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HomeMy WebLinkAboutJ_CUP_Justification_180124_v1 1 Puget Sound Energy - Energize Eastside Conditional Use Permit Project Summary & Justification – Renton Segment Project Summary Puget Sound Energy, Inc. (“PSE”) proposes to upgrade approximately 4 miles of existing 115 kV transmission lines (two) in the city of Renton (“City” or “Renton”) with two 230 kV transmission lines (“Project”) (see maps 1 and 2). The Project is part of the Energize Eastside project, which involves the construction of a new substation in the city of Bellevue (“Bellevue”) and upgrades to an additional 14 miles of transmission lines in the cities of Bellevue, Redmond, Newcastle, and unincorporated King County. The new substation and upgraded transmission lines are needed to address electrical system deficiencies identified during federally-required planning studies. Combined with aggressive conservation, the Energize Eastside project significantly improves reliability for Eastside communities, including the City, and will supply the additional electrical capacity needed for current and anticipated growth. The existing electrical system is not robust enough to maintain reliable service if the entire 18-mile facility is taken out of service at one time. Therefore, the Energize Eastside project will be constructed in two phases. This will allow PSE to keep the existing 115 kV facilities partially in service during construction, which will ensure the continuation of reliable service to customers. This approach best allows PSE to continue to deliver reliable electricity to PSE’s customers during construction. This Conditional Use Permit (“CUP”) application proposes the construction of a 4-mile segment in the City as part of PSE’s first phase of construction. The Project’s second phase will be permitted and constructed outside of Renton’s city limits at a later date. PSE’s first phase includes the following components: • Within Renton, approximately 4 miles of existing 115 kV lines (two) will be upgraded with two 230 kV lines beginning at the City’s northern boundary with Newcastle and ending at the existing Talbot Hill substation. The upgrade is located entirely within PSE’s existing 100-ft electrical transmission utility corridor. Upgrading requires replacing approximately 144 existing wood and steel poles (H-frame designs) with approximately 41 steel monopoles of either single- circuit or double-circuit design. Within the Talbot Hill substation, additional breakers and associated controls will be added to accommodate the new lines. • Outside Renton, the first phase will include construction of the Richards Creek 230 kV to 115 kV substation in Bellevue and upgrading an additional approximately 5 miles of the two existing 115 kV lines with two 230 kV lines between the new Richard Creek substation and the northern city boundary of Renton in the cities of Bellevue and Newcastle. The Project site is currently occupied by PSE’s existing 115 kV transmission lines. After deliberate review and extensive stakeholder input, PSE proposes to undertake this Project in PSE’s existing 100-ft easement that was established in the late 1920s and early 1930s rather than siting a new corridor 2 through Renton communities. The existing transmission lines are co-located with Olympic Pipeline (OPL) petroleum pipelines for about 0.2 miles at the north end of the Project before the pipelines divert from the Project corridor and follow the Seattle City Light (SCL) 230 kV utility corridor, as well as 0.6 miles at the south end of the Project near Talbot Hill substation. Within the existing utility corridor, upgraded pole locations will generally be in the same locations as the existing poles. Use of the existing corridor minimizes environmental impacts and impacts to adjacent uses to the fullest extent feasible. The current uses adjacent to the corridor have developed over time as areas in the City became more dense and populated. The utility corridor is part of the existing character of these areas and crosses 42 parcels (see pre-application file No. PRE 17-000362 for parcel numbers). Renton is a partner city engaged in evaluating the Project under the State Environmental Policy Act (“SEPA”). In conjunction with the cities of Bellevue, Redmond, Kirkland, and Newcastle, the City published a Phase 1 and a Phase 2 Draft Environmental Impact Statement (DEIS). These documents can be found online at http://www.energizeeastsideeis.org/. The Phase 1 DEIS contained a programmatic review of project alternatives. See Phase 1 DEIS, Ch. 2. A thorough analysis of all project alternatives relative to defined project objectives (e.g., meeting demand growth and being environmentally acceptable to affected cities), resulted in a narrowing of reasonable alternatives to an overhead transmission solution. The Phase 2 DEIS contains a focused review of overhead transmission line route alternatives and impacts. Within Renton, PSE’s preferred route uses the existing transmission line corridor as this route is the least impactful (particularly because it minimizes new environmental impacts that would result from a new or expanded corridor). PSE has supported public involvement in the SEPA process through notifications supplementing the official SEPA announcements and will continued to do so through the Final EIS, schedule for completion and publication in early 2018. Upgrading the transmission lines will involve removing existing poles and installing new poles by direct embedding or placing them on foundations. During design, PSE has worked to locate the upgraded poles near existing accessible routes to minimize construction traffic impacts. Vehicular access to pole replacement sites will be made from these existing roads and will utilize existing or constructed temporary access roads. Pole installation typically requires 3–7 days for each pole (within an approximately 2-month work window at any one pole location) and additional time is required for stringing wire (typically 1 to 2 days). Access to adjacent land uses will be maintained. PSE will work to maintain access to roads and recreation sites while providing a safe working area for crews and the public. The existing transmission corridor will not require any new permanent access. Construction job shacks will be located by the contractor selected for the Project, but are typically placed in close proximity to the Project and away from sensitive areas. No off-site improvements are proposed in Renton. Multiple critical areas are mapped along the Project corridor including: wetlands, steep slopes, coal mine hazards, landslide hazards, streams, and wellhead protection areas (also see Renton Critical Areas Report (“Renton CAR”), Chapter 4). The Project includes replacement of aerial wire across the Cedar River (shoreline per Renton Municipal Code [RMC] 4-3-090.B.2). The Project proposes the replacement 3 of poles outside of jurisdictional shorelines and the aerial wire crossing does not require any disturbances in the shoreline. Selective tree removal will occur within the managed utility corridor easement, except within the Cedar River shoreline jurisdiction, to meet federal vegetation management requirements and PSE standards, which generally require removal of trees located in the wire zone that have a mature height of more than 15 feet. An estimated 339 trees could be removed of which 238 are significant trees and 57 are located in stream or wetland buffers. It is anticipated that vegetation removal or management will occur adjacent to streams and wetlands in the project corridor. Where possible, efforts will be made to minimize work activities in or adjacent to critical areas (see also, the Renton CAR) provided under separate cover and the City of Renton Tree Inventory Report: Puget Sound Energy – Energize Eastside Project (The Watershed Company 2016b).). To mitigate for the loss of significant trees in the transmission corridor, PSE is proposing mitigation ratios that exceed the City’s regulatory standards. PSE has been meeting with property owners along the existing corridor to discuss tree replacement and will continue to work together to develop property-specific landscaping and tree replacement plans. It is anticipated that a number of trees cannot be replaced onsite due to property owners’ preferences. In those cases, replacement