RE: The Enclave at Bridle Ridge Preliminary Plat lua14-000241, ecf, pp

P
.O. Box 2936 Renton, WA 98056 206.888.7152 [e-mail]

Phil Olbrechts

Hearing Examine

City of Renton

1055 S Grady Way

Renton WA 98057

June 24, 2014

RE: The Enclave at Bridle Ridge Preliminary Plat - LUA14-000241, ECF, PP

Dear Mr. Olbrechts,

This copy of my notes is provided for easy reference in the record. We offer a few attached exhibits as well to which I will refer in my remarks.

Thank you,

Gwendolyn High

CARE President

P.O. Box 2936 Renton, WA 98056 206.888.7152 [e-mail]

Gwendolyn High will represent CARE in this matter. She is co-founder and President of CARE and has led CARE’s previous participation in these comparable Land Use Actions in the community:

Evendell Preliminary Plat and Rezone (KC DDES file No. L01P0016 and L01TY401)

Liberty Grove Preliminary Plat and Rezone (KC DDES file No. L03P0006/L03TY403)

Liberty Grove Contiguous Preliminary Plat and Rezone (KC DDES file No. L03P0005/L03TY401)

Nichols Place Preliminary Plat (KC DDES file No. L03P0015)

Highlands Park Preliminary Plat (Renton LUA -05-124, PP, ECF)

Threadgill Preliminary Plat (KC DDES file No. L05P0026)

Heritage Preliminary Plat (KC DDES file No. L07P0009)

Cavalla (KC DDES file No. L06P0001 and Renton LUA08-097)

Liberty Gardens Preliminary Plat (KC DDES file No. L04P0034 and Renton LUA08-093)

Heritage (KC DDES file No. L07P0009)

Saddlebrook (Renton LUA12-077)
CARE has represented the needs and concerns of the East Plateau residents since 2001, as a group of concerned and likeminded neighbors. We incorporated and were recognized as a 501c4 nonprofit in 2003. We have an email list of over 400 households.
CARE households own properties and reside in the community surrounding the proposed project. There is considerable potential for this community and the environment to be directly and adversely affected if the subject application is permitted without adequate conditions to mitigate increased traffic, light and stormwater.
CARE’s participation in this matter is in the public interest. We are primarily interested in ensuring coordinated and responsible land use decisions in this community consistent with state and local laws and regulations. We bring historical experience and familiarity with the existing conditions of our community as well as the detailed understanding of the potential negative impacts that must be adequately mitigated. Our intent is to facilitate the appropriately thorough consideration of the facts that bear on this proposal.
This document is not a formal legal argument, but documents the concerns of the community and our requests for adequate mitigations to properly accommodate the impacts from the construction and eventual occupation of the proposed Enclave at Bridle Ridge subdivision (Enclave).
GENERAL ERRORS:

Staff’s Report to the Hearing Examiner page 3:

“E.1.b. Sewer: Sewer service will be provided by the City of Renton. There is an 8-inch sewer main in 156th Avenue SE."

Contradicted on p.12 of same report.

“E.1.c. Surface/Storm Water: There is a 12 inch storm pipe in 156th Avenue SE to the north of the project."

Pipe is to the south of the project and an open ditch is to the north.

TRANSPORTATION:

TraffEx TIA page 3:

“156^th Ave SE is straight and flat at the access streets with excellent sight distance in both directions.”
This is a true statement, but it is insufficient to fully describe the situation. SE 142^nd PL is not straight at this location and has terrible sight distance. When there is any vehicle waiting at the southbound stop sign on 156^th Ave SE, any vehicle waiting to turn either right or left from SE 142 PL onto 156^th AVE SE will not be able to see. This will be particularly dangerous when vehicles is entering or leaving the proposed southern access for the project. The driver will be obstructed by the telephone pole in front of the stop sign and the southbound car, and will not be able to see any exiting vehicle on the access street. In a scenario with a southbound vehicle turning left into the project, the driver will be further obstructed by a solid fence and vegetation. If the tractor trailer truck that lives at parcel# 5336700015 is parked where is usually is – the driver will see that truck and very little else. Please see the accompanying SightLineIllustration.pdf.
TraffEx TIA page 4:

“A 3% per year annual background growth rate was added for each year of the two year time period (for a total of 6%) from the 2013 traffic count to the 2015 horizon year of the proposal. The 3% per year growth rate should result in a conservative analysis since the growth in traffic volumes has remained relatively flat the last several years.”

