Multifamily Development Regulations Need Further Analysis

SEATTLE COMMUNITY COUNCIL FEDERATION

November 22, 2010

Councilmember Sally Clark, Chair, Committee on the Built Environment

Members of the City Council

600 Fourth Avenue

Seattle, Washington   98124-4749

Subject:  Multifamily Development Regulations Need Further Analysis

Dear Councilmember Clark and Members of the City Council:               

For many years concerned citizens and neighborhood organizations have drawn the City’s attention to problems associated with rampant townhouse development in our low rise zones.  These cramped “4 pack” projects typically provide inadequate access and open space, and they destroy rather than enhance the established development patterns of our neighborhoods.   In places they cover whole city blocks.  They stand in stark contrast to the dense livability envisioned by the Urban Village strategy underlying our City’s Comprehensive Plan.  And they are a testament to what misguided development can do to our communities. The Seattle Community Council Federation, a coalition of community groups throughout the city of Seattle, offers the following comments on these important issues.

The Federation has argued that many of these undesirable projects are the result of lax administration such as a willingness to ignore access easement requirements.  But the Nickel’s administration chose a major rewrite of the multifamily code which, after an independent analysis by independent teams last year (the ‘black hat/white hat’ exercise) initiated a further rewrite in the hands of Council.

Trying to rewrite the development rules for the city's most affordable housing class that covers almost 6 square miles spread throughout our city is a challenging task, but one that should acknowledge the variety of conditions under which it will be applied.  While the overhaul generally attempts to encourage development in designated “areas of change” (our Urban Villages), it does not ensure that infill respects ‘context’ in our “areas of stability” (outside of the Urban Villages) where predictability and consistency of neighborhood building forms are most desired.

We recognize the tremendous effort that has gone into this process, and acknowledge improvements have been made over the last several months.  But we are concerned that the final stages are being driven more by schedule than results and that additional work necessary to resolve real problems will not be allowed.  Despite earlier indications that another independent ‘black hat/white hat’ review would be undertaken, it seems that COBE is intent on asking for passage as soon as possible.  We think this is a mistake and will net a flawed code despite the years of effort.

What follows are what some examples of the most pressing issues that are imperative to address in the final legislation to avoid a variety of unintended consequences.

Abandonment of Urban Design Principles

We want to make it clear that we assert that some very specific faults remain with the code which would be clearly shown if an independent ‘black hat/while hat’ review exercise were undertaken.

1.     Focusing on building types and the removing the public from the review process makes it likely that existing and intended development patterns will be ignored and neighborhoods with inconsistent streetscape characteristics and yard patterns will result.

The conversion of front and back yards to minimal setbacks, and the elination of side setbacks for end rowhouse will result in the placement of buildings incongruous with its neighbors.   This will also introduce privacy and security failures.  Respect of development patterns is a clear Comprehensive Plan goal, particularly outside of Urban Villages. 

2.     The upzoning of LDT à LR1, and L1 à LR2 and L3à L4 (LR3) in Urban Villages, coupled with removal of parking requirements in Urban Villages, will result in over-densification when green building bonuses are used. [1]

A few simple examples will best illustrate this dramatic flaw (see attachment for more):

o      A 5000 sq ft lot zoned LDT in an Urban Village is now limited to 3 units and would be flats or townhouses with legal access provided perpendicular to the street.  The proposal would force use of the certified green bonuses to retain 3 townhouse units, but could allow 3 rowhouses each with an accessory unit above, yielding 6 units - a 100% increase in unit density.

o      A 5,000 sq ft lot zoned L1 in an Urban Village previously would allow 3 units, most typically townhouses with their own parking.   Now as an LR2, if built green, the project could include 12 small apartments (~500 sq ft) with no parking provided – a 400% increase in units.

o      A 5,000 sq ft lot zoned L2 outside of an Urban Village is now limited to 4 units and if unit lot access easements were enforced they would likely be flats or the lot would be combined with another to gain enough area for the access.  The same potential as noted above (12 units) is possible if the proposed sharing of parking can be arranged.  This is a 300% increase in units.

3.     FAR as the overriding bulk/scale control will yield unpredictable lot coverage results and exacerbate the loss of the clear delineation between low-density MF zones and high-density zones.  All zones now can yield a variety of density and building type outcomes.

Floor area ratio is a general planning bulk and scale tool for identifying project capacity where established patterns of open space and building placement make little difference.   Applying it to low scale residential building types with fractional differentiation for various conditions is not appropriate.  It might be easy to discern the difference between a building of FAR 2 and one of FAR 3, but not the difference between 1.2 and 1.3.

By choosing to use FAR as a way to incent or disincent certain building forms, rather than clearly allow or disallow, means profitability will rule what buildings are built and how they cover the lot. This defeats one of the primary objectives of land use regulations—the investment security of having a rough idea of the future of one's immediate vicinity.