trees will need to be planted elsewhere. PSE will work with the City to identify other offsite areas that would benefit from these trees, including in locations outside of the managed utility corridor and/or will participate in the City’s fee in lieu program. RMC 4-4-130.H.1.e.iii. One benefit of offsite planting is the option to plant larger trees in clusters that will contribute to increasing habitat quality and area aesthetics. Offsite options may include city parks and neighborhood groups/HOAs. Surface soils in the Project area include mainly silty gravel, silty sand, and silt. Soils along the proposed route provide adequate support for the new poles (GeoEngineers 2017; see Appendix C of Critical Areas Report). To minimize impacts to soil, a Sediment and Erosion Control Plan will be addressed in the Project-specific Temporary Erosion and Sediment Control (or “TESC”) Plan and Construction Stormwater Pollution Prevention Plan (CSWPPP). Areas of disturbance will be limited to the minimum necessary within geological hazard areas, including limiting equipment access. See Renton CAR at Sections 4.3.5; 5.2.2; 7.1.2; and 8.3. All disturbed areas will be restored. Drainage patterns will not be changed as a result of the Project; more information will be provided in the Drainage Report to be submitted to the City along with a future clearing and grading permit application. The Project will entail removing 144 poles and installing 41 new ones. The installation of the new poles will require approximately 450 to 650 cubic yards of excavation. The annulus between the outside of the hole and the pole is typically backfilled with crushed rock. The property is located within multiple zoning designations, including: Commercial Arterial (CA), Commercial Office Residential (COR), Center Village (CV), Light Industrial (IL), Residential-1 (R-1), Residential-10 (R-10), Residential-14 (R-14), Residential-4 (R-4), Residential-6 (R-6), Residential-8 (R-8), Resource Conservation (RC), and Residential Multi-Family (RM-F) (Renton Zoning Maps 2015). The Project is considered a “Utility, Large” land use per RMC 4-11-210A, which is permitted within all zoning designations as a Hearing Examiner-issued CUP. See RMC 4-2-060; RMC 4-8-070(H)(1)(d). Although there are already two existing 115 kV transmission lines in the utility corridor, Renton considers the Project an intensification of utility use; therefore, a CUP is required by the City. See RMC 4-9-030. The 4 Project is located in Township 23N, Range 05E, and Sections 4, 9, 16, 20, and 21. Total cost of construction for Project in Renton is estimated to be about $18 million. Conditional Use Permit Justification: Consistency with Plans and Regulations: The proposed use shall be compatible with the general purpose, goals, objectives and standards of the comprehensive plan, the zoning ordinance and any other plans, programs, maps or ordinances of the City of Renton. Response: The proposed transmission line replacement and substation construction are consistent with the City’s Comprehensive Plan (‘Plan) adopted June 22, 2015. Details of consistency are provided in the table below. The City’s vision in the Plan is for a thriving, opportunity-rich community. The Plan was developed in conformance with the state Growth Management Act (GMA), King County’s Countywide Planning Policies, and Vision 2040. PSE has a statutory duty to provide safe and reliable power at a reasonable cost. See RCW 80.28.010(2). The Energize Eastside project is an electrical infrastructure project needed to bring a 230-kV power source to the Eastside region, including Renton, facilitating the City’s vision by providing electrical resources that will support new residential and commercial facilities contributing to the health of the community. The proposed Project is reviewed below for compatibility with the Plan. Table 1 – Renton Comprehensive Plan policies and compliance consistency review Comprehensive Plan Goal or Policy Consistency Review Land Use Element L-B: Continue to build Renton’s Regional Growth Center consistent with VISION 2040 to provide compact, pedestrian-oriented, mixed-use development to meet the demands of population and employment growth, while reducing the transportation-related and environmental impacts of growth. Response: Renton is planning for a projected growth of over 14,000 new households and 28,000 new employees by 2035. Without adequate electricity to service the new population and employment growth, these goals cannot be achieved. PSE has determined that a deficiency in electrical transmission capacity during peak periods could develop on the Eastside as early as the winter of 2017-2018, with the potential for corrective action plans including load shedding (forced power outages) as early as the summer of 2018. Five separate studies performed by four separate parties have confirmed the need to address Eastside transmission capacity: Electrical Reliability Study by Exponent, 2012 (City of Bellevue); Eastside Needs Assessment Report by Quanta Services, 2013 (PSE); Supplemental Eastside Needs Assessment 5 Report by Quanta Services, 2015 (PSE); Independent Technical Analysis by Utility Systems Efficiencies, Inc., 2015 (City of Bellevue); and Review Memo by Stantec Consulting Services Inc., 2015 (EIS consultant). These are provided with the CUP application. The deficiency in the transmission capacity on the Eastside is based on a number of factors. Key factors include growing population and employment in the Eastside (including significant projected growth in Renton), changing power consumption patterns, and changing utility regulations that require a higher standard of reliability. PSE has concluded that the most effective and efficient solution to meet the need objectives is to site a new 230 kV transformer at a central location on the Eastside (Bellevue) that will be fed from the Sammamish substation in Redmond from the north and the Talbot Hill substation in Renton from the south. A lack of reliable power service would adversely affect Renton’s ability to attract and retain businesses and residents. As such, Project implementation supports the needs of Renton’s residents and businesses both now and with projected future growth. L-2: Support compact urban development to improve health outcomes, support transit use, maximize land use efficiency, and maximize public investment in infrastructure and services. Response: The Energize Eastside project is an important investment in the infrastructure needed to support Renton’s planned and projected growth. As stated above, five studies have confirmed that the Energize Eastside project is needed to address near- term system reliability deficiencies. By maintaining a reliable electricity grid, the proposed transmission line will support Renton’s efforts to grow its business and residential communities. L-J: Develop well-balanced, attractive, convenient Centers serving the City and the region that create investment opportunities in urban scale development, promote housing close to employment and commercial areas, reduce dependency on automobiles, maximize public investment in infrastructure and services, and Response: The Energize Eastside project is an important investment in the infrastructure needed to support Renton’s planned and projected growth. As stated above, five studies have confirmed that the Energize Eastside project is needed to address near- 6 promote healthy communities. term system reliability deficiencies. By maintaining a reliable electricity grid, the proposed transmission line will support Renton’s efforts to grow its business and residential communities. L-P: Minimize adverse impacts to natural systems, and address impacts of past practice where feasible, through leadership, policy, regulation, and regional coordination. Response: The Project’s impact to natural systems and PSE’s related minimization and mitigation efforts are detailed in the Renton CAR. PSE’s decision to use the existing transmission line corridor avoids new adverse impacts to natural systems. PSE has worked hard to identify pole placement locations and adjust transmission pole height to minimize adverse impacts to natural systems, including impacts to aesthetic resources. PSE is also committed to implementing Best Management Practices (“BMPs”) to limit any unavoidable impacts. See Renton CAR. However, not