There is no citation to support these assumptions, we therefore ask that the following questions be answered and considered in evaluating the reliability of these unsupported assertions.

• 
  Where did this data come from and by what standard is it justified?
  
• 
  How have the pipeline projects being built and occupied now been accounted in the analysis??
  
• 
  How have past and proposed cuts in transit service accounted in the analysis?
  
• 
  How have the effects of the improving economy, and the resulting increase in people commuting to work accounted in the analysis?
  
• 
  Did TraffEx regularly measure the traffic rates over “the last several years” in order to be have this data available for this TIA?
  

ROAD STANDARDS:

Report to Hearing Examiner page 10 under Streets section:

"As per code, the minimum separation of intersections along an arterial is 125 feet."
TraffEx TIA page 4 and on to 5:

“The south site access is located approximately 250ft north of the 156^th Ave. SE/SE 142^nd Pl. intersection and therefore meets the standard.”

The southbound stop sign and crosswalk for this intersection is located about at the center point of parcel# 5336700015 which is approximately 70 feet north of the southern boundary of the Enclave site. Figure 2 of the TIA shows that the stormwater tract is proposed to be 95.24 feet wide and Lot 19 is proposed to be 94.59 feet. This yields a measure of 189.86 feet north of the southern boundary of the Enclave site as the proposed location for the south access to 156^th Ave SE. 189.86-70 yields a measure of 119.86 feet which fails to meet the intersection distance standard of 125 feet. Please see the accompanying 156thAveSEIntersectionLocation.pdf. Therefore, we request that the street access as proposed be rejected.
The original Traffic Impact Analysis (Exhibit_B_-_Traffic_Impact_Analysis.pdf) states (bottom of page 2) that 156th Ave. SE is a "minor arterial". Based on the traffic volumes Renton reported as a result of the citizen recommendation to investigate the need for signalization earlier this year (and which Roger Paulsen graphed) the road segment including this intersection should be classified as at least a minor arterial (12K Average Daily Trips). The table in the code indicates a need for 4 lanes and 91' of pavement to properly accommodate such such levels of use. If the project is permitted as proposed, there is no indication that sufficient right of way will be required to accommodate the eventually required upgrades - particularly considering this is officially designated as a bypass corridor in need of arterial improvements in the attached WADOT I405 Corridor Plan (I405MasterPlan_052808.pdf).
Report to Hearing Examiner Page 9 under Streets:

“The cul-de-sac must meet City of Renton code and Fire Department requirements.”

Report to Hearing Examiner Page 10 under Public Services:

No comment recorded from Fire Department re: cul-de-sac.

There is no evidence in the Exhibits made available to the public that the cul-de-sac meets the specified standards. Therefore, we request that the street plan as proposed be rejected.
Report to Hearing Examiner Page 10 under Schools:

“Any new students from the proposed development would be bussed to their schools. The stop is located approximately .06 mile from the project site at 156^th Avenue SE & SE 5^th Place. The proposed project includes the installation of frontage improvements along the 156^th Avenue SE frontage, including sidewalks. Students would walk a short distance along 156^th Avenue SE north of the project along the road shoulder to the bus stop. However, there appears to be adequate area along the road shoulder to provide safe walking conditions (exhibit 25)…

Continuing on Page 11:

