Urgent need to rebalance the City's ruinous Comprehensive Plan "Update"
City Council to act Oct. 17 — it’s urgent to testify and write them on this issue On Monday, Oct. 17 (2 p.m. at City Hall, 601 Fifth Avenue), the City Council is expected to vote on the Mayor’s Recommended Amendments to Seattle’s Comprehensive Plan. For the Councilmember addresses and suggested key items to mention, click here For further background, see below. Also: click here for the 12-page comment letter that the Eastlake Community Council filed in November 2015.
Key points: (1) Don’t eliminate the Plan’s tailoring of land use and transportation to neighborhood conditions and concerns, and especially don’t eviscerate neighborhood planning; (2) Don’t eliminate current brakes on rezones and conditional uses; (3) Don’t abandon current policies to promote yards and large trees in new projects; (4) Don’t adopt an ideological arterial and transit level of service; (5) Don’t remove from the Plan its current protections for parking; and (6) Do better outreach.
City Council considers Comprehensive Plan “Update” that would be ruinous for Eastlake, repealing current protections for livability and public involvement
Against urging by the Eastlake Community Council and many others, Mayor Ed Murray has proposed Comprehensive Plan that would be ruinous for neighborhoods like Eastlake. It’s now in the hands of the City Councilmembers, and they need to hear from you–especially on the need to slow this process down to avoid the wholesale damage to our quality of life that the Mayor’s proposals represent. The committee chair, City Councilmember Rob Johnson, is trying to push the Mayor’s changes through the Council in the next two weeks, repealing with one thoughtless action so much that ensures Seattle neighborhoods that growth is accompanied by livability and involvement. Below is background.
The 1994 Comprehensive Plan designated 37 neighborhoods as urban villages, with varying degrees of density (highest: urban center; medium: hug urban village; low: residential urban village. Eastlake is a residential urban village). The promise was that while there would be more growth than in single-family zoned neighborhoods, it would be at no more than a level consistent with livability, and accompanied by investments, policies, and neighborhood involvement to protect that livability. Officially terming these neighborhoods as “urban villages,” as the Comprehensive Plan has done since 1994, was a promise that while growth would come, it would be no more than is consistent with the intimacy and scale of a village.
Hiding the consequences and claiming it’s just an “update”, and after being elected on a promise to protect neighborhood character, the Mayor is pushing an entirely new Comprehensive Plan, shorn of the protections for livability and involvement in the Comp Plan that we have today. The effect is to turn the urban village strategy on its head, denying neighborhoods like Eastlake the protections they now enjoy and making them bull’s eyes and sacrifice areas for unbridled growth. The City Council must not let this happen.
The Mayor’s propose deletions, changes, and additions in the Comprehensive Plan would (1) eliminate current protections for affordable housing and neighborhood character; (2) eliminate current obstacles to unlimited increases in building heights; (3) allow wholesale upzones without regard for local conditions and preferences; (4) eliminate the Comp Plan’s neighborhood focus and its support for neighborhood planning; (5) remove current expectations for yards, landscaping, and trees; and (6) eliminate any balance in parking policies, leaving neighborhood businesses unprotected and making it impossible to restore on-site parking requirements for new buildings. Click here for a list of the specific policies and goals that we need to save, and for the City Councilmembers’ contact info.
Why the Comprehensive Plan matters
Since its adoption by City Council action in 1994, Seattle’s Comprehensive Plan has designated 37 neighborhoods as urban villages, distinguishing among them three categories based roughly on level of density, with the least dense being the residential urban villages (examples are Eastlake and Wallingford). Other categories of urban villages are the hub urban villages (examples are Fremont, Ballard, and Lake City) and the urban centers (examples are the University District, South Lake Union, and Capitol Hill),
The draft “update” for the Comprehensive Plan would add major new growth expectations for all of these urban villages while removing protections that currently ensure them village-like livability. And to make matters worse, the draft update would have Seattle take more growth than it is currently expected to by regional targets, which already have Seattle accepting as its share of growth more new construction per acre and per capita than any other city in the state. Further increasing these already unsustainable growth targets would have huge negative consequences for Seattle’s livability. It is a decision that must not be considered without the City government leveling with the public about what it is proposing, and listening–not forcing a foregone conclusion.
Policies and goals no longer in the Comp Plan would lose their protections in state law
Washington state law (the Growth Management Act) requires cities and counties each to have a Comprehensive Plan, to obey it, to amend it only once a year, and to do so in accordance with City laws and resolutions. Enforcement action can be imposed by the Washington state Growth Management Hearings Board and the state courts.
Unfortunately, the information so far provided to the public about the draft “update” does not disclose that it would remove many policies and goals from the Comprehensive Plan and that in doing so, it would deny the public the protections that having these policies and goals in the Comp Plan now provides under state law. Removing these policies and goals from the Comp Plan (whether dropped completely or put in other City plans that lack the same protections under state law) would immeasurably increase the Mayor and agencies’ discretion to ignore or change these policies and goals at will, freed of the state requirements that apply to the Comprehensive Plan.
A failure of transparency in how City government is portraying this “update”
For the most recent available version of the proposed “update,” click here or search on the web for Seattle 2035. But you are largely on your own in trying to discern from the City web site the vast differences between the two documents. In fact, with all the City web site’s hype about the Mayor’s proposals, you are lucky if you can even find on it the actual Comprehensive Plan that currently governs. Fortunately, we know the link: click here for the current Comprehensive Plan.