all Project impacts can be avoided. Strict federal clearance requirements must be met with the upgrade from a 115 kV transmission corridor to a 230 kV transmission corridor, resulting in additional vegetation management within the existing corridor. Federal standards require PSE to maintain safe clearances between vegetation and utility lines. These standards are designed to maintain a reliable electric transmission system by using a defensive strategy that minimizes vegetation encroachment into the lines to prevent risks of vegetation-related outages. The upgraded transmission lines will comply with PSE’s 230 kV vegetation management standards (based on the federal standards), which generally require removal of trees located in the wire zone that have an expected mature height of more than 15 feet. Taller trees within the transmission easement may also be affected depending on tree species, tree health, distance from the wires or poles, and topography. Additionally, the co-located OPL easement is maintained to prevent trees and other woody vegetation from growing and interfering with the pipelines. For these reasons, selective 7 tree canopy will be removed as part of the transmission line upgrade. To mitigate for loss of significant trees (defined per RMC 4-4-130) in the transmission corridor, PSE is proposing mitigation that meets or exceeds the City’s regulatory requirements. PSE will work with individual property owners to replace trees on private property. Where individual property owners decline to have new trees planted onsite, PSE will work with Renton to place additional trees offsite or will participate in the City’s fee in lieu program. RMC 4-4-130.H.1.e.iii. PSE has been meeting with property owners along the existing corridor to discuss tree replacement and will continue to work together to develop property-specific landscaping and tree replacement plans. It is anticipated that a number of trees cannot be replaced onsite due to property owners’ preferences. In those cases, replacement trees will need to be planted outside the corridor or be compensated for under the City’s fee in lieu program. RMC 4-4- 130.H.1.e.iii. One benefit of offsite planting is the option to plant trees with larger mature size than is allowed within the utility corridor, which larger mature trees will contribute to habitat quality and area aesthetics. PSE will work with Renton to determine whether offsite planting is permissible and, if so, to identify areas that would benefit from new trees. L-24: Promote urban forests through tree planting programs, tree maintenance programs that favor the use of large healthy trees along streets and in parks, residential, commercial, and industrial areas, programs that increase education and awareness, and through the protection and restoration of forest ecosystems. Response: See response to L-P above. Although not required to replace those trees that are removed, PSE will work with City and property owners to identify opportunities to replace those trees. L-35: Ensure buildings, roads, and other features are located on less sensitive portions of a site when sensitive areas are present. Response: RMC 4-11-190 defines “sensitive areas” as “critical areas.” Critical areas include “Wetlands, aquifer protection areas, fish and wildlife habitat, frequently flooded and geologically hazardous areas as defined by the Growth Management Act” and are 8 subject to RMC 4-3-050, Critical Area Regulations. See also RMC 4-11-030. As set forth PSE’s Renton CAR, the Project avoids critical areas to the extent feasible and provides mitigation where impacts are unavoidable. In the Renton CAR the Project’s impacts are summarized as follows: “Proposed new poles have been sited to avoid any direct impacts to wetlands or streams. All impacts have been avoided within the shoreline jurisdiction including within all flood hazard areas. Completely avoiding pole impacts to geologic hazard areas and wellhead protection areas is not feasible due to the prevalence of those features in the Project area. Furthermore, pole replacement activities associated with the transmission line upgrade must occur in specific locations for proper functioning of the electrical system due to complex engineering considerations making pole placement in some critical areas unavoidable. Where avoidance wasn’t possible, PSE worked with engineers to minimize impacts through design revisions; such changes reduced pole footprints and increased line heights to avoid critical area impacts to the extent feasible. Temporary impact areas associated with construction access, pole construction work areas, and stringing sites also avoid critical areas to the extent feasible. For example, specific pole construction work areas have been adjusted to exclude critical areas on a pole-by-pole basis.” Renton CAR at 34. The Renton CAR summarizes the Project’s impacts, following implementation of avoidance measures, as follows: “The Project was designed to avoid and minimize impacts to critical areas. No new 9 poles are proposed in wetlands, streams or stream buffers or seismic hazard areas. One new pole is proposed in a wetland buffer and three existing Lake Tradition Line poles in wetland buffer will be replaced with new, larger poles in the same locations, resulting in a net increase in pole footprint at those locations. New poles are also proposed in erosion hazard areas, landslide hazard areas, steep slope hazard areas, coal mine hazard areas, habitat conservation areas and wellhead protection areas. Vegetation conversion impacts are also proposed in these areas, as well as in stream and wetland buffers. In wetland buffers, permanent impacts (i.e., poles) are limited to one new Energize Eastside pole and three Lake Tradition replacement poles. Two existing poles will be removed from and replaced outside of wetland and stream buffer resulting in a net increase of 68 square feet of permanent impact. Vegetation community conversion impacts in wetland and stream buffers total 18,786 square feet and 20,064 square feet of temporary disturbance will occur. Impacts will be minimized by utilizing the existing transmission line corridor, limiting disturbance and implementing best management practices (BMPs) when working in critical areas, and installing transmission lines between poles with minimal site disturbance.” Renton CAR at 1-2; see also Renton CAR at 27 (“The Project has been designed to avoid all impacts within shoreline jurisdiction. Conservatively, this includes avoiding all tree removal and impacts to other native vegetation within the vicinity of Wetland NRO2 as well as the approximated boundaries of the Cedar North wetland which defines the northern extent of the shoreline jurisdiction boundary.”). Unavoidable impacts are described in detail in the Renton CAR, Ch. 7. L-55: Protect public scenic views and public view Response: The Project is permitted as a 10 corridors, including Renton’s physical, visual and perceptual linkages to Lake Washington and the Cedar River. L-56: Natural forms, vegetation, distinctive stands of trees, natural slopes, and scenic areas that “contribute to the City’s identity, preserve property values, and visually define the community neighborhoods” should be protected. conditional use in all zones in Renton. The Phase 2 Draft Environmental Impact Statement identified the following visual resources in Renton: views of the Olympics, Cascades and, near Talbot Hill, views of Mount Rainier, Lake Washington, and the Cedar River. Phase 2 DEIS at 3.2-16. Two viewpoints in Renton (one at 1026 Monroe Ave NE and one at 318 Glennwood Court SE) were selected for review in the visual quality analysis. These areas were characterized as “surrounded by institutional and single-family residences” and “surrounded by single-family residential development and placed on a ridge” respectively. Phase 2 DEIS at 3.2-21. The Phase 2 DEIS concludes that “[i]mpacts to scenic views would also be less-than- significant because the degree of additional obstruction would be minimal compared with existing conditions.” Phase 2 DEIS at 3.2-81. By using the existing utility corridor, PSE protects existing public scenic views and public view corridors as the impacted areas already include transmission lines in the viewshed. This includes the Cedar River recreation area, in which PSE was able to avoid any tree