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HomeMy WebLinkAboutF. Revised & Amended Request - TPWAG (1/28/2015) i Date: Wed,Jan 28, 2015 To: City of Renton Hearing Examiner Phil Olbrechts mailto:olbrechtslaw�Li)gmail.com CITY OFRENTON .dam City of Renton JAN 2 8 2015 1055 Grady Way C;�,i Renton, WA 98057 RECEIVED CIN CLERK'S OFFICE From: Tiffany Park Woods Advocacy Group mailto:renton-opposites@comcast.net 1725 Pierce Avenue SE Renton, WA 98058 Subject: Reserve at Tiffany Park PP - Hearing Examiner Decision (LUA13-001572) Revised and Amended Request for Reconsideration Dear Mr. Olbrechts: This letter constitutes Tiffany Park Woods Advocacy Group's Revised and Amended Request for Reconsideration pursuant to RMC 4-8-100(G)(9) and RMC 4-8-110(E)(13), which provide for reconsideration of a hearing examiner's decision if a party of record believes the decision is based on "an erroneous procedure, errors of law or fact, or the discovery of new evidence which could not be reasonably available at the prior hearing." TPWAG has elected to pursue this Request for Reconsideration Pro Se and hereby designates Renate Beedon as the designated representative. References • Letter entitled, "RE:The Reserve at Tiffany Park - Preliminary Plat- Preliminary Plat and SEPA Appeals - LUA13-001572, ECF, PP, CAE - Final Decision", from Phil Olbrechts - City of Renton Hearing Examiner, dated Jan 8, 2015. Scope • The Hearing Examiner's decision provides inadequate mitigation for the impacts on the environment and on the surrounding community of Applicant's proposed development to support a DNS-M determination under SEPA. • The City of Renton has authority to ask for mitigation under SEPA, and TPWAG asks the City of Renton (via the Hearing Examiner) to exercise that authority in the areas discussed in this letter. • An environmental impact statement is justified and must be prepared whenever significant adverse impacts on the environment are probable, not just when they are inevitable. If an environmental statement is required by the weight of the evidence and if the responsible city authority does not require an environmental impact statement then the decision is clearly erroneous. • The Hearing Examiner is entitled to consider newly discovered evidence not reasonably available at the prior hearing. TPWAG Revised/Amended Request for Reconsideration Page 1 of 8 r Wetland Determination, Measuring and Staking Newly Discovered Evidence Pursuant to the Hearing Examiner's Order on Request for Reconsideration dated January 22, 2015 TPWAG removed all photographs of the wetlands taken on January 16, 2015. These photographs were simply provided to show that the wetland boundary markers and wetland buffer markers are standing in bodies of water. Photographs of this condition were not readily available at the time of the hearings because the wetland studies were performed after a 3 month draught (2013) or after unusual we seasons (2014) of the year. The photographs that have been removed show typical conditions in January and bring into question the delineation of the limits of the wetlands and suggests the boundary of Wetland B and possibly wetland C were not correctly delineated. RMC 4-8-100(G)(9) provides that "any interested person feeling that the decision of the Hearing Examiner is based on "erroneous procedures, errors of law or fact, error in judgment or the discovery of new evidence which could not be reasonably available at the prior hearing" may make a Request for Reconsideration. Thus the Renton Municipal Code allows the Hearing Examiner to consider this limited discovery of new evidence. TPWAG believes that the wetland photographs removed from this Revised/Amended Request for Reconsideration fall into this category of evidence and should be considered by the Hearing Examiner. TPWAG requests that they be allowed to resubmit these photographs as newly discovered evidence. Problems • One of our concerns is the wetlands and the way they have been determined, measured and staked. As you can see from our comments below, we believe that the wetland depiction alone has been done incorrectly and therefore question the way other studies pertaining to this development have been conducted. An EIS would clearly provide the city and all interested parties with