SEPA letter

September 2, 2026
VIA E-MAIL
Charlie Hohlbein
King County Parks and Recreation Division
201 South Jackson Street, Room 6500
Seattle, WA 98104KCParks.SEPA@kingcounty.gov

RE: Formal Comment on SEPA Determination of Nonsignificance -
Petrovitsky Park Disc Golf Course

Dear Ms. Hohlbein:

I am an attorney representing the Trovitsky Park Homeowners Association (“TPHA”) and 
a number of its members, including Brandy Bilyeu, owner of the home located at 16930 SE 180th 
Place in Renton, Washington. 

My clients are concerned about the likely environmental, safety, and congestion 
consequences associated with a pending proposal for development of a 27-hole disc golf course in 
Petrovitsky Park (the “Project”), adjacent to many TPHA Homes. Please accept this letter as a 
formal comment proposing that King County retract the Determination of Nonsignificance
(“DNS”) that issued for this project on or about August 19, 2026, and either require a formal 
Environmental Impact Statement (“EIS”) for the Project or, in the alternative, require preparation 
and consideration of additional information prior to issuing a new SEPA threshold determination. 
In addition to the comments below on the likely environmental impacts associated with the 
disc golf proposal, my clients additionally respectfully request that the pending grading and 
floodplain review permits, under King County Permit Nos. GRDE26-0067 and FLOD26-0209, be 
denied for the reasons outlined below. In the alternative, each permit should be conditioned to 
account for and/or mitigate each of the concerns outlined.Charlie Hohlbein
September 2, 2026

A. The SEPA Checklist and Permit Applications Fail to Account for the Project’s
Extensive Clearing Needs
Initial estimates from the Northwest Disc Golf Association (“NWDGA”) proposed clearing 
of approximately 1.92 acres of undergrowth at Petrovitsky Park in order to make room for disc 
golf “fairways,” not including an additional 38,172 square feet anticipated to clear 30-footdiameter circles around each disc golf basket, to be cleared and covered in mulch. See Enclosed 
Exhibit 1 (Petrovitsky Park Disc Golf Course Proposal). At the time of the Proposal, NWDGA 
apparently intended only an 18-hole course, 3,888 square feet of clearing for “Tee Pads,” clearing 
of 4,536 board feet of trees and 1.92 acres for 24 “fairway/pathways,” each of which would require 
“underbrush clearing.” Id. Each of the 54 anticipated baskets would further require clearing of 
706.9 square feet, comprising the above-stated additional clearing of 38,172 square feet. Id.
Notwithstanding an addition of a separate 9-hole beginner course to the originallyproposed 18 holes, the SEPA Checklist represents that only “approximately 6,560 square feet of 
vegetation” will be “removed” and only 3,975 square feet of this total “will be for fairway and trail 
development.” SEPA Checklist ¶ B.4.a. A proposed “Clearing Area Map,” attached to this 
Comment as Exhibit 2, reflects the minimal areas to be “cleared” consistent with these significantly 
lower numbers and contemplates no clearing whatsoever for fairways or basket circles on 19 of 
the 27 proposed holes.
The incredible reduction in planned cleared area appears to be based on a plan to “trim” 
rather than “clear” the originally proposed fairway and basket areas: “Additional vegetation may 
be trimmed but not removed along course fairways.” SEPA Checklist ¶ B.4.a. This fails to account 
for the broad definition of “clearing” under the Code: “the cutting, killing, grubbing, or removing 
of vegetation or other organic material by physical, mechanical, chemical, or any other similar 
means.” KCC 16.82.020.D (emphasis added). To the extent the Project intends to “trim” its 
originally anticipated 1.92 acres or more for fairways and basket circles, as compared with 
“removing plants by the roots” in a smaller area, the full area constitutes “clearing” under the plain 
language of the Code and must be analyzed accordingly. 
Of note, as recently as August 29, 2026—over a week after issuance of the SEPA checklist 
and DNS—the NWDGA orally reaffirmed to my clients its commitment to clear 30-foot-diameter 
circles around each basket and cover them with mulch, as contemplated in the original proposal. 
My clients understand the Project plans to additionally contemplate “trimming” of the originallyproposed 1.92 acres of Petrovitsky Park forest with likely catastrophic impacts to the local flora 
and fauna that have not been considered or acknowledged by the SEPA Checklist or DNS. This 
“trimming” constitutes “clearing” under the Code and must be permitted and recognized as such 
in the Project permit applications and corresponding SEPA analysis.
The revised clearing area of 6,560 square feet appears geared to fall just shy of 7,000 square 
feet, which would require preparation of a Technical Information Report prepared by a licensed Civil Engineer, addressing “full drainage review requirements.” See Enclosed Exhibit 3 (Undated 
Letter from Zoe Vierling-Coulter to Charlie Hohlbein).
To the extent the area for proposed “clearing” by the SEPA Checklist and updated 
“Clearing Area Map” includes only 6,560 square feet to be “cleared” to complete the Project, the 
County should formally clarify that this limitation is a hard cap and no additional fairways, basket 
circles, or other portions outside the specific areas identified on the Clearing Area Map may be 
cleared for the Project—including “trimming” or other “cutting” of Petrovitsky Park vegetation.