removal or construction activities within the jurisdictional shoreline, thereby protecting the heavily vegetated ravine. Constructing the Project in the existing transmission line corridor, in roughly the same location as the existing poles, also protects new disturbances to trees, natural slopes and scenic areas. After a pole-by-pole review, PSE concluded that a maximum of 339 trees will be removed, 238 of which are designated as significant trees. Tree inventory methodology and results are available in the City of Renton Tree Inventory Report: Puget Sound Energy – Energize Eastside Project (The Watershed Company 2016b). PSE will work with the City and property owners to identify preferred species of replacement vegetation that enhances adjacent uses to the extent possible. PSE has 11 been meeting with property owners along the existing corridor to discuss tree replacement and will continue to work together to develop property-specific landscaping and tree replacement plans. This mitigation will help to ensure that Renton’s view corridors retain trees and vegetation. The Phase II DEIS also concludes that constructing the Project in the existing corridor limits impacts to property values to a “less than significant” level. DEIS at Section 3-10. L-62: Promote environmentally friendly, energy-efficient development, including building and infrastructure. Response: The proposed alignment for Energize Eastside utilizes the existing utility corridor, which minimizes to the extent feasible new environmental impacts. PSE has led all northwest utilities in energy conservation since 1979. Its energy efficiency programs have helped PSE customers conserve nearly 5 billion kilowatt-hours of electricity. PSE continues to develop and undertake aggressive conservation programs and the Project relies on the continued implementation of aggressive conservation programs. More information on PSE’s conservation planning and accomplishments can be found in PSE’s 2016-2017 Biennial Conservation Plan (https://pse.com/aboutpse/Rates/Document s/ees_2016_annual_rpt_energy_conservatio n_accomplishments.pdf) and 2016 Annual Report of Energy Conservation Accomplishments (https://pse.com/aboutpse/Rates/Document s/ees_2016_annual_rpt_energy_conservatio n_accomplishments.pdf). Economic Development Element ED-14: Encourage investments that address future needs: focus investment in infrastructure and services in designated centers that align with the City’s projected population, housing, and job growth targets. Response: The Energize Eastside project is an important investment in the infrastructure needed to support Renton’s planned and projected growth. By maintaining a reliable electricity grid, the proposed transmission line will support Renton’s efforts to grow its business and residential communities. 12 Community Planning Element CP-B: Through Community Planning, improve the livability of Renton’s neighborhoods, preserve unique identities, foster and enhance community character, and prioritize the provision of City services and investment in infrastructure. Response: The Energize Eastside project is an important investment in the infrastructure needed to support Renton’s planned and projected growth. By maintaining a reliable electricity grid, the proposed transmission line will support Renton’s efforts to grow its business and residential communities. CP-6: Implement Community Plans in concert with Community Plan Advisory Boards who make recommendations based on the adopted vision and goals of their Community Plan regarding the provision of City services and infrastructure investment. Response: The Multi-modal Transportation plan element of the Benson Hill Community Plan seeks to improve the existing trail system. Part of the strategy for this plan element includes connecting paths with Puget Sound Energy properties near Arnold Park (see Sect. 2.2.4). PSE will work with the City to support this planning element within the limits of easements and safe operation of the transmission lines. Section 5.2.3 of the Strong, Livable, and Safe Neighborhoods planning element seeks to investigate undergrounding powerlines with PSE, but recognizes that this would require residents to create a special district to tax themselves for the additional cost of undergrounding. PSE has not been approached by affected neighborhood associations to facilitate this undergrounding option and associated cost. Utility Element U-A: Provide an adequate level of public utilities consistent with land use, protection of the environment, and annexation goals and policies. Response: The Energize Eastside project is an important investment in the infrastructure needed to support Renton’s planned and projected growth. As stated above, five studies have confirmed that the Energize Eastside project is needed to address near- term system reliability deficiencies. By maintaining a reliable electricity grid, the proposed transmission line will support Renton’s efforts to grow its business and residential communities. U-2: Protect the health and safety of Renton citizens from environmental hazards associated with utility systems through the proper design and siting of utility facilities. Response: PSE has conducted studies on potential health effects of the proposed transmission line upgrade, which have been peer reviewed by City of Bellevue’s chosen consultants through the SEPA review process and the drafting of an Environmental Impact Statement (EIS) for this project. In particular, the EIS looked at electric and magnetic fields 13 (EMF) and pipeline safety. As detailed in the Phase 1 Draft Environmental Impact Statement, no impacts from EMF are expected from the Project. Phase 2 DEIS at 1-27. PSE commissioned an independent analysis on EMF. Power Engineers, EMF Calculations and Report, available at http://www.energizeeastsideeis.org/uploads /4/7/3/1/47314045/ee230_emf- calc_rpt_rev-2_03-07-17.pdf (Chapter 10 contains a Renton-specific analysis). This analysis found that, following Project completion, EMF would be reduced at the edge of the right-of-way as compared to existing conditions, thus further ensuring that the Project will not negatively impact the health and safety of Renton residents. See Power Engineers, EMF Calculations and Report at 40 and 42. U-3: Promote the co-location of new utility infrastructure within rights-of-way and utility corridors, and coordinate construction and replacement of utility systems with other public infrastructure projects to minimize construction- related costs and disruptions. Response: The proposed Project route fulfills the City’s goal of collocating utility infrastructure in a single corridor as the corridor (which includes the existing transmission line) also houses the Olympic pipeline (OPL) for a portion (0.8 mi) of the corridor. Continued collocation of the two utilities will help to limit neighborhood fragmentation and other impacts from siting a new transmission line corridor. Thus, the Project supports the City’s policy of promoting collocation to minimize impacts to land use and neighborhoods. U-4: Coordinate with adjacent jurisdictions and non-City service providers within Renton to cooperatively plan for regional growth. Response: The Energize Eastside project embodies a coordinated, multi-jurisdictional effort to cooperatively plan for regional growth in electricity demand. In total, five separate studies performed by four separate parties have confirmed the need to address Eastside transmission capacity: Electrical Reliability Study by Exponent, 2012 (City of Bellevue); Eastside Needs Assessment Report by Quanta Services, 2013 (PSE); Supplemental Eastside Needs Assessment Report by Quanta Services, 2015 (PSE); Independent Technical 14 Analysis by Utility Systems Efficiencies, Inc., 2015 (City of Bellevue); and Review Memo by Stantec Consulting Services Inc., 2015 (EIS consultant). The identified need resulted in an inter-jurisdictional agreement between the Partner cities to study the environmental effects of possible solutions to the transmission line capacity deficit. U-5: Approval of development should be conditioned on the availability of adequate utility service and should not result in decreases in local levels of service for existing development. All new development should be required to pay their fair share of construction costs for necessary utility system