information that is correct and fully evaluate the significant adverse impacts on the environment. The original study by OTAK pointed out many discrepancies in the original study submitted by Schulz. The OTAK study claimed that the wetlands are actually larger than described in the original study submitted by Schulz. After the Applicant received the OTAK study, a meeting was held between the City of Renton, Schulz and OTAK. At that on-site meeting the Applicant apparently convinced the OTAK consultants that the original study by Schulz was correct and the OTAK study was not. If you look at and compare both reports, you can see significant changes between the two versions of OTAK studies. TPWAG requested minutes for this meeting from the City of Renton and was told that there were no minutes because this was a "field trip" and that the two revised wetland reports from Schulz and OTAK were record enough. Apparently, there is no written record of what was said and decided by whom during this off-site meeting in the woods. One thing the participants of the "field trip" did agree on is the addition of wetland D. TPWAG Revised/Amended Request for Reconsideration Page 2 of 8 OTAK Secondary Review Memo-43-1, • We are providing you with a Tree Cutting/Land Clearing Plan, which shows how the proposed lots (in particular lots 70, 79 and 80) appear to encroach onto the wetlands B and C. • Also encroaching onto wetland C is a street. On the "Preliminary Cover Sheet for Tiffany Park" chart it looks like the street is cutting right into the wetland. / VW CUrTNOAAM CLE~KM• PM ,'�-----, ,e\ ��` REBF•RYS AT TIFFANY PARK r 'iii'! "tb • Tc �` r s `t• �_ WaBIT 11 • These encroachments appear on the Tree Cutting/Land Clearing Plan dated in 2014. (Date is too small to read). TPWAG Revised/Amended Request for Reconsideration Page 3 of 8 w • The maps provided by thr iplicant show that plats and streets al-- ,dy encroach onto wetland boundaries acknowledges ,,y the Applicant. If we, TPWAG, are co{,._ct in our assumption that the wetlands have been marked incorrectly and that all the wetlands are bigger than depicted by the Applicant, than the proposed lots and street will greatly violate the wetland buffers and therefore the wetland code/regulations, etc. • We believe that this aspect alone should call for an EIS, since it is possible that more errors or oversights like with the wetlands have been made throughout the whole proposed development. • We hope that at least the wetland delineation will be revisited and re-staked and then reviewed again • (A visit to the City of Renton Clerk's office on Monday,January 26, 2015 by TPWAG revealed that several sets of original drawings were incomplete, thus we were unable to study these drawings in conjunction with our request for reconsideration. The city planner, Ms. Timmons, told TPWAG that the drawing dated August 2014, is "old". This "old" drawing showed the presence of a storm water retention pond rather than a vault as presented during the Hearing Examiner's meetings in 2014. After Ms.Timmons left, we looked for newer drawings but could not find any. The City Clerk staff told us that they were not in possession of newer drawings.) Relief Requested • Discount the one-sided testimony of Applicant's wetlands expert (because the property owner refuses to allow TPWAG to bring an independent expert on the property) • Require the property owner to allow TPWAG to bring a wetlands expert on site, allow adequate time to find an expert who is willing to work with private citizens, allow adequate time for the expert to prepare a report, and then hold a meeting to examine the results. TPWAG requests that it be invited should such a meeting take place. • Direct the Applicant and City Staff to make a complete set of original drawings available for review by the public as soon as possible to support this process. • Require an EIS to resolve the unanswered probable significant environmental impacts as raised by Steve Neugebauer in his testimony before the Hearing Examiner, and as are raised in this letter. Trees Problems • A 10 foot buffer around the property is inadequate, not only because of esthetic value but also because it does not provide sufficient protection from the high winds that occur regularly in our area. • During