Instead, specific building types, as identified by Neighborhood Design Guidelines should be considered.  Also, specific building forms should be tied to zones as is being done elsewhere in the country.   This ensures that the higher density projects are produced in appropriate places and that permeable open space is promoted elsewhere in compensation.[2]

Parking Requirements

Removal of parking requirements for projects in Urban Villages does not recognize real issues with severe parking problems in some neighborhoods.  With likely Metro service cuts we will see street congestion exacerbated.  Many neighborhoods are extremely concerned about the shortsightedness of these rules, and believe that this change in fact only externalizes development cost to the broader community by placing parking on the street.  At the same time, these cars will compete with spaces that could be used by customers of small businesses and other visitors to the community.  More granularity is needed in the determination of where parking should be required or exempted. At a minimum, a multi-unit project should require some shared parking if the area is already at an over-parked state (residential Parking Zone).  

Design Review

Design review and citizen participation are being dramatically weakened or removed with the use of SDR.  We are adamant that a strong design review process is the citizen’s right based on our Comprehensive Plan[3] and is necessary to develop quality infill in the multifamily zones by providing the developer with flexibility and input from the community.

The Design Review process however is already weakened by the ‘stacking’ of Boards with industry professionals who in review of their contemporaries’ projects are unwilling to seriously critique or pursue concerns voiced by the community, and is further made ineffective by Director rulings that allow unacceptable departures from the code.  While perhaps ultimately in the project’s favor, it is a costly process and time-consuming process and one that only induces mistrust or contempt in our city agencies.

We believe that a strong citizen-based regularly-monitored design review processes (ADR, SDR, and DRB), along with recognition of extant neighborhood plans and sound codes will yield the best outcomes for our city.  We would like to see more citizen staffing on Boards and, when development is more active, more Boards to ensure that projects may be reviewed in a timely manner.   We also insist on the right to appeal decisions made by the Director concerning projects of 4 or more units in our neighborhoods.

Other

We object to the abdication for any responsibility in this legislation for the recognized Unit Lot Subdivision problems, including questionable access easements and optional CC&Rs.  We remain concerned about how these multi-building projects with shared streetscapes and building elements will be maintained and whether there remains the potential for blighting.  CC&Rs (Covenants, Conditions and Restrictions) should be required for all multifamily projects with shared areas and easements in order to address issues related to insurance, maintenance of common areas, building upkeep.

SUMMARY

The proposed legislation reflects an underlying disregard for the built environment and urban design elements of our neighborhoods in exchange for freedom of design for a project on a lot. Your cover letter dated October 18 states one of the goals for these amendments is to “Generally maintain the current overall scale and density of Lowrise zones”. 

Yet these zone redesignations and code changes replace a clear delineation of densities and intensity of use from low duplex/triplex through the more intense larger-form structures with many units. We now have the possibility of

1.     similar sized buildings, building types and similar unit densities throughout all the lowrise zones regardless of zone designation, and 

2.     loss of predictability about the number of units and unit size in all lowrise zones, and

3.     an abandonment of urban design principles disturbing the existing characteristics of our neighborhoods, including yard and streetscape patterns.  

A neighborhood is left with little certainty of how much can be built and what it will look like. 

We are NOT against density, particularly in Urban Villages.  What we strongly object to is the loss of gradation and the increased potential for incongruous development, the loss of targeted densities through zoning, and the potential disregard for extant conditions that would affect how projects are added to our communities.

We assert that the issues that remain with the proposed legislation are critical, represent divergence from our Comprehensive Plan, and yet are fixable.  Please allow the additional public analysis necessary through a similar exercise to the black hat/white hat’ effort last year that uncovered the variety of flaws with the original Nickels proposal.  We must complete this task and allow refinement to correct these significant errors.

Thank you for considering the views of the Seattle Community Council Federation.  We look forward to hearing back from you soon.

Sincerely,

Jeannie Hale, President

3425 West Laurelhurst Drive NE

Seattle, Washington  98105

206-525-5135 / fax 206-525-9631

jeannieh@serv.net

ENC

---

[1] Appendix B, the map of these upzones, belies the declaration that there is “no upzoning.”  It took several years of costly “remapping” by petition to resolve a similar deception in 1988 through 1991.

[2] This is consistent with the Comprehensive Plan  “Yards and Open Space” Policies LU36 & 37, and  “Environment” Policy LU10: “Strive to increase the amount of permeable surface and vegetative cover in the city in order to mitigate the heat island effect of developed areas, control storm water flows and reduce pollution.” 

[3] LU 55: Employ a design review process to promote development that:. . . Allows for diversity and creativity in building design and site planning.

ALERT - Sunday December 12, 10 a.m. Memorial Service for Ingraham Trees

Dear Friends,

It is with sadness that we announce that we have reached the end of our efforts to save some 29 mature Douglas fir, western red cedar and madrone trees at Ingraham High School. We recently lost our appeal before King County Superior Court Judge Teresa Doyle and are unable to continue with an appeal to the Appellate Court because of the cost and potential liability if we lose on continued appeal.