improvements. U-7: Non-City utility systems should be constructed in a manner that minimizes negative impacts to existing development and should not interfere with operation of City utilities. City development regulations should otherwise not impair the ability of utility providers to adequately serve customers. Response: The Energize Eastside is a utility service upgrade. It increases, rather than decreases, the local levels of service for existing development. Other future developments in Renton will benefit from the increase in utility service reliability. Negative impacts to existing development are minimized through the use of the existing transmission line corridor. Operation of the Project will not interfere with the operation of City utilities. Instead, it will provide improved reliability of necessary electrical service to Renton customers, which could include the City, which also uses electricity to support its own utility operations. U-43: Minimize erosion and sedimentation by requiring appropriate construction techniques and resource practices. Response: Pole replacement activities are proposed in erosion hazard areas, landslide hazard areas, steep slope hazard areas and coal mine hazard areas. See Renton CAR (Appendix C; GeoEngineers Report); Renton CAR at 40-41 (tables 8 and 9); Renton CAR at 53; Renton CAR at Section 9.2. However, new poles are replacing existing poles, which will be removed, and more poles will be removed than will be installed. For pole replacement activities, the disturbed area will be stabilized using best management practices (BMPs) that reduce potential impacts, including plant replacement, seeding, or hog fuel application in areas of bare soil and scattering chipped wood or tree debris. Soil removed from new pole excavations may be scattered into vegetation and away from landscaped areas or disposed of offsite. If the work area is wet or has standing water, driving mats will be used under all equipment and all soils excavated 15 for pole installation will be removed from the site for offsite disposal. PSE will also minimize the use of large equipment to the extent possible. The requirements of a Sediment and Erosion Control Plan will be addressed in the Project-specific Temporary Erosion and Sediment Control Plan and Construction Stormwater Pollution Prevention Plan. In rare instances, such as geological hazard areas or associated buffers, the old poles may be cut off approximately 1-2 feet below the ground surface and the remaining portion of each pole left. See Renton CAR at 8.3; Renton CAR at Appendix E. In wetland and stream buffers, permanent impacts (caused by pole placement) will be reduced by 12 ft2; tree removal (required to meet federal utility management standards) will result in about 8,090 ft2 of vegetation community conversion impacts; and about 10,650 ft2 of temporary disturbance will occur. Impacts were minimized by utilizing the existing transmission line corridor, limiting disturbance and implementing BMPs when working in critical areas, and installing transmission lines between poles with minimal site disturbance. U-46: Prohibit permanent structures from developing in floodways and manage development within the 100 year floodplain. Where development is permitted in the floodplain, ensure compliance with FEMA floodplain development regulations and the National Marine Fisheries Biological Opinion regarding the National Flood Insurance Program. Response: Flood hazard areas within the Project area in Renton are mapped along the Cedar River in the corridor. Flood hazard areas include both the 100-year floodplain and floodway. No impacts or permanent structures are proposed in flood hazard areas. Renton CAR at Section 5.1.3. U-O: Promote the availability of safe, adequate, and efficient electrical service within the City and its planning area, consistent with the regulatory obligation of the utility to serve customers. Response: The Energize Eastside project is designed to provide safe, adequate and efficient electrical service in Renton specifically, and the Eastside generally. PSE has prepared two studies that describe the need for the Energize Eastside project: the Eastside Needs Assessment Report and the Supplemental Eastside Needs Assessment Report (Gentile et al., 2014, 2015). The deficiency in the transmission capacity on the Eastside is based on a number of factors. Key factors include growing population and 16 employment in the Eastside (including significant projected growth in Bellevue), changing power consumption patterns, and changing utility regulations that require a higher standard of reliability. PSE has concluded that the most effective and efficient solution to meet the need objectives is to site a new 230 kV transformer at a central location on the Eastside (Bellevue) that will be fed from the Sammamish substation in Redmond from the north and the Talbot Hill substation in Renton from the south. The upgraded transmission line proposed in Renton will facilitate transfer of electricity to this new transformer, which subsequently serves the City. Without adding transmission capacity, a deficiency during peak periods could develop on the Eastside as early as the winter of 2017-2018, with the potential for the implementation of corrective action plans including load shedding (forced power outages) as early as the summer of 2018. The proposed Project is needed to meet the needs of Renton’s residents and businesses. U-72: Coordinate with local and regional electricity providers to ensure the siting and location of transmission and distribution facilities is accomplished in a manner that minimizes adverse impacts on the environment and adjacent land uses. Response: By using an existing transmission line corridor, the Project is designed to minimize new impacts to existing properties and uses adjacent to the subject property. PSE proposes a transmission line upgrade in an existing utility corridor that was established in the late 1920s and early 1930s. The current uses adjacent to the corridor developed over time as areas became more dense and populated. The utility corridor is part of the existing character of these areas. By selecting this route through Renton, PSE limits new impacts that would result if a new corridor were selected. Additionally, the existing corridor ensures consistency with the existing uses, which already accommodate proximity to a high voltage transmission line. PSE has also undertaken aesthetic design work to ensure no materially detrimental impact to adjacent properties and uses. The new poles will be steel monopoles that are 17 generally installed in the same location or in close proximity to the existing poles. In most cases, the number of poles will be reduced from four to six poles down to one pole, which reduces visual clutter. The consistency of the proposed transmission line upgrade with adjacent properties was confirmed by the Phase 2 DEIS, which found that impacts to land use will “be less-than-significant because [the proposed project] is consistent with city plans, and would not adversely affect existing or future land use patterns.” (Phase 2 DEIS at 3.1-42). PSE will also work with the City to assess pole finishes (e.g., galvanized, Corten [self- weathering], or painted [powder coat]) of the steel monopoles to make them more visually pleasing, thereby limiting aesthetic impacts to adjacent uses. PSE will work with the City and property-owners to identify preferred species of replacement vegetation that enhances adjacent uses to the extent possible. U-73: Encourage electricity purveyors to make facility improvements and additions within existing utility corridors wherever possible. Response: PSE proposes a transmission line upgrade and improvement in the existing utility corridors consistent with The City’s Comprehensive Plan. Shoreline Management Element SH-43: Trails should be developed to enhance public enjoyment of and access to the shoreline: … 2) Trails should be developed as an element of a system that links together shoreline public access into an interconnected network including active and passive parks, schools, public and private open space, native vegetation easements with public access, utility rights of way, waterways, and other opportunities. Response: Currently, no plans or access for trail development in shorelines are being proposed as part of