B. Petrovitsky Park Contains an Acknowledged Wildlife Habitat Network
It is undisputed that Petrovitsky Park comprises a designated King County wildlife habitat 
network “to provide for wildlife movement and alleviate habitat fragmentation.” KCC 
21A.06.1424.
Pursuant to KCC 21A.24.386.B.3,1 any “applicant proposing recreation, forestry, or any 
other use compatible with preserving and enhancing the habitat value of the wildlife habitat 
network located within the site shall have an approved management plan.” In lieu of such a 
management plan, the SEPA checklist for the Project appears to summarily conclude that 
“[w]ildlife movement through Petrovitsky Park along this mapped wildlife corridor is limited, and 
the project is not anticipated to impact any wildlife movement through the park along this 
corridor.” Checklist at 14.
KCC 21A.24.388 additionally requires mitigation “to compensate for the adverse impacts 
associated with wildlife habitat conservation areas and wildlife habitat networks.” No mitigation 
appears to have been proposed for likely impacts associated with the new course on wildlife that 
utilize the network.
Contrary to the SEPA Checklist’s summary, and consistent with Petrovitsky Park’s formal 
designation as a critical wildlife habitat network, local residents have reported sighting numerous 
animals in the park, impacts to whom are not analyzed or considered whatsoever by the SEPA 
Checklist or recognized by the DNS. Animals seen by residents of the area include deer, bears, 
beavers, owls, and songbirds. Though the SEPA checklist acknowledges the likely high noise 
impact of disc golf park uses of up to 95 decibels, see SEPA Checklist ¶ B.7.b.2, no corresponding 
analysis considers the likely harm to local wildlife utilizing the Petrovitsky corridor from constant 
disc golf noise.
Further, SEPA requires consideration of “direct and indirect impacts caused by a proposal,” 
including cumulative impacts. See WAC 197-11-060(4); 197-11-330(3) (“Several marginal 
1 King County Code Section 21A.24.386 provides two alternative versions depending on whether 
located within shoreline jurisdiction. Both alternatives include the required management plan, though under different subsection headings. See KCC 21A.24.386.D (Shoreline version).Charlie Hohlbein
impacts when considered together may result in a significant adverse impact.”). The extensive 
“trimming,” constituting “clearing” under the Code as analyzed above, combined with the noise 
generated by frequent disc golf use, and increased foot traffic of golfers utilizing the area, and the 
danger of discs colliding with sensitive wildlife homes and habitats together comprise likely 
cumulative impacts on the recognized wildlife habitat network located at Petrovitsky Park. The 
current DNS does not adequately account for these cumulative impacts—particularly where no 
required management plan has been prepared. Until and unless these impacts are considered, 
through preparation and consideration of a complete wildlife management plan, the Project should 
not be authorized to proceed.

C. The SEPA Checklist Fails to Analyze Parking and Traffic Generation
The SEPA Checklist acknowledges that a “traffic study has not been completed for the 
project.” SEPA Checklist ¶ B.14.d. However, it presumes that “no significant chances in vehicular 
trips per day or peak volumes are anticipated as a result of the project. Without a traffic study, no 
data or information of any kind is cited in support of this conclusion. The checklist similarly states 
that “[n]o additional parking needs have been identified for this project because Parks plans to 
strategically schedule the course to avoid congestion at the park.” Id. ¶ A.11. 
No consideration in the checklist or DNS appears to consider the likely daily or weekly use 
of the park outside planned disc golf events. To the extent non-regulated use of the course has not 
been considered or analyzed in the SEPA Checklist or DNS, non-regulated use of the Project disc 
golf course outside the proposed “scheduled events” must be prohibited or closely regulated to 
ensure no unanticipated traffic impacts. 
Where the current proposal contemplates that the “course will be open from dawn to dusk,” 
and no traffic impacts have been considered or analyzed, the conclusion that the Project will 
require “[n]o additional parking needs” and result in no additional daily trips is speculative and 
without foundation. 

D. Conclusion
The Applicant proposes extensive clearing of forested areas to create a sprawling 27-hole
disc golf course in a recognized critical wildlife habitat region of King County without any 
consideration of the full extent of proposed vegetation clearing, without preparation of a wildlife 
management plan or consideration of cumulative impacts on local wildlife, and without any 
analysis into likely daily usage or traffic/parking needs of disc golfers. 
The TPHA respectfully requests that King County retract the DNS issued on August 19, 
2026, and require additional analysis prior to any approval of a new disc golf course at Petrovitsky 
Park. 

Please advise if I or my clients can provide any additional information for King County’s 
consideration relating to this matter.

Sincerely,
SMITH ALLING, P.S.
/s/ Gabriel H. Hinman
Gabriel Hinman
Attorney at Law