SEATTLE COMMUNITY COUNCIL FEDERATION
May 6, 2010
Senior Transportation Planner
P.O. Box 34019
Seattle, Washington 98124-4019
Subject: DNS for the Multi-Family/Lowrise Zoning Update
Dear Mr. Shaw:
This letter represents comments on the DNS for the Multi-Family/Lowrise zoning update from the Seattle Community Council Federation for inclusion into the SEPA record.
The Federation has been monitoring and engaged in the legislative process for amending the land use code affecting the Lowrise Multifamily zones and related amendments to SEPA concerning parking mitigation authority for many months. The DNS was discussed at our April 22nd meeting.
It is not evident that any thorough SEPA analysis was performed in developing the checklist and determination, nor are supporting documents resulting from analysis referenced in the Checklist or the Determination. In fact, the zoning approach now proposed by Council has existed for only a couple of months (and has been changed even within that time) and is extremely complicated to determine resulting density and other environmental impacts – even for the architects and professionals that have done the evaluation for the Federation.
The fact that DPD only allotted two weeks to citizens to evaluate the SEPA documents and legislation (almost 200 pages), and because of missing supporting information in the determination, reinforces our claims that the determination of “no significant adverse impacts” itself is questionable.
The proposed changes to the zoning will increase housing density, increase lot coverage, and increase demands on public infrastructure for almost 6 square miles of the city.
· The DNS is framed around the proposal as a non-project action, and for the majority of the checklist no evaluation is identified because of that. Yet elsewhere in the checklist it is stated that over 12,000 additional units of housing will result from the zoning changes proposed and elsewhere specifics of units are used to assess traffic and parking.
· The proposal itself is clearly meant to increase density of units in these zones through redevelopment of existing housing stock. All evidence shows that new units developed to replace existing, more affordable units, results in higher cost of housing and displacement and dispersion of some peoples to outside the city. These result in additional transportation impacts.
· The proposal will, as indicated in your SEPA documents, result more lot coverage and less open space and permeable surfaces. Storm water run-off, loss of tree canopy and other affects clearly have not been analyzed.
We have concluded that the Determination of Non-significance is an incorrect assessment of the impacts of the proposed legislation and that thorough evaluation of the broad and cumulative impacts, and identification of mitigations to them, is required through an EIS.
Thank you for considering the views of the Seattle Community Council Federation.
Jeannie Hale, President
3425 West Laurelhurst Drive NE
Seattle, Washington 98105
206-525-5135 / fax 206-525-9631