the Hearing Examiner's meetings on Nov 18, 2014 and Dec 8, 2014, we witnessed public testimony from Claudia Donnelly and Jill Jones showing how the developer had apparently removed all trees from another development, even though the City of Renton requires them to retain trees. Relief Requested • Require a buffer of at least 20 feet around the property • Therefore, we request that the City of Renton ensure that the developer doesn't intentionally or carelessly damage the few trees that are required to be retained under city ordinance, and then use that as legal loophole to circumvent city ordinance and remove the "damaged" trees. • Consider assigning a person on site during construction hours to monitor activities to ensure code compliance. • Consider steep fines for careless or intentional damage to trees. TPWAG Revised/Amended Request for Reconsideration Page 4 of 8 • If trees are damaged and ry -t be removed, require Applicant to red- ' -:e the damaged trees with equivalent *mature* trees, _.id prohibit them from using any of the ,riginal canopy from the removed tree for any purpose other than to allow the new tree to grow. Storm Water Problems • Per Steve Neugebauer's testimony, removing trees will remove 75% of the property's ability to process storm water. • 24" pipe (as proposed by Applicant) is barely good enough for a 10-year storm. 100-year storms are common. We may have a few 100-year storms in any calendar year. Thus, it is likely that the neighboring properties will be flooded regularly as a result of the proposed development. Relief Requested • Consider requiring a larger storm water drainpipe along SE 18th Street. • Consider requiring "pervious" pavement (that allows water to pass through it) on all streets, sidewalks and driveways, so that the storm water can be naturally mitigated on site. • Consider requiring retention of at least 6" of topsoil on all exposed surfaces (e.g., lawns) to minimize the need for watering, and so that the storm water can be naturally mitigated on site. • TPWAG requests that storm water management studies, calculations be completed in compliance with the City of Renton Storm Water Management Requirements, as further defined by the adopted King County Surface Water Design Manual; sections which specifically address this issue are titled: Core Requirements#2 Off site Analysis, and Core Requirements#4 Conveyance Systems. The City of Renton has some added amendments for special community situations. Roof Runoff Problems • Although roof runoff by itself may not be a pollutant, when it is mixed with chemicals and pesticides used in the yard it becomes a pollutant. • Although roof runoff may not be a target pollution-generating surface, roof runoff is still subject to flow control per Core Requirement#3 which mandates that the City may require design adjustments per the wetland hydrology protection guidelines in Reference 5. • KCSWDM Reference 5, Wetland Hydrology Protection Guidelines, mandates that a wetland may not be structurally or hydrologically engineered for runoff quantity or quality control in Category 2 wetlands. (We have attached the Wetland Hydrology Protection Guidelines.) Applicable Laws The Hearing Examiner's Order on Request for Reconsideration provides that "applicable laws are not considered new evidence." The Wetland Hydrology Protection Guidelines are part of the King County Surface Water Design Manual. Section 6.2 of the KCSWDM provides "roof runoff is subject to flow control per Core Requirement#3. Section 1.2 of the KCSWDM provides that where there is potential impact to wetland hydrology, "DDES may require design adjustments per the wetland hydrology reference guidelines in TPWAG Revised/Amended Request for Reconsideration Page 5 of 8 Reference Section 5. Therefore th' -ection is merely summarizing applical�'--law and should be considered by the hearing examiner. Relief Requested Applicant should comply with the Wetland Hydrology Protection Guidelines Traffic Problems • Applicant's expert has testified that the level of service on the roads surrounding the proposed development will be acceptable per the applicable city and state laws. However, that analysis did not address the impact of converting SE 18th Street and 124th Place SE from quiet cul-de-sacs into arterials