Save the Trees - Seattle has succeded in reducing the trees to be cut in the NW Grove from an initial 70 to less than 30.  The 29 trees to be cut down represent about one quarter of the trees in the NW Grove. We also succeed in saving a mixed conifer madrone grove of the trees on the east side of the school that  had been protected for 50 years in an agreement with the Parks Department but which the Seattle School District had targeted for a parking lot.

Our efforts to save the NW Tree Grove helped to get the City to pass a stronger interim  tree protection law which currently protects tree groves from future development. We also originated the idea and worked to pass legislation to create the current Urban Forestry Commission. And we are working now to fight the proposal by the Mayor and his Department of Planning and Development to deregulate tree protection in the city that would send us back to the roar of chainsaws clearcutting what trees remain in Seattle's reduced tree canopy which has been reduced by half since the 1970's.

The time to appeal expires as of Dec 9th so we expect the Seattle School District to rev up their chainsaws and cut the trees down as early as this weekend. We urge you to stop by and say good-by to the 29 trees condemned to die because of the City's and the Seattle School District's  blindness to environmental and ecological values.

  If the trees are gone when you come by, we urge you to pay homage to the 70 plus years of service they provided the city by reducing stormwater runoff, cleaning our city's air, producing oxygen for us to breathe, providing a park area for the school and the neighborhood, providing habitat for birds and squirrels and insects and other animals and plant life, for being part of the last 50 plus acres of an uncommon plant habitat in Seattle (a conifer madrone forest), and for just being there for their beauty and serenity.

This  Sunday (Dec 12th) at 10 AM we will hold a Citizen's Memorial Service on the North side of the tree grove to honor the trees for their 70 years of service to our neighborhood and city and to say good -by. 

The street is N 135th between Ashworth Ave N and Meridian Ave N. Please come by and bring something in writing or a sign or flowers or something to post on the wire fence circling the grove. Bring a poem or words or a picture to share with others as we grieve for this unnecessary loss of part of our city and our neighborhood and our green urban forest infrastructure.

And vow to write to the Mayor and the Seattle City Council, urging them to reject efforts to eliminate all protections for existing trees as the Mayor proposes. Urge that they strengthen our tree laws to protect trees like those being cut down at Ingraham.

And if you are able to - please donate to Save the Trees to help pay off our legal bills and support our efforts needed over the next year to get a much stronger tree protection law passed. Contributions can be sent to Save the Trees-Seattle, c/o Steve Zemke, 2131 N 132nd St, Seattle, WA 98133.  If you have questions or would like to help in our fight, you can contact us at stevezemke@msn.com or call 206-366-0811.

We want to thank everyone who has helped over the last three years. Your support has keep us going. While we have not saved all of the NW Grove, we have reduced the impact and loss overall. We as a group are dedicating ourselves to strengthening our City's tree laws so that other trees in our city can avoid the fate facing those trees being cut down at Ingraham. On Sunday we will pay homage to those trees that are dying an unnatural death despite their long service of 70 years to our city.  We hope you will join us in saying thanks on Sunday.

Steve Zemke

Chair - Save the Trees-Seattle

Come by and see the trees and post something on the fence or leave something when you can.  As noted, there is no guarantee that the trees won't be cut down before Sunday. The 29 trees to be cut down are those closest to the west side of the School Building.

E-mails for the Seattle City Council and Mayor are:

tim.burgess@seattle.gov

sally.clark@seattle.gov

richard.conlin@seattle.gov

sally.bagshaw@seattle.gov

jean.godden@seattle.gov

mike.obrien@seattle.gov

nick.licata@seattle.gov

bruce.harrell@seattle.gov

tom.rasmussen@seattle.gov

Mike.McGinn@seattle.gov

Postal mail can also be sent to all of the above at:

Seattle City Hall 7th floor, 600 Fourth Avenue, P.O. Box 94749, Seattle, WA 98124-4749

Please forward this message to others, as time is very short. Let neighbors and others know and come on Sunday.

ALERT - Comments due Monday 12/13/2010 - SHA's 785 page Yesler DEIS fails to address loss of low income housing

 For immediate release:  December 9^.

