Wednesday, April 11, 2012

Comments on C.B. 117430, “Regulatory Reform”

Dear Councilmembers,

Attached and pasted below is a letter from the Federation about the regulatory reform proposal you will be considering.  We hope you will consider our comments.
Jeannie Hale, Pres
Seattle Community Council Federation

 April 11, 2012

 Members of the Planning, Land Use, and Sustainability Committee
Seattle City Council
601 Fifth Avenue, Second floor
P. O. Box 34025
Seattle, WA 98124-4025

 Comments on C.B. 117430, “Regulatory Reform”

 Dear City Councilmembers:

The Seattle Community Council Federation has deep concerns about many portions of the so-called “regulatory reform” package.   The administration’s development of these proposals has not been inclusive, and as a result the distorted priorities unreasonably favor certain developers and businesses while undermining rights and protections that residents and small businesses now depend on to ensure the livability and sustainability of their neighborhoods. 

“Regulatory reform” is an Orwellian term for this legislation, which in important ways removes rights that Seattleites now have to participate in decisions that affect them.  One would never know from the many ways that it would degrade the quality of life and sustainability in neighborhoods and the democratic rights of the public.  The changes reverse nearly a century of precedent. They effectively repeal important portions of neighborhood plans without notice or consultation. 
There has been no real outreach and engagement so far with those who most negatively affected.   

The Department of Planning and Development grossly failed the City Council in no real outreach and engagement except to a chosen few, and the City Council must make up for this omission.   The March 28 public hearing was poorly publicized and was held downtown in the daytime.  

Please delay action on this package until public meetings and outreach mailings are held in neighborhoods throughout Seattle.  Not to do so is to disenfranchise the very stakeholders who should most be consulted and involved in consideration of changes of this magnitude.

To be sustainable, growth must proceed at a pace that the public finds acceptable, and through actions that the public understands and participates in.  The policy process must be open and consultative, and the policies themselves must be balanced.  For example, the public’s right of appeal is not a “regulatory barrier”—it is a fundamental of democracy that ensures reasonable and balanced land use decisions at the ground level. 

This legislation would so accelerate the changes occurring in neighborhoods that it will surely undermine the consensus on growth.  Seattle is already growing at a brisk pace, about as quickly as is possible without damaging communities as one sees happening in some world cities with less concern about humanity that Seattle believes it has.  
As we understand that the issues of parking and SEPA thresholds are being held for a future Committee meeting, we will provide our comments to you on those topics in a separate letter.  In this letter, we particularly oppose the several ways in which the legislation would detract from the livability and sustainability of residential areas by injecting commercial uses into their midst.  Seattle must remember the answers for why we have residential zones.  The noise, pollution, congestion, and other disruption that accompany business development are damaging to communities. 
The Council should refuse to extend temporary use permits to 18 months from the current 6 months and must not remove the current right of appeal.  18 months is certainly not “temporary” and the term should remain at 6 months.  The right of neighbors to appeal the current 6-month temporary use permit is an essential way that land use decisions are kept sane.  This right must not be removed, especially if there is any increase in length of the permit.  The reasoning given for removing this democratic right—that the DPD permit fee could be less—misrepresents the issue.  The City Council can reduce the permit fee without damaging the rights of people to file an appeal that ensures the decision is a reasonable one.

The Council should also resist the proposals to expand the business presence in residential dwellings.  Communities are already being damaged in current law by the displacement of residential space by business space.  There are fewer people living in and participating in communities, fewer “eyes on the street,” and many other negative consequences that the Council has not considered. The proposed changes will accelerate this trend in which Seattle is becoming less of place where people live, and more a place where they maintain technical residence but actually use their residence for business that should be occurring in a commercial zone. 

 Thanks for your consideration of the above comments.  We will follow up with another letter on some of the matters not yet covered here. 


 Jeannie Hale, President
3425 West Laurelhurst Drive NE
Seattle, Washington  98105

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