the Project as PSE does not have the property rights to do so. SH-7: Existing and future activities on all Shorelines of the State regulated by the City of Renton should be designed to ensure no net loss of ecological functions. Response: PSE’s Project does not propose any pole replacement activities, construction laydown, access, or vegetation management activities in the shoreline. Rather, the Project involves the aerial replacement of a wire more than 200-feet over the Cedar River. As the wires replace existing wires and all construction work required to hang the lines will occur outside the shoreline, the wire replacement will not cause any loss of 18 shoreline ecological function. Additionally, the change in voltage has no impact on ecological function nor will it cause a substantial adverse effect to shoreline resources (access, aesthetics, etc.). By utilizes the existing utility corridor new impacts to the shorelines are avoided. Further, the Project avoids adverse impacts to navigation (the height of lines over the water will be increased). As there are no shoreline impacts, there will also be no impact to shoreline ecological function. In fact potential impacts to avian species will be reduced. As explained in the DEIS, “[t]he project would reduce the electrocution and collision rates for avian species. The most common cause of avian electrocution is when birds simultaneously contact two power phases (wires carrying different charge). Avian electrocutions occur most frequently with lower voltage distribution lines (30 kV or less) because conductors on most these lines are narrowly spaced and can be bridged by birds, particularly those with large wing spans (Dwyer et al., 2013; SCL, 2014). Electrocution incidences are lower with higher voltage transmission lines because of the greater separation between wires. For the Energize Eastside project, spacing of the 230 kV wires would typically be greater than the existing 115 kV lines, which would reduce the electrocution potential.” DEIS at 3.4-17. In sum, the Project will, to some degree, improve ecological functions from the existing conditions by reducing electrocution risk. 19 Appropriate Location: The proposed location shall not result in the detrimental overconcentration of a particular use within the City or within the immediate area of the proposed use. The proposed location shall be suited for the proposed use. Response: PSE is proposing to replace the existing 115 kV transmission lines with 230 kV transmission lines. The upgrade is located entirely within PSE’s existing 100-foot electrical transmission utility corridor. After deliberate review and extensive stakeholder input, PSE proposes to undertake this work in the existing transmission line corridor rather than siting a new corridor through Renton communities. Use of the existing corridor (which has housed transmission lines since the 1920s and 30s) minimizes environmental impacts and impacts to adjacent uses to the fullest extent feasible. The transmission line replacement will reduce the number of poles within the corridor by over 70% from 144 to 41 poles. Also, the vast majority of the utility corridor does not currently house other electrical utilities. Thus, the proposed Project does not over concentrate the particular land use, which is already an existing utility corridor. The utility corridor is part of the existing character of the area. By selecting this route through Renton, PSE limits new impacts and ensures consistency with the existing uses, which already accommodate a utility corridor. Effect on Adjacent Properties: The proposed use at the proposed location shall not result in substantial or undue adverse effects on adjacent property. Response: The consistency of the proposed transmission lines upgrade with adjacent properties was confirmed by the Phase 2 DEIS, which found that impacts to land use will “be less-than- significant because [the proposed Project] is consistent with city plans, and would not adversely affect existing or future land use patterns” (Phase 2 DEIS at 3.1-44). The 230 kV transmission line upgrade is proposed within the existing 115 kV utility corridor and the replaced poles will generally be installed in the same location or in close proximity to the existing poles. Additionally, the number of poles will be reduced by over 70%. The proposed transmission line replacement will have temporary construction impacts on surrounding neighbors as many of the transmission poles are within easements in residential backyards. However, construction impacts will be minimized to the greatest extent feasible through use of mainly existing or historic access routes that were used for initial pole installation and/or maintenance activities. A safe work area will be established around each pole removal and installation location, providing space for placing equipment, vehicles, and materials. The installation time for poles depends on whether a given pole is placed on a foundation or is directly embedded. Poles on foundations take longer. Typically, pole foundation work takes 1 to 3 days; setting the pole takes 1 to 2 days; and stringing the wires across the pole takes 1 or 2 days. Stages of work can be separated by up to 1 month or more. Accordingly, in any given location, construction activities typically take place over 3 to 7 days within a 2 month period. Additional time may be required for site preparation, installation of BMPs, and site restoration. For direct embed steel poles with no foundation, the hole is typically prepared and the pole is set in a single day. The wires are typically installed up to a month later. PSE will work with individual property owners to restore areas impacted during construction to its previous, or an improved, state. PSE will work with property owners and the City to identify 20 preferred species for replacement vegetation, with a focus on native species, so as to enhance adjacent uses to the extent possible. PSE will mitigate for impacts in a manner that is consistent with the applicable regulations when on-site restoration is not possible. All applicable codes and standards will be followed during design and construction, including electrical, stormwater and erosion control, tree protection, and noise codes. Compatibility: The proposed use shall be compatible with the scale and character of the neighborhood. Response: The Energize Eastside project is compatible with the existing scale and character of development in the Project neighborhood, which includes other tall vertical structures and trees. The proposed upgraded transmission lines are located in an existing utility corridor, where existing land uses are predominantly vacant (42%). Non-vacant land uses are primarily transportation and single-family residential uses located adjacent to the existing transmission lines. Approximately 185 parcels are immediately adjacent to the existing corridor. The Project, as designed, will not change the use of these parcels. Unique land uses include Sierra Heights Elementary School, Renton Seventh-day Adventist Church, Church of Jesus Christ of Latter-day Saints, Renton Technical College, North Highlands Neighborhood Center, and a large commercial area along NE Sunset Blvd. The Renton segment goes through the residential neighborhoods of Honey Creek Ridge, Shadow Hawk, Liberty Ridge, Glencoe, and Sunset (Renton Highlands). Honey Creek Ridge, Shadow Hawk, Liberty Ridge, and Glencoe are predominantly single-family and multi-family planned-developments with designated park spaces. Sunset (Renton Highlands) is one of Renton’s older developed areas and is comprised of commercial and residential uses; it is currently being redeveloped with new multi- family, parks, library, and commercial land uses. Several parks are along the corridor, including May Creek Greenway, Honey Creek Greenway, and the Cedar River Natural Zone. PSE designed the Project to use the existing transmission line corridor that was established in the late 1920s and early 1930s. The current uses adjacent to the corridor developed over time as areas were annexed into the City and these areas became more dense and populated, particularly starting in the 1940s when Boeing Airplane Company built its Renton Boeing plant for production of B-29s. The utility corridor is part of the existing character of the adjacent neighborhoods, which