The bus is traveling south students would be required to cross 156^th Avenue SE at SE 5^th Place via the existing crosswalk. The driver stops traffic to allow the students to cross 156^th Avenue SE and board the bus.
New sidewalk from this project will only extend less than halfway to SE 5^th PL. The crosswalk sign is obscured by vegetation. Kids will walk along this arterial, in the dark and rain, in the shoulder ROW, and cross before the bus arrives in order to be there waiting when the bus arrives. Without a lighting plan the public has no way to evaluate what lighting improvements will be made. There should be some improvements to the crosswalk, such as the flashing lights in the pavement on the nearby Duvall Ave SE which is also and arterial on the same I405 Corridor bypass route, to ensure students’ safety under normal conditions during most of the school year.
INTERSECTION IMPROVEMENTS:

Carlos e-mail.pdf

From: Nancy Thompson

Date: Wed, May 14, 2014 at 3:30 PM

Subject: Proposed Signal on Northeast 142nd Place at 156th Avenue Northeast

To: "[e-mail]"

Cc: Chris Barnes <[e-mail]>, Ron Mar <[e-mail]>
Our Traffic Operations Section conducted a signal warrant analysis at this intersection. We have determined that a new signal here could help handle the increasing traffic volumes that pass through this intersection. Using the signal rating system developed by the Washington State Department of Transportation, we have placed this intersection on a priority list for the installation of a new signal.
From the MEMORANDUM of 4/18/2014 from Neil Watts (PRR-14-085-Memo.doc):

“Any additional off-site improvements identified through SEPA or land use approval will also be completed prior to recording of the plat.”

2014-2019 Transportation Improvement Program page 5-25 (TIP sheet.pdf):

“[h]istorically, on average, one traffic signal is designed and constructed every 2 years.

It is our understanding that funds from the developer for the project's impact must be used for that purpose within 6 years or returned to the developer. Since the available evidence indicates the signalization cannot be expected within that time limitation, we must expect the mitigation funds to be forfeit and an even longer wait than the 18 years as a result of this loss of funds. This project should not be approved until a plan for the required intersection improvements are programmed – planned and funded.
From 4/15/14 email from Steve Lee responding to Roger's Records Request (Public Records Request_1_Reply.pdf):

“The Transportation Division has currently provided some direction as to an initial response with the statement, "Within the City of Renton, the steep topography between Maple Valley Highway and the upper plateau (and on to Cemetery Road) makes it in feasible to provide additional access. Widening 1-405 (which the State is pursuing) to provide more traffic capacity could attract some traffic now using 156 th SEto access Cemetery Road."

These statements contradict everything we have ever heard since 2001. We have been assured by WA DOT, King County, and the City of Renton that there is no option to provide additional north-south access to the East Plateau from the Cedar River Valley. Additionally, while widening of I405 might add capacity, we are not aware of any even preliminary plans for such activity. If such work has been done, please provide copies. If it does not exist, then this is irrelevant speculation and of no use in evaluation the impacts of this project or the appropriate mitigations/improvements for this corridor.
What is not speculation is all the other development activity in the area.

• 
  The Enclave project at the 3 Way stop, Hearing on Tuesday, will add 31 houses.
  
• 
  Alpine Estates (Alpine Nursery) is in pre-app for 29 lots (which requires two access/exit roads. It lies between 160th Ave SE and 161st Ave SE).
  
• 
  The 4.5 acres on the west side of 156th at SE 6th (SE 139th Place) is in annexation (the plan is for 14 lots with a through street between 154th Ave SE to 156^th Ave SE.) They tried to include the 5 acres on the west side of 154th in their annexation also, but could not get the required 60% signatures.
  
• 
  The Burnstead Co. is putting 14 homes, Maplewood Park East, on the parcel at 6101 NE 2ND ST (SE 132nd and 152nd Ave S).
  
• 
  The parcel at Nile (148th Ave SE) and NE 2nd St. (SE 132nd) is slated for 7 lots.
  
• 
  There is also an 8 lot parcel in pre-app on the east side of 160th Ave SE at SE 140^th St.
  