Contact:  John V. Fox  206-632-0668 or Bill Kirlin-Hackett  425-442-5418

From:  Seattle Displacement Coalition (SDC) and the Interfaith Task Force on Homelessness (ITFH)

"SHA's 785 page Yesler DEIS fails to address loss of low income housing and its impact on our community"

                    - Coalition and Interfaith Task Force file their comments today (link to their comments below)

SHA is now taking public comment on the draft EIS outlining alternatives now under consideration for demolition and redevelopment of the 561 unit Yesler Terrace Public Housing Community.  Despite 785 pages of information, the document neglects to provide one shred of information about how their plans will adversely affect our city's dwindling stock of very low income and affordable housing.  Not one of the alternatives studied indicates how many of the 561 units currently on site ever will be replaced and what the impact that loss would have on our city.  Here is a link to our full list of concerns and comments submitted earlier today.  We are raising issues and calling for a level of analysis that is legally required and must be included in the final document due out early next year.

http://www.zipcon.net/~jvf4119/Yesler%20DEIS%20Comments%202010.htm

The deadline for written comments on the DEIS is this coming Monday, December 13.  What is contained in this DEIS will be the basis for and inform critical decisions our Seattle City Council will be making early next year whether to grant  SHA’s request for significant upzones, alley vacations, and other land use changes necessary for SHA's plans.  That is why it's so important for the final EIS to include full disclosure of these potentially negative impacts especially those caused by the loss of low income units in our city.

Summary of our comments: 
In sum, we've called for SHA to explicitly declare how many public housing units will be lost under each of the redevelopment options they are considering and to provide the required detailed environmental assessment of what the impacts will be accompanying those losses.  To date - and after more than four years of preparation - SHA still has not pledged to retain all 561 low income housing on site. Instead they plan a massive very dense redevelopment that would include highrise offices, retail uses, and construction of as many as 3000-5000 housing units - most offered as expensive condominiums.  They see the site in fact as a cash cow and revenue generator. Much of the land - SHA would sell off to developers - who then would complete various elements of the project.  Nearly all of the tree canopy including most of the 22 "Heritage" Trees now on the site would also be removed.

Yesler Terrace, is the last of Seattle’s historic garden communities located immediately south of Harborview and across the freeway from City Hall.  It has a 70 year history.  Gary Locke and his family lived there as did hundreds of other young households struggling to get their feet on the ground.  It's also been renovated many times and remains structurally sound despite SHA's claims to the contrary.  The 561 units sit on 30 acres of prime development property overlooking downtown and Puget Sound. You’re eligible for a unit at Yesler Terrace if you earn no more than 30 percent of area median income. That’s about $23,000 a year for a three-person household. You then pay about 30 percent of your income for rent. As it happens, the average income of families living at Yesler Terrace now is only 18 percent of median, about $15,000 a year for a three-person household. 

There are over 100,000 households in King County with incomes in this very low income range according to King County's Housing Benchmark's report, but only about 300 unsubsidized privately owned units in all of the county offered at rent levels affordable to this group.  Only about 10,000 subsidized units, including what now exists at Yesler Terrace are available at these very low income rent level (serving those at or below 30% of median) That's why we cannot afford to lose any of these public housing units or spend millions in limited housing dollars to replace them - dollars we don't have and that we instead must use to expand our stock of these much needed units. 

SHA has an obligation to provide full disclosure of how their plans at Yesler Terrace will affect our city's precious remaining stock of low income units. SEPA and NEPA rules require it.  Our comments raise several other issues such as failure to adequately assess the historic character of Yesler Terrace, failure to adequately assess loss of green canopy and open space and failure to assess the full impacts of the project on the neighborhoods immediately adjacent to Yesler Terrace, specially the Squire Park area east of the site where SHA already is accumulating property and redeveloping in conjunction with their plans at Yesler Terrace.

SEATTLE COMMUNITY COUNCIL FEDERATION

Founded in 1948, the Seattle Community Council Federation is one of the nation's oldest and most active coalitions of neighborhood groups.  Yearly dues for member groups are $50.  SCCF welcomes new member groups, and encourages renewal by groups whose membership in SCCF may have lapsed.  Individual donations are also welcome and tax deductible, and go very far, as SCCF is an all-volunteer 501(c)(3) organization.  Please mail your check to SCCF, 2370 Yale Avenue East, Seattle, WA  98102-3310.  For questions, contact treasurer Chris Leman, (206) 322-5463, cleman@oo.net.

Keep up-to-date at our blog/website www.seattlefederation.blogspot.com

Seattle Skyline and Signs - Nick Licata's Urban Politics #304

http://licata.seattle.gov/2010/12/09/up-304-seattle-skyline-and-signs/

UP #304 Seattle Skyline and Signs

No Comments (Leave Comment)

December 8, 2010

By City Councilmember Nick Licata

With assistance from my Legislative Aide, Lisa Herbold

CHANGING OUR SKYLINE

The question has been raised: “Do we want large illuminated signs on the top of our downtown buildings advertizing their tenants?” A proposal before the Council could specifically allow Russell Investments, which recently moved from Tacoma, to place a sign of up to 1080 sq. ft near the top of what had previously been the Mutual of Washington Tower.

