent existing Wetland and therefore request to have the requirement for performing a Wetland Study and Subsequent Issuance of a Wetland Delineation Report, waived for the project. The project is important as it is maintaining and existing community asset that provides significant benefit to the surrounding neighborhoods and residents of the City of Renton. Thank you for consideration and time in reviewing this exemption request. Should you have questions, or if I can provide you with additional information, please feel free to contact me at (206) 426-2600 or alan@jacobsonengineers.com. Regards, Alan Jacobson, P.E., Principal Sascha Eastman, P.E. Senior Project Manager CC: Mike Cato, Renton School District Johnny Hong, Integrus Architecture Attachment: HDES_Offsite Drainage Exbibit_221128.pdf 255 S. King Street, Suite 800, Seattle, WA 98104 | 206.399.6233 | JACOBSONENGINEERS.COM OFFSITE DRAINAGE EXHIBIT SCALE: NTS 206.426.2600 Project Sites Stormwater Pond Wetland 18"18"24"15"12"12"18" Regional Stormwater Facility 12"