• 
  There is 2 lot short plat at 156th Ave SE and SE136th St.
  
• 
  There are 46 homes planned for the Copperwood project which is slightly southwest of Maplewood Heights Elementary. The listed address for the project is 5001 SE 2nd Pl. The project sign is on SE 2nd Pl just west of where it intersects 144th Ave SE
  
• 
  And there are 4 plats being actively developed at 210 Duvall Ave SE
  

31 + 29 + 14 + 14 + 7 + 8 + 2 + 46 + 4=155

The Highway manual standard is to calculate 9.9 vehicle trips per day per house so:

155 x 9.9 = 1534.5 new trips per day.
Most will travel some portion of the 156th Ave SE corridor, but each project will be considered independently. The cumulative impact will continue to accrue, and the infrastructure deficit will remain for decades. Virtually all of this traffic will traverse the corridor from the intersection of 154th Ave SE & SE142 Pl (the first intersection at the top of the hill – Tom Carpenter has more detailed information, and there is an email from a neighbor at the end of this document) through the 156^th Ave SE and SE 142^nd Pl all the way through the intersection of 156^th Ave SE and SE 128^th St. The proposed new connections to SE 156^th Ave SE from this project are at the heart of this vital regional corridor. The travelshed is already over-burdened. We are in the midst of a new development surge. This quality of life in this community and safety of thousands of daily commuters in this corridor new, and it is the City of Renton's responsibility to provide infrastructure to meet the needs of the development it permits.
STORMWATER/DRAINAGE:
Report to Hearing Examiner page 11 under Public Services at the bottom of the page:

"The applicant shall be required to create a homeowner's association of the maintenance agreement for the shared utilities, stormwater facilities, and maintenance responsibilities for all shared improvements of this development."
Despite the garbled sentence structure, it seems clear the intent is for the HOA to be responsible for maintenance of the pond and stormwater system. It was our understanding that the code had changed and Renton was taking ownership of all new subdivision stormwater facilities now.
ERC Report page 5:

"According to the TIR (Exhibit 9)the upstream areas are densely vegetated and any flows entering the project site would be negligible."
Even though this community is on a plateau and not in any flood plane, there are historical drainage complaints everywhere (Drainage Complaints). Even this project site itself has experienced flooding due to a plugged culvert as recently as 1997. The site is directly north of the major groundwater induced landslide in 2006 that blew out the side of the cliff above the Cedar River and filled several houses with mud and debris. The vast majority of development on this plateau occurred in the 1960s, well before the first King County Drainage Manual (the basis of Renton's stormwater regulations) were adopted in 1964. It will take many more decades to slowly address the systemic lack conveyance and water quality. The system that exists is poorly maintained and chronically undersized. Our homes exist is a state of fragile equilibrium. Every new development pushes the system
CARE has the longest and most consistent participation in land use applications and project implementation in this area. In every single project we have participated in (see list above) we have won Level III drainage mitigations. Nonetheless, these measures have consistently proved insufficient. We have had to participate repeatedly when these mitigations have failed and neighbors downstream of those projects have suffered serious damages to their homes and properties (list drainage complaints and list properties affected by the different projects). Due to our highly compacted Alderwood soils, surface flows are intense to begin with. Since the major wave of development in the 1960s, existing homeowners have implemented site-specific mitigations to deal with this situation, but every time a new project is cleared, new measures have to be installed. Level III drainage mitigations should be required here, too.
LANDSCAPING/TREE RETENTION:

Report to Hearing Examiner page 6:

Proposal to plant Heavenly Bamboo, which is an invasive species with berries poisonous to native birds and should not be used in a plat landscaping plan.

http://www.oregonlive.com/hillsboro/index.ssf/2013/12/heavenly_bamboo_the_red_berrie.html (Heavenly bamboo .htm)
RCP Policy CD-17 (page 7 of Report to Hearing Examiner)