THE PROPOSED BILL

Yesterday (12/8/10) the City’s Department of Planning and Development (DPD) briefed Council President Conlin’s Regional Development and Sustainability Committee on the proposed CB 117065. It would amend the City’s sign code to allow businesses leasing 200,000 square feet or more in a single downtown building to have illuminated identification signs on the exterior walls of that building.  Businesses in building less than 500 feet tall could install up to four signs, each up to 324 square feet.  Businesses in buildings taller than 500 feet would have an additional option of installing two signs of up to 648 square feet each.  One such business, Russell Investments, proposes another amendment that would allow a single sign of 1080 square feet, with 10 foot high letters, allowing a sign to stretch across 108 feet.

The DPD review of potential applicants shows that currently 7 downtown tenants would lease 200,000 square feet or more in a single downtown building and would qualify to install such signs.  Opponents of the legislation point out that under the current conditions only Russell would benefit since the other tenants would face other hurdles to take advantage of the law.

THE PUBLIC RESPONSE

Twenty-one people testified at the Committee’s public hearing, all but five were opposed to the proposal. The Greater Seattle Chamber and the Downtown Seattle Association came out in favor of the legislation, while a number of small business owners, architects, urban designers and market advertisers were opposed.

Those in favor argued that illuminated corporate logos on our tallest buildings would help Seattle’s economy, which has lost 20,000 jobs to this region in the last decade. Meanwhile Bellevue, which allows these types of signs on their buildings, although only on the sides of buildings facing I-405, has gained 2 million sq. ft. of office space during this period.  The head of the Downtown Seattle Association asked what are the opponents of this measure trying to protect? The skyline is man-made and constantly changing, it is not a thing of nature. And lastly an argument was made that allowing company names to glow at night on our buildings will attract major new businesses to Seattle.

The Washington Trust for Historic Preservation wrote that the “current sixty-five foot height limit on signage plays an important role in Seattle’s sense of place. Seattleites and visitors alike enjoy an uncluttered skyline relatively free from advertising. Tall buildings are recognizable for their form, massing, and details, allowing the architecture to define the experience rather than a corporate logo.”  For this reason, photos of Seattle’s skyline are the 10th most requested of a city according to Getty Images. Further, about 25 members of the University of Washington School of Architecture faculty wrote to tell us that “the proposal to allow 648 square foot lighted signs at the request of a single company which recently moved to Seattle ignores the Comprehensive Plan, overturns a half century of treasuring and protecting the downtown skyline and betrays any claims to sustainability.”

AN ALTNERNATIVE APPROACH

We are very fortunate that Russell chose to move to Seattle and we certainly want them to feel welcome.  It is very unfortunate if Russell was given the impression that such a change in Seattle’s skyline would be a minor matter.  A recent study by the Seattle Chamber of Commerce found that the most significant reason cited by companies and their employees to be in Seattle is our regional beauty and our relationship to the natural environment.  Would adding logos to our skyline add or detract from that environment?

I believe amending the sign ordinance, at least at this time, is not merited because the basic thrust of our current sign code has always been to permit signs that attract and invite rather than demand the public’s attention. Those signs that we do allow above 65 ft have been confined to way-finding purposes, such as locating hotels or public buildings.  Our Comprehensive Plan’s Urban Design Policies for Downtown “generally discourage signs not oriented to persons at the street level” and to “limit signs on the upper floors of building intended to be seen from a distance.”  Before we change the sign code in contravention to our decades of planning and design we should first determine whether the current code permits an exemption. DPD has granted exemptions under the currents sign code in the past for large signs on Pacific Place.

Additionally, there appears to be an abundance of off-premise and on-promise signs in violation of our current sign code.  Given the City’s recent budget cuts, DPD is now more than ever challenged in staffing sufficiently to enforce compliance. Fees for both of these types of signs may be undervalued relative to their market value to the advertiser.  One citizen has asked, “Seattle has just increased parking rates downtown to “market rate”. What is the market rate for a 648 square foot bill board so prominently positioned?”

Finally, the Hearing Examiner reviewed an initial proposal that would have permitted 4 signs at 324 sq ft each and allowed it to go forward.  The current legislation allowing for greater signage has not been reviewed by the Hearing Examiner for potential impacts on the environment.

I believe we should take the time to address these issues. To that end I’ve drafted a resolution which asks DPD to come back to the Council next year with a report on how to establish a comprehensive set of regulations to ensure that our sign regulations achieve their intent of contributing to the City’s image and not result in the needless proliferation of outdoor advertizing.

Conlin’s Committee will take up both his ordinance and my resolution for a possible vote on December 17th at 9:30 am.