house many tall vertical structures including light poles, street lights, electrical lines (including Seattle City Light’s existing lattice tower 230kV transmission lines), communication towers, buildings, and trees (including Douglas fir, which have a mature height of 70 ft to over 300 ft). By selecting this route through Renton, PSE limits new impacts and ensures consistency with the existing uses, which already accommodates transmission line facilities, which are typically the tallest features in the corridor. PSE’s proposed transmission line upgrade design involves replacing the existing 144 H-frame wood 115-kV transmission poles with 41 steel monopoles to accommodate 230-kV conductors (e.g., wires). The replacement poles will generally be installed in the same location or in close proximity to the existing poles. This design provides over a 70% reduction in transmission poles within the corridor. The reduction in poles reduces aesthetic impacts to adjacent uses by eliminating visual clutter, which is arguably more compatible with adjacent neighborhoods. The average pole height 21 being proposed in Renton is approximately 85 feet (variance option); however, actual heights are location dependent. Additionally, the replacement poles will not preclude compatible existing and future uses of the adjacent properties. The Phase 2 DEIS concluded that “[o]verall, impacts to the aesthetic environment from the Renton Segment would be less-than-significant” (See Phase 2 DEIS at 3.2-87). Plans and policies of Renton do not directly address mitigation of impact to scenic views or the aesthetic environment. However, PSE will also work with the City to assess various pole finishes (e.g., galvanized, Corten [self- weathering], painted) to limit aesthetic impacts to the neighborhood and protect public scenic views (Plan policy L-55). PSE will also work with the City and property owners to identify preferred species of replacement vegetation, with a focus on native species, so as to enhance adjacent uses to the extent possible. The Renton Comprehensive Plan land use designations include Single-Family Residential and Multi- Family Residential. This indicates that the neighborhoods will continue to have residential land uses along the existing corridor for the foreseeable future. The policies specific to the Plan indicate an intent to preserve the current residential character while providing for concentrated growth where necessary (Plan Goals L-H and L-I, and Policies L-15, L-16, and L-171). The consistency of the proposed transmission lines with existing land use pattern and neighborhood character was confirmed by the Phase 2 DEIS, which concluded that the “Project would not impact affect the existing land use pattern of single-family residential” and “future land use, which are anticipated to be mostly single-family residential, mixed-use, and commercial” (Phase 2 DEIS at 3.1-45). All potential SEPA impacts must be assessed against the existing transmission line and the existing property rights granted with the establishment of the utility corridor. See, Chuckanut Conservancy v. Washington State Department of Natural Resources, 156 Wn. App. 274, 292-93, 232, P.3d 1154,1163 (2010). Parking: Adequate parking is, or will be made, available. Response: The Project is a transmission line upgrade and thus, no parking is necessary or provided as a component of the Project. If necessary, construction vehicles will utilize parking spaces or adjacent street parking during active construction. In addition, it is possible that recreation sites or facilities may be used for temporary construction staging. PSE would work with the appropriate cities to identify suitable locations for staging that would result in minimal impacts to parking. Such suitable locations may include overflow parking areas or parts of the site that are underutilized. Traffic: The use shall ensure safe movement for vehicles and pedestrians and shall mitigate potential effects on the surrounding area. Response: The proposed transmission line upgrade will ensure safe movement of vehicles and pedestrians and mitigate potential impacts in the Project area. The proposed transmission line upgrade is located within the existing utility corridor. This corridor has been established for almost a 1See Renton Comprehensive Plan, August 2016. 22 century. Because adjacent land uses and roads already integrate with the transmission lines, once operational, the upgraded transmission lines are not expected to disrupt vehicles or pedestrians in the surrounding areas. During construction, impacts will be limited in duration and mitigated consistent with Renton’s code. Construction vehicle access to pole replacement sites will be made from existing roads or newly constructed temporary access roads. During design, PSE worked to locate poles near existing accessible routes to minimize impacts to traffic from Project construction. PSE will work to maintain access to roads and recreation sites while providing a safe working area for crews and the public. During individual pole replacement and wire stringing, the public may be temporarily inconvenienced by construction activities; however, impacts will be short in duration at each site and less than significant as confirmed in the Phase 2 DEIS at 4.6-2 and 4.6-13. Also, the transmission line upgrade does not require the construction of walls, fences or screening vegetation, which further ensures that the existing uses and circulation will not be disrupted. Access to adjacent land uses would be maintained during construction. Informal recreational activities occur throughout the Project area. There are both formal and informal recreation trails within and across several segments of the existing PSE transmission line corridor, which is generally viewed as a green belt. Trails along the Renton segment include: Sierra Heights Park trail, Honey Creek Greenway, portions of the May Creek Greenway, the Cedar River Trail (part of the Cedar River Natural Area), and Riverview Park trails. During pole installation and wire stringing, trail access in proximity to the transmission line will be limited to protect public safety. The total duration of trail access impacts will range from 3 to 7 days at each pole site depending on the method of pole installation (see description of construction techniques and duration above). Post-construction, neighboring properties will have the same uses and circulation patterns as currently exist. PSE will work with the City to ensure that appropriate mitigation measures are implemented at the Project site. Mitigation of temporary impacts to pedestrian uses during construction may include the following: avoiding construction during peak trail usage, providing alternative points of access and detours, 2-week advanced notification of temporary trail closures, and signage of temporary closures along trails or park entrances at least one week in advance of closures. Bicycle and pedestrian use of roads or sidewalks may be temporarily restricted while poles are replaced or wires strung along roads to protect public safety. Mitigation of potential impacts to traffic could include “maintenance of traffic” plans that identify traffic control and detours to maintain mobility and safety for vehicular and non-motorized travelers and maintain access to properties (Phase 1 DEIS at 1-44). Noise, Light and Glare: Potential noise, light and glare impacts from the proposed use shall be evaluated and mitigated. Response: The proposed transmission line replacement will not result in any significant noise, light, or glare impacts when completed and in use. 23 Noise. Chapter 9 of the Phase I DEIS contains an analysis of potential operational and construction- related noise impacts. With respect to operational impacts, the Phase I DEIS states that “Potential operational impacts from overhead transmission lines associated with any of the transmission line alternatives would occur from corona discharge. The maximum corona noise produced from 230 kV lines at ground level during wet weather conditions [is] a relatively low noise level that would not be noticeable in most suburban environments. . . Background ambient noise levels in suburban residential areas of King County fall between 40 and 50 dBA during nighttime hours. Even in rural areas, corona noise from 230 kV transmission lines would be