"Setbacks and other development standards should not be reduced on newly platted lots through modification or variance to facilitate increased density."
But on page 8 of the Report to Hearing Examiner, staff say that installation of the required 15 foot landscaping buffer around the storm drainage pond could not be done because it would cause the loss of at least one lot, even though the project is proposed at 4.45 lots per acre when it is zoned at R-4.
In the next paragraph, staff removes the specific requirement of trees in the on-site landscape strips along all frontages. Not only is there no justification for this, and it violates RCP Policy CD-15. In repeated surveys of our community, the trees are the consistently reported as the defining characteristic of our community. We are already losing over 300 significant trees in this project. We ask that this exemption be disapproved for this project.
Report to Hearing Examiner page 12:

To the condition requiring a tree protection easement under section J.5, please add a requirement for prominent and permanent signage announcing the protection of the trees in order to prevent accidental homeowner or HOA removal.

MISSING DATA:

This Hearing is the last opportunity for the public to participate and to ensure that adequate administratively and legally enforceable mitigations are required of and implemented with this project. Staff has allowed several documents essential for the surrounding impacted community to evaluate the effects of the proposed project to be prepared and submitted after this Hearing is concluded. This makes it impossible for meaningful community input on the following:

1. 
   Report to Hearing Examiner page 8: City of Renton Arborists report promised
   
2. 
   Report to Hearing Examiner page 12: Landscaping Plan
   
3. 
   Report to Hearing Examiner page 12: Tree Retention Plan
   
4. 
   Report to Hearing Examiner page 12: Tree Protection Easement
   
5. 
   Report to Hearing Examiner page 12: Street lighting plan
   
6. 
   Report to Hearing Examiner page 13: HOA maintenance agreement
   

If items 1-4 are not required until application for construction permits, the trees will have already have been removed during the development/site preparation phase of the project and the issues becomes moot. The trees in our community have been consistently and enthusiastically identified in every single one of the land use actions CARE has participated in since 2001.

Without item 5, the public cannot evaluate the adequacy of the protections for school children walking to the bus stop on 156th Ave SE or the potential impact to the privacy and enjoyment of their properties. Community members on SE 4^th Place had a months’ long challenge of emails and meetings with the City and Puget Sound Energy when new lighting meeting the new standards was installed just 2 streets away. The new lighting was a huge disruption, and we need to ensure the new development does not make sleep at night impossible. A statement from an affected neighbor is included at the end of this document.
Renton has a responsibility under RCP Policy CD-15 to ensure that this project is “reflective of the existing character of established neighborhoods even when designed using different architechtural stypes, and/or responding to more urban setbacks, height or lot requirements. Infill development should draw on elements of existing development such as placement of structures, vegetation,” etc. We understand that new development will be more dense and the housing styles will be different. Further, we appreciate to beginnings of plans for the tree easements. However, we have repeatedly heard lovely aspirational allusions to responsive development during past preliminary plat Hearings, only to see radically different realities built in our neighborhoods. Cavalla was supposed to save and replant giant specimen rhodies and japanese maples. That didn't happen. There was supposed to be no road in the 162^nd Ave SE ROW, but the bulldozers plowed right through – stream and all. The only things we have a hope of actually seeing must be conditions by reference in the Hearing Examiner's report for this project.
Given the intense concern about and established history of drainage issues resulting from development projects in the area, the community needs the opportunity to review the "maintenance and responsibility" for the "stormwater facilities" that the HOA will voluntarily take on to ensure adequate measures are in place to prevent off-site damage. We cannot do that without item 6.

COMMUNITY COMMENTS:

Date: Thu, 19 Jun 2014 08:47:46 -0700

Subject: Re: CARE Update: FCUAC Meeting Agenda

From:

To: [e-mail]
You can also add that nobody goes the speed limit up/down our hill. Ever. Well, unless it's crawling that is.
- One neighbor requested "a light" outside of their home (date unknown and I believe the request was directly to PSE)

- Nobody, including the requester, was notified before PSE installed 4 extra large cobra head led street lights (large roadway type) on our tiny cul-de-sac (7 houses deep) on 7/17/13

- Residents had light pollution/trespass everywhere; in backyards, bedrooms, etc.