Council Members & Mayor’s Email Addresses:

Sally.Bagshaw@seattle.gov

Tim.Burgess@seattle.gov

Sally.Clark@seattle.gov

Richard.Conlin@seattle.gov

Jean.Godden@seattle.gov

Bruce.Harrell@seattle.gov

Nick.Licata@seattle.gov

Mike.OBrien@seattle.gov

Tom.Rasmussen@seattle.gov

Citizens are directed to the following website to complete a form to send an email to the Mayor’s Office. http://www.cityofseattle.net/mayor/citizen_response.htm

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Federation letter re Giant illuminated Signs on Buildings

SEATTLE COMMUNITY COUNCIL FEDERATION 

December 6, 2010 

Councilmember Richard Conlin, Chair, Regional Development and Sustainability Committee  

Members of the City Council 

Mayor Michael McGinn 

600 Fourth Avenue  

Seattle, Washington   98124-4749 

Subject:  Amendment to Sign Code to Allow Russell Investments Sign 

Dear Councilmember Conlin, Members of the City Council and Mayor McGinn:                 

The Federation strongly objects to modifying Seattle’s sign code in order to allow Russell Investments to place its name and corporate logo on top of the former WAMU Center.  At our November 18th meeting, Federation members voted unanimously to oppose these changes to the sign code. 

Seattle has a long history of keeping advertising and signage from its downtown towers and 

this has resulted in a world renowned skyline recognizable for its striking architecture in a setting of natural beauty.  What limited signage that is found downtown above 65 feet is either a relic from a period before the code addressed this issue, or has been allowed for purposes of public benefit and wayfinding. 

The proposed Russell Investments sign is purely for the purpose of advertising and self-promotion which is not in the broader public interest, and we are concerned that it will lead to additional signage requests and therefore the further degradation of our cherished skyline.  

And if it is argued that no further signs are contemplated or allowed, we will be left with a single corporate name branding our city’s image.  Either scenario is unacceptable. 

We have been told that there is an argument being made that allowing this change will be good for attracting new businesses to Seattle, that it will help solve vacancy issues downtown, and it will show that Seattle is “open for business”.  This is a specious argument, and one that ignores the greater issues of our national recession and its impacts on our city.  While we welcome the arrival of Russell Investments to Seattle, allowing them to place their sign on our skyline will do nothing to improve the general business climate.  In fact, such promises to change our city’s skyline without public discussion and contrary to our Comprehensive Plan only cheapen our city’s image by indicating our public realm is for sale or can be had for the asking. 

It should be understood by all that signs above 65 feet are not directed at pedestrians and vehicles on “the street” to aid in location and promotion, and are clearly meant to reach the “eyes” of the wider area for the purposes of advertising.  We strongly encourage that any consideration of advertising signs above 65 feet be made as part of a wider public discussion of how advertising signage is used in our city.  Our sign code is antiquated in a number of ways, this issue being one. 

We all want a vibrant economy and a beautiful, picturesque city.  Corporate advertising on our 

buildings achieves neither. 

We urge that Council and the Mayor reconsider taking further action on this change and instead seek a more thorough and public process to address the issues that this proposal has brought to light. 

Thank you for considering the views of the Seattle Community Council Federation.  We look forward to hearing back from you soon. 

Sincerely, 

Jeannie Hale, President 

3425 West Laurelhurst Drive NE 

Seattle, Washington  98105 

206-525-5135 / fax 206-525-9631 

jeannieh@serv.net 

Comments on Giant Illuminated Signs due Monday Afternoon, 5.PM

A reader writes:

Dear Councilmember Conlin:

Thank you for the response to my recent e-mail on this topic.

The present proposal may indeed be limited -- perhaps tailor-made for just one company.  But once it's in place, innocent little amendments are sure to follow --just a little increase in the size of the signs that are permitted, a lower limit on the number of employees, a change in the way employees are counted (sort of like the "job creation" story), a modest change in the minimum height requirement (let's just simplify & make it 50 feet, rather than 500).  These sorts of things are easily slipped through, once the main controversy has been forgotten.

It's disturbing to think that economic development depends on lighted signs on downtown buildings.  This does not bode well for the success of such a marginal business.  (The argument IS, is it not, that without the sign, Russell won't thrive.)  It's also disturbing to think that Seattle City government is so eager to

play this race-to-the-bottom game.  One has to wonder what else the Mayor & his staff have promised to this firm, & what they will promise to the next one that they steal from some other city.

Yours truly,

Federation Editor's note: 

Comments on Giant Illuminated Signs due Monday Afternoon, Decemer 6, 5.PM

Don't vandalize Seattle's skyline with unsightly illuminated signs

http://seattletimes.nwsource.com/html/opinion/2013570345_guest02ochnser.html

The Seattle City Council is considering changes to its rules about signs that could mar the city's skyline with giant illuminated signs. Guest columnist Jeffrey Karl Ochsner argues the city should preserve the sense of the city's civic identity apparent under current sign rules.

By Jeffrey Karl Ochsner

Special to The Times

THE city of Seattle may be poised to approve an ordinance that will permanently deface the downtown skyline. A Nov. 6 Seattle Times editorial noted that unnamed "dignitaries" were amenable to rewriting the Seattle Municipal Code to allow Russell Investments to put giant illuminated signs at the top of their building, the former WaMu Tower.