unlikely to impact sensitive uses. Consequently, audible corona noise would be a negligible operational noise impact…” Phase I DEIS at 9-14. The proposed transmission line replacement may have temporary construction-related noise impacts on surrounding neighbors as many of the transmission poles are within easements in residential backyards. These impacts include increased presence of construction vehicles, equipment, materials, and personnel. Temporary construction impacts (consistent with the limited durations described above) would terminate once construction is complete. PSE will comply with all City codes and approvals relating to hours of construction and noise. Project construction will entail the installation of poles and stringing of conductor wires. Typical equipment required for installation includes vactor trucks, cranes, concrete trucks (for pouring foundations), and “boom trucks” for lifting up personnel and materials. Table 9-4 of the Phase I DEIS contains the typical noise levels for the equipment used during the Project’s construction phase. Pole installation typically requires 3–7 days each (within a 2-month work window); no significant excavation is required and installation would not create significant noise. Noise- generating activity during pole installation would occur for a relatively short period of time. The Phase I DEIS concludes that “[w]hile likely to be above background noise levels, [Project impacts] would likely be within the restrictions for construction noise in Section 12.88 of the King County Code (and most local codes), which exempt construction noise from quantitative noise exposure limits but restrict construction noise to daytime hours.” Phase I DEIS at 9-10. Any nuisance caused by the short-term construction activities would be ‘less-than-significant’ (Phase 2 DEIS 4.1.1 and 4.4- 9). Some of the areas along the Renton segment are possible candidate locations for the use of helicopters because of the complex terrain in the area. It is important to note that using a helicopter is the last option utilized by a contractor due to costs and additional FAA permitting. Although not required, one of the most efficient methods of installing new conductor on poles is to use a helicopter, which would be used to pull a rope or “sock line” from pole to pole. Once the rope is in place, the rope is then used to pull in the new conductor (wire). Non-helicopter methods required personnel to pull the sock line between poles by walking to each structure. 24 The use of helicopters is most likely for the crossing over the Cedar River. Helicopter use facilitates faster installation of wires and often includes minimizing land disturbance that may be necessary to access pole locations, thereby reducing traditional access and associated restoration costs. If helicopters are used, PSE and their contractor would comply with the local and FAA congested air permit conditions and notification requirements2, including those related to the Renton Municipal Airport. As these are specialty helicopters and work techniques, the work would likely be scheduled weeks in advance. The public notice and awareness outreach would be flexible and could be communicated in advance. Additional analysis on helicopter use will be provided in the FEIS. Light and Glare. Chapter 11 of the Phase I DEIS analyzes potential light and glare impacts from Project construction and operation. The proposed transmission line replacement may have temporary construction-related impacts. These impacts include increased presence of construction vehicles, equipment, materials, and personnel, as well as the potential for temporary increased light and glare associated with temporary construction site lighting. See Phase I DEIS at 11-25. Operational light and glare impacts would be de minimis. The transmission poles themselves are not lit. As discussed in the Phase I DEIS, “The Federal Aviation Administration (FAA) has standards and guidelines that determine when structures need to be marked and lighted for aircraft safety. It is not anticipated that aviation warning lights would be required for this project because the proposed electrical infrastructure, including transmission poles, would be less than 200 feet in height and would not exceed the obstruction standards contained in 14 CFR Part 77 (FAA, 2007).” The Phase I DEIS notes that steel poles are “more likely to result in glare impacts,” but that “[i]f steel poles are used, a non-reflective coating would be used.” Phase I DEIS at 11-37. Landscaping: Landscaping shall be provided in all areas not occupied by buildings, paving, or critical areas. Additional landscaping may be required to buffer adjacent properties from potentially adverse effects of the proposed use. Response: PSE is committed to preserving vegetation that can safely coexist with transmission lines. The majority of the existing transmission line corridor is naturally vegetated or has been planted by residents. Access to poles in critical area buffers located in the transmission corridor will generally occur using existing, partially vegetated access (established during original construction and re-used over time to maintain the corridor). Post construction, all disturbed areas will be re-vegetated, as necessary, and left to return to their natural state in compliance with vegetation management plans and requirements. Typically, crushed vegetation rebounds within one growing season resulting in only temporary impacts to vegetation. Vegetation in the existing corridor is routinely managed. The corridor was initially disturbed during original construction in the 1920s and 1930s (including clearing associated with construction 2 http://fsims.faa.gov/WDocs/8700.1%20GA%20Ops%20Insp%20Handbk/Volume%202/2_102_00.htm 25 activities for the line itself and associated access roads) as well as subsequent parking lots, subdivisions, trails, and residential and commercial development. Disturbance is regular and ongoing due to vegetation maintenance and pole replacement activities. With the exception of Honey Creek Open Space and Cedar River Natural Area, the majority of trees in the existing corridor are ornamental and associated with existing property uses. Vegetation in a transmission line corridor that has an operational voltage of more than 200 kV must be managed in compliance with federal requirements, resulting in limitations with regard to the type and scope of landscaping that is allowable. Vegetation management standards vary depending upon the location of vegetation management in relation to transmission wires. Consistent with federal standards, vegetation in the wire zone (i.e., 10-ft outside wires) must have a mature height of no greater than 15 feet, unless the local topography is sufficient to allow a 20-foot vertical clearance between the power lines and the mature height of trees under the power lines. Trees can be taller outside the wire zone. The deep ravine cut by the Cedar River allows retention of taller trees under the upgraded transmission lines. PSE will mitigate impacts to trees that are necessary to meet federal transmission line operational standards identified in the Renton Critical Areas Report (Watershed 2018). To mitigate for loss of significant trees in the transmission corridor, PSE is proposing mitigation ratios that meet or exceed regulatory standards as proposed in the Renton Tree Retention Plan (Watershed 2017). PSE will work with affected property owners, the City, and other stakeholders to replace trees in the most effective manner that meets the permit conditions. Much of the corridor is within private properties, including homeowners’ backyards, and is fenced off. PSE has been meeting with these property owners along the existing corridor to discuss tree replacement and landscaping, and will continue to work together to develop property-specific landscaping and tree replacement plans, with a focus on controlling invasive species and enhancing native species. Where individual property owners decline to have new trees planted onsite, PSE will work with the City to place additional trees offsite or will participate in the City’s fee in lieu program. Offsite options may include city parks and neighborhood groups/HOAs. One benefit of offsite planting is the option to plant larger trees that will contribute to habitat quality and area aesthetics.