for the traffic from almost 100 new homes (over 1,000 vehicles per day- mostly on SE 18th Street- by Applicant's own estimates). • Realtors know that the difference in value between a house on a busy street and a house on a cul-de- sac is significant. • We have researched home prices on quiet and cul-de-sac streets vs. busy streets. Those findings showed that the 16 homeowners on SE 18 Street can probably each expect a $30,000 loss in property value as a result of the increased traffic on this street should the development go forward. The city has noted to that they take no responsibility for any loss sustained. More ingress and egress points to the development would certainly help to disperse the traffic. (Roenicke Testimony.) • Applicant also seems to be well aware of this fact. The planned development contains not one, but two cul-de-sacs (instead of building adequate roads to carry traffic in and out)! • We respect Applicant's right to develop their property, but we expect the applicant to respect the property rights of the surrounding community. We believe that Applicant is maximizing its profit by unfairly externalizing its costs to the neighboring property owners. Relief Requested • We ask the City of Renton to intervene to ensure equal protection under the law. • Consider substantially reducing the number of allowable houses in the proposed development. • Consider requiring at least one more access road to the proposed development (even if Applicant has to buy existing houses to create such access). • Consider removing speed bumps that are blocking arterial streets to the South (especially 126th Avenue SE, SE 164th Street, and SE 160th Street). This will provide less incentive for drivers from the proposed development to avoid the back entrance (i.e., 124th Place SE) and for drivers coming from Fairwood to use Pierce Ave SE and SE 16th Street. • Consider street modifications to encourage traffic to use Royal Hills Drive SE instead of SE 16th Street. Royal Hills Drive SE is currently a bus snow route. It is a wide road, it has a gentle incline, it has good sight distance, and it is sanded when icy, so it is much better suited for the heavy volume of traffic than is SE 16th Street. 1. Re-open the north end of Beacon Way SE to Puget Drive SE. 2. Close the intersection at SE 16th Street and Edmonds Avenue SE. Local traffic will be able to use the newly opened Beacon Way SE, and traffic from Edmonds Way SE will no longer have to fight arterial traffic on SE 16th Street to leave their neighborhood. TPWAG Revised/Amended Request for Reconsideration Page 6 of 8 t Environmental Impact Statement Problems • An environmental impact statement is justified and must be prepared whenever significant adverse impacts on the environment are probable, not just when they are inevitable. If an environmental statement is required by the weight of the evidence and if the responsible city authority does not require an environmental impact statement then the decision is clearly erroneous. • The problems raised in this request for reconsideration, together with the issues raised at the appeal hearing, coupled with Applicant's refusal to provide full documentation of environmental conditions at the site and the full extent of structural retaining walls at the site, and the piecemeal manner in which the City of Renton and the Applicant addressed problematic issues for the wetlands, detention vault, drainage and retaining walls, weigh in favor of requiring preparation of an environmental impact statement. Relief Requested • The City of Renton should require an environmental impact statement for the project. Respectfully submitted by Tiffany Park Woods Advocacy Group with the hope that you reconsider our issues. Thank you. RENATE BEEDON President cc: Rocale Timmons mailto:RTimmonsLcDRenton�,va.gov Nancy Rogers mailto:NRoaersid)Cairncross.com TPWAG Revised/Amended Request for Reconsideration Page 7 of 8 �t E - 4� 4A, � y Iti'vaiNib Cedar T4sRiver .. . a Grdft Severlk � s impact m OCSE �:�-. �ttitM1 St p ASF Qc. cw to 4 .. tl.idren ddw 1%e �y young ren.. > m R ,�tau Ow - inn K A aVA 4 Severe � h LU -SE Ct impact � fy * �� =rcpt ed enakin by bLe+� py ' ^N' _SE ISM St �'!F many►+rkd"�� Cr, i:-veicpmer,t 4 { �,,p �g � se 1" 1� Pwa&, Cdo V ue w Severe