A City Council committee will consider proposed revisions to the sign-code portion of the Seattle Municipal Code at a public hearing Dec. 7. A council vote on the issue may occur before Christmas.

Adding giant illuminated signs to the former WaMu Tower will mar the downtown skyline. The Tower is nearly dead center in the skyline. The bright lights will make the Russell Investments sign the primary focus of the skyline. The state outlawed billboards in 1961, but the Russell Investments sign will turn the downtown skyline into a giant billboard.

The proposed changes are a shocking give-away of our skyline. This kind of special favor for a special interest undermines the integrity of Seattle governance. Allowing giant illuminated signs will blight the skyline that Seattle has protected for the last half century. The proposed changes contravene our Comprehensive Plan.

The sign code currently allows downtown signs for business tenants only below 65 feet. Hotels and public buildings may have signs above 65 feet because these signs help us find places for public access and use.

The proposed changes would allow any tenant downtown with more than 200,000 square feet of space to have giant illuminated signs near the tops of downtown buildings. Signs could be up to 324 square feet on four sides of a building, or up to 648 square feet on two sides of a building more than 500 feet tall. Giant illuminated signs up to 18-by-36 feet or 12-by-48 feet or 10-by-64 feet would be allowed.

The downtown skyline is a tremendous asset forming a memorable image within our natural setting. Victor Steinbrueck called attention to the extraordinary value of our skyline nearly 50 years ago in "Seattle Cityscape," writing, "Seen from west of the bay, at a small lookout park on the tip of Duwamish Head, the central business district provides a thrilling panorama by day and by night."

The city of Seattle Comprehensive Plan "Culture Resource" section cites the skyline as central to our civic identity: "Over time, Seattle has acquired many features that people have come to identify with the city. Among them are ... the downtown skyline, distinguished by landmarks such as the Smith Tower." But now, with little public discussion, this will be discarded and forgotten.

The Municipal Code currently restricts signs at the tops of downtown buildings to protect our skyline for the enjoyment of everyone. The Comprehensive Plan specifically calls for "reducing visual clutter" and "limiting the signs at the tops of buildings," yet this is being ignored.

If approved, the proposed changes will set an appalling precedent. What happens when a tenant with 150,000 or 100,000 square feet asks for equal treatment? The Russell Investments signs open the door to untold visual clutter on our skyline.

The code changes undermine Seattle's claim to be a sustainable city. Giant illuminated advertising signs will consume energy for commercial advertising, contributing nothing to the community.

Seattle City Council must recognize how appalling the proposed sign-code revisions are. The integrity of the Seattle Municipal Code and the Comprehensive Plan is at stake.

After a half-century of treasuring our Seattle skyline, why is the city poised to allow it now to be vandalized? The skyline belongs to all of us. It should not be given away.

Jeffrey Karl Ochsner is a professor of architecture at the University of Washington.

Seattle Sign Code Amendment

Issue: 

The City of Seattle is considering amending its sign code to allow building signage above 65 feet for purposes other than wayfinding or public buildings.  These signs would be limited to tenants leasing over 200,000 square feet.

This change is being made to allow Russell Investments (which has just moved to Seattle) to place a 1200+ square foot sign on the former WAMU Center building.

Public Hearing: Tuesday Dec 7, 2pm, City Hall Council Chambers

Letters: need to be received by Monday Dec 6, 5pm (email, fax ok)

Talking Points

PROCESS

1.     There sign code currently has an exception process for applying for this type of sign.  It includes consultation with the Design Commission. Why isn’t that satisfactory, especially if there is only one applicant (Russell Investments)?

2.     The City has great difficulty monitoring and enforcing the current sign code for signs below 65 feet.  DPD is cutting staff that manages sign permitting and enforcement.  With these changes, what will keep these types of advertising signs from proliferating as well?

3.     Lease agreements are private contracts.  How will city monitor lease arrangements? What if the amount of space leased declines below the threshold? How will the City even know this? And if the leased area decreases below the threshold, will the tenant be made to take the sign down? 

4.     It seems that a deal was made over a year ago to allow this sign.  With a change this dramatic to what is essentially everyone’s skyline, shouldn’t this have been a more public decision making    process?

IMPACT TO SEATTLE'S SKYLINE AND AESTHETIC CHARACTER

1.     Signs above 65 feet have been reserved for wayfinding and public benefit.  What is the Public Benefit for allowing corporate advertising signs? Companies are private places, and are not the same as public destinations or hotels.

2.     The skyline is composed of and defined by architecture, not signs. We have a skyline recognized throughout the world.  Commercial branding will mar the character of our skyline, the 10^th most photographed skyline according to Getty Images.

