Lake Union Opportunity Alliance has submitted comments on the SLU Draft EIS. We’d like to take a moment to thank the various contributors collectively: THANK YOU!!
Remember: if you have anything to add, TODAY IS THE DAY!
You can send any comments you have to the Seattle Department of Planning & Development via email to: email@example.com
Here is a summary of our comments:
April 10, 2011
Senior Urban Planner
City of Seattle Department of Planning and Development
700 Fifth Avenue, Suite 2000
Seattle, WA 98124
Re: DEIS for South Lake Union Height and Density Alternatives.
Dear Mr. Holmes:
Lake Union Opportunity Alliance finds numerous flaws within the Draft EIS for South Lake Union as well as potential legal errors and we appreciate the opportunity to comment.
- LUOA has retained Richard Aramburu of Aramburu & Eustis, LLP to comment on our behalf from a legal perspective. Mr. Aramburu’s comments will be submitted separately but are attached here as well.
- LUOA also commissioned Christopher Ferrell of CFA Consultants (a transportation planning and research firm) to review and provide commentary on the Transportation section (3.13) of the DEIS. Mr. Ferrell’s Memo will not be submitted separately and is included herein.
It is the position of Lake Union Opportunity Alliance that the Draft EIS was not properly edited prior to being released to the public. We believe that the omission of this critical step caused significant negative impact on the public’s ability to understand and provide appropriate feedback on the DEIS. As having an editor is an expected practice for a professional technical document, we strongly recommend that a REVISED Draft EIS be released along with an additional comment period prior to developing the Final EIS.
The bulleted list below is a summarized list of items LUOA finds to be misrepresented, missing, or deficient in the DEIS and our requests for correction. Following the summary, you will find the more detailed explanation of various points from our contributing Board Members. These comments may or may not be submitted individually so please review this document in its entirety for the purposes of your response to Public Comments.
- First, the summary section of the EIS needs to be more informative, quantitative, and objective in order for the general public to understand the impacts in a timely manner.
- LUOA formally requests an EIS free of misleading “sales pitch” style terminology. There are a multitude of examples to choose from – here is one:
o Page 1-18 states in reference to Alternative 1, “Building heights increase slightly in the block north of Mercer.” A transition from 240’ to 300’ to blocks currently zoned at 40’ is not ‘slight.’
- Disclose all entities who contributed to the construction of the DEIS document with all potential conflicts of interest made transparent to the public.
- On page 1-55, it states “There are no significant unavoidable adverse impacts identified for any of the elements of the environment, except Transportation.” This is a false statement and needs to be corrected.
- The Shoreline Management Act prohibits the shading of water bodies with new development. The allowance of tall buildings next to the lake and the admission that these buildings will shade the lake seems to be a clear violation of the State Law and is ignored in the DEIS. The EIS must address this issue.
- The “Growth Targets” for 2031 on Page 2-7 are extremely aggressive for SLU, have not been adopted by City Council, and are not incorporated in the Comprehensive Plan. These targets are inappropriate, inconsistent with policies of the Growth Management Act, and should not be used or considered for any purpose.
- The entire document fails to address flight path issues – FAR77. Specifically, but not limited to page 1-13, page 1-15, page 1-35, and page 2-9 all illustrate inadequate study. The City must address this issue and not leave it in the hands of private corporations to determine the safety of the neighborhood.
- Page 1-18 and 1-19 incorrectly characterize Alternatives 1 and 2 as a step-down to the lake. Alternatives 1 and 2 do not step down and this must be corrected.
- While making the assertion that is “does,” the DEIS fails to address “how” an increase in height and density, which increases land values and moves from wood-frame construction to the more expensive steel and concrete, will actually increase the amount of low-income housing and affordable housing within SLU. High-rise housing is the most expensive per square foot and could eliminate new, low-income housing in SLU. This needs to be defined in the DEIS.
- The Housing section (3.9) contains incomplete and inaccurate inventories of current housing available within SLU. This should be corrected.
- One-day shadow studies are inadequate and shadows will have a major environmental impact on the public spaces of Denny Park, Cascade Park and Lake Union Park. Also, shadow impacts on page 1-19 suggest the impact is similar for all Alternatives. This is incorrect and must be addressed in further study.
- The DEIS states that birds and fish species dependent on the lake will be adversely impacted by the build-out but fails to explain how the city will protect against the adverse environmental impacts in any Alternative to public health, the land, the vegetation and wildlife which are currently part of the Lake Union environment. This must be addressed.
- In the Water Quality section (3.3) the DEIS fails to identify the baseline Combined Sewage Overflow (CSO) volumes for each of the six current outfalls into Lake Union. It further fails to indicate what the volumes of CSO’s will be upon full potential build-out of any Alternatives. The fact that the DEIS states that there will be unavoidable Combined Sewage and Storm-water Overflows into Lake Union in the future is unacceptable and is clearly a possible substantial adverse impact that must be studied.
- The DEIS ignores the rights of recreational and commercial users of Lake Union for reliance on wind currents which provide public enjoyment of sail boat recreation and tourism. The DEIS does not address potential wind-wakes that could adversely impact sailing on Lake Union. This should be studied.
- Tower spacing is an issue that should be addressed in the EIS. There is a general feeling that towers being proposed will be “slim” like those of 6,000 to 8,000 squared feet as seen in Vancouver and Belltown. But the proposals for two towers per block in SLU with floor plates of 10,500 to 24,000 square feet are NOT slim and the DEIS fails to adequately address the impacts of this in multiple sections throughout the document.
- Table 2-3 indicates that an office tower with a floor area of 24,000sf will be awarded to a developer who owns 22,000sf of property. This is an obvious oversight that needs to be addressed.
- The Land Use section (3.8) fails to examine the potential of South Lake Union to be overrun with commercial development based on the incentives offered in Alternatives 1 and 2. There is nothing in the DEIS discussing incentives or controls to allow for a vibrant retail, recreation, or living environment in a future South Lake Union under any of the proposed Alternatives. This must be addressed in the EIS with specific relation to, among other things, a primary goal of SLU’s Neighborhood Plan to “balance housing and job growth, providing a live/work neighborhood” and the UDF’s recommendation for enhancing community character “by requiring pedestrian-oriented uses along Westlake Ave. N and Valley St., and exploring requirements along other streets.”
- The entire Aesthetics section (Chap 1 and 3.10) is filled with misrepresentations and inaccuracies. They must all be addressed and corrected in a manner that more fully represents the true impacts of the proposed Alternatives on SLU.
- The Transportation section (3.13) is woefully inadequate to the task of studying the potential transportation impacts in South Lake Union under the proposed Alternatives. Many of the suggested mitigation strategies appear to be pipe dreams at best. Realistic proposals are required along with a complete and thorough transportation study based on this urban neighborhood and Seattle’s track record of mitigating traffic concerns.
- The Air Quality section (3.2) is heavily tied to the flawed studied in the Transportation section. Poor assumptions and modeling in 3.13 can have a substantial and direct impact on the health of the residents and employees of SLU and this must be studied.
We realize this is a long list, but it merely emphasizes the breadth of the deficiencies within the Draft Environmental Impact Statement itself.
What follows is more in-depth commentary from the contributing Board Members of Lake Union Opportunity Alliance along with the letter from Mr. Aramburu and the memo from Mr. Ferrell. We look forward to each of these points being addressed in preparation for finalizing the forthcoming EIS.
Thank you for your time and attention to detail in the coming weeks.
LUOA Board of Directors