impact - -,.SE 21st St - -� ., Zt Grade Vhb chidwe SE 160th St _ S r c ed .. - - SE lfi th St-_ - SE IM St - v- wvkwkka aCNK.Kle K .camps" l ou irs4,10 SE SE16tstSt SE 162nd St - >a i " SE 162nd St SE 162nd St 4 SE 163rd St SE 163rd St SP —d < ` 3�d 7 b.ar,rS $E%ft%tst SE SE 164th St SE 164th St Figure 1 -Area Map TPWAG Revised/Amended Request for Reconsideration Page 8 of 8 f Technical Memorandum To: Rocale Timmons, Senior Planner City-of Renton - Current Planning 10230 NE Points Daae From: Darcey Miller, Senior Wedand Scientist Suite 400 (425) 739-7977 Kirkland, RA 98033 Phone(423)8224446 Copies: Fax(423)827-9377 Date: April 3, 2014 Subject: Reserve at Tiffany Park Wedand Delineation Review Project No.: 32385.A This review pertains to the Preliminary-Plat application for the Reserve at Tiffany Park (City- of Renton LUA13-001572) submitted by the applicant, Novastar Development, Inc., to the Citi-of Renton (City). The proposed Reserve at Tiffany Park is located generally to the east of Tiffanv Park, to the north of SE 158" Street, and south and west of Pierce Avenue SE. Otak has been asked by the City- of Renton (the City) to review the submitted critical areas document and to provide comments regarding its applicability to the Renton NIunicipal Code (RN1C), specifically, Section 4-3- 050, Critical Areas Regulations. The following documents were reviewed in terms of compliance with the critical areas sections of the City-code: • Vetland Determination:Reserve at Tiany Park, prepared by C. Gary Schulz, dated February 28, 2014; • Plan set for the Reserve at Tiffany-Park Preliminary=Plat,prepared by Barghausen Consulting Engineers, Inc., signed February-27, 2014. • Technical Information Report, prepared by Barghausen Consulting Engineers, Inc., dated November 12, 2013,and revised February 24, 2014. The Wetland Determination identifies three Category-2 wetlands and one Category 3 wetland on the site,which are required to have 50-foot and 25-foot buffers,respectively. The report indicates that wetland buffer averaging is proposed for the project site, and outlines the rationale for meeting the requirements for buffer averaging described in the R IC. K:Aproject\32300\32385:A\Reports\Cri6cal_areas Review Memo_2014_0403.doe Rocale Timmons, Senior Planner, City ofRenton Page 2 Reserve at Tiffany Park 1L"etland Review Apri13,2014 Two Otak wetland biologists visited the site on March 17, 2014, to confirm whether the wetland delineation was consistent with the IYlarhington State Vetlands Identification and Delineation Manual (Ecology 1997), as required by the RhIC. An Otak biologist made an additional site visit on March 31, 2014. Please note that the wedand delineation was performed in June 2013,whereas the rainfall amount as of March 17,2014,was approximately 5.58 inches above the normal amount for March (National Weather Service);and on March 31, 2014 was 5.85 inches above normal for March. Comment 1 — Delineation Method The wetland determination report cites the US Army Corps of Engineers wetland delineation manuals (1987 and 2010 supplement) for the methodology used. However, the Vashington State Vetlands Identification and Delineation Alanual(Ecology 1997) is required by RMC 4-3-050.NI.4.a. Recommendation: The applicant should ensure that the wetland delineation is consistent with the methodology required by the RMC. Comment 2—Survey Map We have not seen a survey map showing all of the wetland flags,which is necessary for confirming the wetland delineation.As discussed below, some wetland flags were not found in the field; however, if we have a detailed map and some of the flags remain, all of those missing flags may not need to be replaced. Recommendation: The applicant should submit a map showing all of the surveyed wetland flags (from June 2013 and any upcoming revisions). In addition,missing wetland flags should be replaced as deemed necessary for Otak's confirmation of the wetland edges. Comment 3—Wetland A We agree with portions of Wetland A's delineated edges. However,we could not find some of the flags (including Wetland A-1) in the southern part of the wetland. It appears that the wetland areas extend farther out than the delineated edge, specifically near Flags A-1,A-3,A-5, and A-6. In these areas,we observed hydrophytic vegetation (if any plants at all), hydric soils, and wetland hydrology (mainly inundation). On March 17, 2014,in some areas that appeared to be outside of the delineated (flagged) wetland,inundation was over 1 foot deep during our site visit (see Photograph 1). We agree that Wetland A meets the criteria outlined in the RMC for a Category 2 wetland,which is required to have a 50-foot buffer. Recommendation: Wetland A should be reexamined and any differing edges re-flagged during the early growing season (before mid-May). Any changes to the wetland should be included in the revised Wetland Determination Report and project plans. K:\project\32300\32385. \Reports\Critical Areas Review Nlemo_2014_0403.doc Rocale Timmons, Senior Planner, CityofRenton Page 3 Reserve at Tiany Park lf'etland Revieav April3,2074 Comment 4—Wetlands B and C During our site visits, standing water extended generally- 10 to 70 feet farther than the delineated edges of Wetlands B and C. In addition,Wetlands B and C are not separated by upland area; they appear to be part of the same wetland. On March 17, 2014,inundation ranged from several inches to 1.5 feet deep in areas that may be outside of the delineated wetland edge. Hydrophytic vegetation (mainly- salmonberry>and red alder) and hydric soils were also observed in the majority-of these areas. We agree that Wetland C meets the criteria outlined in the RMC for a Category-2 wetland, which is required to have a 50-foot buffer; however, because Wetlands B and C are connected (one wetland), the area flagged as Wetland B would also be considered a Category-2. Recommendation: Wetlands B and C should be reexamined and any differing edges re-flagged during the early growing season (before mid-Nlay). Confirm the rating and buffer size for Wedand B. Any changes to the wetlands should be included in the revised Wetland Determination Report and project plans. Comment 5—Wetland D We agree with the majority-of the wetland flag locations on Wetland D, although the wetland appears to extend approximately 25 feet to the south of Flags D-3 and D-4. We agree that Wetland D meets the criteria outlined in the RMC for a Category-2 wetland. Recommendation: The wetland should be reexamined and any differing edges re-flagged during the early growing season (before mid-flay). Any changes to the wetland should be included in the revised Wetland Determination Report and project plans. Comment 6—Offsite Wetland (SW side Mercer Island Pipeline ROW) An offsite wetland adjacent to the Reserve at Tiffany Park site was observed on the southwest side of the Mercer Island Pipeline Right-of-way (see Photograph 2). The northwest end of the wetland is southwest of(in line with) 18`h Court SE. This linear wetland is approximately 150 to 200 feet long and contains hydrophytic vegetation (creeping buttercup, reed canarygrass, and other grasses) and hydric soils. Wetland hydrology observed on Nfarch 17, 2014, ranged from saturation at the surface to saturation at 4 inches below the surface. This wetland likely meets the criteria in the Ri'NIC for a Category 3 wetland,which is required to have a 25-foot buffer. Recommendation: If permission is granted from the offsite landowner, the wetland should be delineated, classified, and added to the revised Wetland Determination Report and plans. If permission for delineation is not received, the wetland location should be estimated and shown on the plans, along with the buffer. K:\proiect\32-300\323853\Reports\Critical Areas Review blemo_2014_0403.doe Rocale Timmons, Senior Planner, City of Renton Page 4 Reserve at Tiffany Park If'etland Review April 3, 201.1 Comment 7—Offsite Wetlands (NE side Mercer Island Pipeline ROW) Several offsite wetlands were observed on the northeast side of the Nlercer Island Pipeline Right-of- way (northeast of the gravel access road). These wetlands appear to be Category 3 wetlands;if so, they are likely far enough away so that their 25-foot buffers do not extend onto the project site. Recommendation: The applicant should confirm that buffers from these offsite wetlands do not extend onto the property. Comment 8—Wetland in Southwest Corner of Site A wetland was observed in the southwest corner of the site, to the north of SE 18`h Street and southeast of the adjacent development's fence. The