- City was notified with a list of the issues they caused on 7/22/13

- Didn't hear back from the city on the initial email sent until 7/26/13 (after emailing them again)

- Petition emailed (with pics) on 7/30/13 with one signature missing due to him being gone on vacation

- Completed petition hand delivered 8/5/13 along with a chat with Mr. Barnes at City Hall

- The issues weren't resolved until 9/17/13

Summary:

For two months, the residents on SE 4th Place had to deal with overly bright LED lights that were completely inappropriate to the neighborhood. This disrupted people's sleep, made yard use unpleasant and in some cases was a safety hazard (blinded while backing out of garages). Neighborhoods should have a choice/say in the types of lighting used and a study of existing neighborhood houses should be considered. Lighting should also be appropriate to the scale of the neighborhood with minimal light pollution to disrupt the natural world.

Marsha Rollinger
From:

To: [e-mail]

Subject: RE: CARE Update: FCUAC Meeting Agenda

Date: Wed, 18 Jun 2014 11:08:14 -0700

Gwendolyn:

I live at 152 PL SE and regularly come up from the Maple Valley Highway to access my home. That involves a left turn at 154th Ave SE and SE 142 PL. It is a challenging enough intersection with limited sight visibility, no left turn lane, and long waits during commute hours. Under existing conditions, the traffic can back up already from the 3 way stop. Frustrated drivers finally decide to go for the left after long waits for breaks in traffic. Unfortunately, I've seen too many oncoming cars slam on their brakes because the left turner didn't really have a big enough break to pass through easily. The Enclave development will increase congestion at our left turn and make more drivers make a left turn into a too-small traffic opening.

As the development increases in the East Highlands around Maplewood Heights Elementary, we are seeing an increasing number of people who are making that left turn to access their homes. The increased traffic from the Enclave and its odd street layout will complicate the 3 way stop traffic, increase the number of cars, and back that traffic problem back to our already dicey left turn.
I realize that the Enclave development will go through even though I question the wisdom of having its two streets funnel out so close to the 3-way stop. Seems like it is almost making it into a 5-way intersection. But I doubt the County has the appetite to force the builder to change his site plan.

For us left turners, a left turn lane would provide some welcome mitigation and straightening out the curve - even just a little - would give more visibility and help safety tremendously.

Not sure you can do anything with this but thanks for trying.

Kathy Johnson

From:
To: [e-mail]
Subject: RE: CARE Update: 1000+ new trips, Wild Babies, and Meeting Monday
Date: Fri, 20 Jun 2014 08:39:25 -0700

Gwendolyn,

The 111 bus line which goes out to Lake Kathleen is scheduled to be truncated in September to not go east of 156th but rather to leave Maplewood and go directly up 156th st. This would only happen during the morning and afternoon commute hours as there is no service other times.

That will be another major disruptive factor to the 156th st corridor. In addition to the bus traffic along 156th, there will be the bus commuters who will drive and try to park along the bus route to connect to the new stops. This will impact the residents along this path plus adding the congestion. An example of this type of "staging" for the bus line is in Kennydale where the entire area is parked up along the 111 route as it heads to the Park and Ride. It adds a lot of congestion at the worst time of the day for it.

Not to mention making a number of us no longer have a commuter bus to downtown on weekdays. It also will affect the kids at Liberty who need the bus to get to the Running Start program at Bellevue College whereby they take college classes for both high school and college credits during their high school years.

One of my points was that with the bus stopping all along 156th.....traffic would be disrupted greatly at the worst time of day at a point where many trips are being added. The parking mess is true all along the Kennydale section of the 111 with people driving to park at bus stops instead of the P&R.

John Nanney

Alyssa Nanney

CARE The Enclave at Bridle Ridge - LUA14-000241