3.     The design review process is very rigorous for downtown buildings. It is part of our Comprehensive Plan’s downtown policies.  Why are we not including a rigorous design review for signs which will be many hundreds of square feet in size and visible for miles?

4.     We are spending hundreds of thousands of dollars on a design for our Central Waterfront, but consideration of the how the skyline itself looks has been abandoned.

5.     What will keep this from being the first sign for a gradual proliferation of signs on many more downtown buildings?  What about companies that lease less than 200,000 sq ft?   Or companies that are long associated with Seattle?  What assurances do we have that companies that own their building won’t want to display their name and logo?  Or that multiple tenants would want to display signage?

ADVERTISING

1.     Signs of this size and placement are clearly meant for advertising purposes.  We are already faced with a proliferation of advertising in our lives.  Our skyline should not be used as another place to hang corporate names and logos. 

2.     Seattle has a long history of controlling advertising and billboards, and this is a bad precedent which opens a new outlet for the placement of advertising signs.

3.     This change will in effect “brand” our skyline and the city with the name of a single company (Russell Investments) which has just arrived in Seattle.

4.     Cities around the US and the world are trying to reverse the trends of advertising signage on their skyline (such as Pittsburgh - http://www.post-gazette.com/pg/09088/959089-53.stm). 

ECONOMIC

1.     This is ostensibly being done to help promote business and to attract businesses to Seattle.  But companies do not choose a city because they can put a sign on their building - they seek quality of place.  Seattle is desirable because of its aesthetics and natural beauty. 

2.     The net return to the city for this is virtually nothing.  The stadium naming right at least generated significant money for the city.  The permit fees for this type of advertising should reflect market rates.  The city has just taken measures to ensure that street meter parking fees match market rate.  This advertising should pay market rate fees to the city as well.

3.     Successful businesses do not need big signs, and not having signs on our buildings doesn’t make Seattle any less “open for business”. 

4.     Cities that allow signage have not fared any better in lease rates or business retention.

TECHNICAL

1.     The Seattle sign code is decades out of date - it is too weak and flawed in many ways.  It needs a major overhaul. 

2.     The City has not established clear and enforceable standards for signs of this type.   The current legislation is written specifically for one sign and is flawed, and it is too restrictive for other companies that are supposedly eligible for signs based on their current lease agreements.

3.     We should create a citizen task force (such as the Pedestrian or Parks Advisory Boards) to define how the downtown sign code should be revised.  There are people with the appropriate skills and interest to make this happen.

4.     Building codes and standards (such as LEED) are moving to control and reduce ambient light from buildings and signs because of negative effects on humans and birds, energy consumption, and light pollution impacting the night sky.

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A reader writes: Re: ZONING CODE "UPDATE" - Illuminated Signs on Buildings  


I see several problems with the proposal to relax the City Code regulating illuminated signs on buildings.  For openers it would be of benefit only to large firms and landlords.  Small businesses would be put at a competitive disadvantage.  That is both unfair and misguided since small to midsize retail businesses are already having a hard time making a go of it, especially in downtown Seattle.   What is the justification for favoring the big guys?   Meanwhile the City's argument that such signs help people find their way around town is hard to take seriously.  The sign would be so high up nobody walking or driving nearby would be able to see it from street level.   Nor could it be seriously argued the building is hard to find.   In fact it is one of the most visible and prominent buildings in the city, not that Russell Investments needs the advertising.   Last I checked their clients are primarily other investment firms, large trusts, and mutual fund companies, very few of which are even located in Seattle.   I don't know if they have any walk-up retail customers.   If that weren't enough, the sign would be most visible at night when the building isn't even open.   

This looks like just another sweetheart deal where City Hall does a favor for a large company.  Don't get me wrong, I'm glad Russell Investment moved to Seattle, but they sure don't need special treatment from the City.  They already got a steal when they bought the building for a fraction of what WAMU paid for it.   The City ought to think about what other tall buildings will be turned into free advertising if this ordinance goes through.   If City Hall wants to help the downtown landlords and developers the way to do it is through efficient public services down at street level.  Allowing advertising on the top of highrises won't do anything to fill vacant buildings, but better police and social services might make downtown a little more attractive to the small retailers and service businesses that are struggling. 

By the way, before the City further relaxes the sign ordinance they ought to take a look at what happened after they allowed bright moving-image signs.   If you want to see one take a look at the large sign on First Ave S. just south of the Stadiums.  You can't miss it, its attached to a strip club and runs provocative ads 24 hours per day.  Yup, just what the city needed to improve its family-friendly image and bring in neighborhood retail.   Whoever is coming up with these changes to the sign ordinance must live in some other neighborhood, or maybe they live in a suburban city that protects neighborhood interests by carefully regulating illuminated signs.   The proposed change for Russell Investment is unnecessary and is another step down a slippery slope.   Allowing big illuminated advertising on buildings is not the answer to any of Seattle's problems.    

Charles Prestrud