area was dominated by salmonberry, Himalayan blackberry, and reed canarygrass. On Nlarch 17, 2014, hydric soils and up to 4 inches of inundation were observed, and water was draining from the wetland onto the sidewalk along the north side of SE 18`h Street. Recommendation: The wetland (if it is determined to be one) should be delineated, classified, and added to the revised Wetland Determination Report and project plans. Comment 9—Flowpath from Wetland B During our March 17, 2014 site visit,water was observed flowing generally west out of Wetland B to the southwest corner of the project site (see Photographs 3,4, and 5), then offsite into the Cedar River Pipeline Right-of-way. The wetted width of the floxvpath onsite on Nlarch 17`h was approximately 3 to 6 feet, and the water depth was 1 to 3 inches. Vegetation on the edges of the stream generally consists of upland species such as Indian plum. A defined stream channel with bed and banks was not observed. Sorted gravels were observed in several small portions of the flowpath; however, these gravels were generally angular and therefore have not been subject to flow strong enough to round their edges. During our Nlarch 31, 2014 site visit, no water was observed along the flowpath that had been observed on Nlarch 17`h. Standing water was present at Wetland B (beyond the flagged wetland edge), but no flowing surface water was observed exiting the wetland. No streams are mapped on or adjacent to the site. The closest stream is Ginger Creek, approximately 800 feet offsite to the west. Ginger Creek is a Class 4 tributary to the Cedar River, per RMC Figure 4-3-050-Q4 (Streams and Lakes). Given the above information, it is our opinion that water flows through this area only during/after high rainfall events, drains quickly, and that the area does not meet the definition of a stream. Recommendation: No action is necessary. K:\project\32300\32385. \Rep orts\Critical areas Review N1cmo_2014_0403.doc Rocale Timmons, Senior Planner, City of Renton Page 5 Reserve at Tiffany Park Fetland Review April 3,2014 Comment 10—Offsite Wetland (Cedar River Pipeline ROW) The flowpath described in Comment 9 drains into the Cedar River Pipeline ROW, to the southwest of the southwest corner of the Tiffany-Park site. Inundation was observed in the area, as well as FAC or wetter vegetation and potentially hydric soils; therefore, the area appears to be a wetland (see Photograph 6). Recommendation: The wetland (if it is determined to be one) should be delineated, classified, and added to the revised Wetland Determination Report and plans. Comment 11—Buffer Averaging The buffer averaging proposal in the Wedand Determination Report has demonstrated that it meets all of the requirements in RNIC 4-3-050.NI.6.£ However,revisions to wetland edges will likely change this proposal. Recommendation: The applicant should revise the buffer averaging proposal to be consistent with the any necessary-revisions to the wetland edges and wetland buffers onsite. Comment 12—Temporary Buffer Impacts Sheets 6 and 7 of the plan set (Preliminary Grading Plan) show disturbed areas in wetland buffers that will result from grading and wall installation. These temporary-buffer impacts are not discussed in the Wetland Determination Report, nor are they shown on Figure 2 in the report. Recommendation: The applicant should revise the wetland documentation to discuss all temporary- impacts to wetland buffers, including impacts to specific functions and how restoration will replace those functions. A restoration planting plan for the disturbed areas should be provided as part of 60°,o design. Encl. Photographs K:\project\3_'300\32355.1\Reports\Critical:areas Revim Dlemo_2014_0403.doc Rocale Timmons, Senior Planner, City of Renton Page 6 Reserve at Tiffany Park Vetland Revie2v April 3,2014 PHOTOGRAPHS Photograph 1: Wedand A, near southern delineated edge (3/17/14) Photograph 2. Offsite wetland on Mercer Island Pipeline ROW, facing SE (3/17/14) K:\project\32300\32385-k\Rt--ports\CriticaI Areas Review Nlemo-2014-0403.doc � . ; .y, •�t sir.. � �'1� •,S k. va.` FIF a /• —_le- 41 r ZI kA .k. T /t < Y '1�+��_ n }, �•,,a .. y: -�� x s,gad' .. ...,�,,. �,�..;- fa v�y�1 ��1.� �t, , ice+•~/ �.••^•` �./ /t ,, �t"�S� �;.: +J` ..� t f✓ "+ ,mow.{ �/° T .