After months of criticism for its failures of transparency, the City responded weakly with a “crosswalk” document (available on the Seattle 2035 documents page) that begins to identify the many parts of the current plan that would be lost. Unfortunately the crosswalk document doesn’t classify or analyze the changes. Also, anything stated in the crosswalk or other City documents doesn’t have legal standing, as the actual proposed changes in the Comprehensive Plan have not been released in ordinance form, showing by cross-throughs the parts of the current Comp Plan that would be deleted and by underlines the additions that would be made.
That the Mayor’s proposed “update” (really an entirely new Comp Plan) is not provided in ordinance form is a serious breach of open government. In fairness, an ordinance version with underlines and cross-throughs should be made available to the public before the City Council considers the Mayor’s slash and burn job on the existing Comprehensive Plan. The City Council must compensate for the gross violations of transparency by the executive branch about the draft update’s actual changes and the many good parts of the Comp Plan that the “update” would furtively repeal.
Links to three public interest analyses for those who wish to explore these issues further–and for those short of time, a briefer set of suggestions
Because City agencies have failed to level with the public about the actual changes in the Comprehensive Plan that the draft update would involve, public interest advocates from around the City have prepared lists of the actual changes, and are pressing the City to be more honest about what it is proposing: (1) click here for the 12-page comment letter that the Eastlake Community Council filed in November 2015; (2) For the 24-page Sept. 2016 comment letter by a committee of the City Neighborhood Council, click here for the PDF, and click here for the Word version of the same letter. (3) click here for that committee’s even more detailed 50-page analysis which it issued in November 2015. And for those short of time, click here for the Eastlake Community Council’s recent list of suggested points to make, along with the contact info for the City Councilmembers.
A sampling of the changes hidden in the draft “update” of the Comprehensive Plan
Following are some of the most significant features of the current Comp Plan’s balanced policies and goals which the draft update would delete or denature. A goal (those with a G) or a policy (those without a G) is deemed deleted if no similar language survives.
• Deletes policy LU11: “In order to maintain the character of Seattle’s neighborhoods and retain existing affordable housing, discourage the demolition of residences and displacement of residents, while supporting redevelopment that enhances its community and furthers the goals of the Plan.” Effect of deletion: Eliminates current protections for affordable housing and neighborhood character.
• Deletes goal LUG2: “Foster neighborhoods in which current and future residents and business owners will want to live, shop, work, and locate their businesses. Provide for a range of housing types and commercial and industrial spaces in order to accommodate a broad range of families and individuals, income groups, and businesses.” Effect of deletion: Eliminates the Comp Plan’s neighborhood focus.
• Deletes policy LU3: “Establish rezone criteria and procedures to guide decisions about which zone will provide the best match for the characteristics of an area and will most clearly further City goals.” Effect of deletion: Allows wholesale upzones without regard for local conditions and preferences.
• Deletes policy LU34: “Limit the maximum amount of lot area covered by a structure to maintain compatibility with the scale and character of an area, to provide an adequate proportion of open area on a site relative to the area occupied by structures, and to provide occupants with sufficient access to light and air, as appropriate to the intended character and use of an area.” Effect of deletion: Removes current expectations for yards, landscaping, and trees.
• Deletes policy LU39 to “preserve and enhance the City’s physical and aesthetic character and environment by preventing untimely and indiscriminate removal or destruction of trees” and to provide incentives to property owners for tree retention; deletes policy LU41 for street trees; and deletes policy UV39 to enhance the tree canopy and understory in urban villages. Effect of deletion: Trees are no longer specifically identified as important.
• Deletes policy LU81: “Limit building heights to establish maximum heights, maintain scale relationships with adjacent buildings, and limit view blockage.” Effect of deletion: Eliminates current obstacles to unlimited increases in building heights.
• Deletes policies LU1, LU5, LU76, LU164 that currently direct that zoning, rezoning, and conditional use changes reflect community preferences, and be consistent with neighborhood plans. Effect of deletion: Ignores community preferences and eliminates the neighborhood planning process.
• Deletes policies LU59 and LU60, which define and protect single family zoning. Effect of deletion: Removes the Comp Plan’s current obstacles to eliminating single family zoning.
• Replaces policy LU67 with policy LU8.9. Effect of change: Allows ultra small lot development in single family and multifamily zones.
• Deletes goals LUG6, LUG6.1, and TG17 and policies LU20, LU49, LU, LU50, T-39, T-40, and T-46 that currently direct that parking policies “account for local objectives,” recognize parking as a part of “moving people and goods,” consider “access to local businesses,” “parking spillover into residential areas,” and “truck access and loading,” and not “introduce serious safety problems or blighting influences” but rather “achieve vitality of urban centers and urban villages” and “preserve Seattle’s competitive position in the region.” While deleting those goals and policies, the Comp Plan “update” would introduce two new policies: LU63 to “rely on market forces” for onsite parking and T40 to give higher priority in the allocation of street space to “greening” (e.g. on-street parks) over “storage” (the City’s new negative term for parking). Effect of deletions and additions: Eliminates any balance or sanity in parking policies.
If readers find any errors or divergences between what is stated here and what the City Council is considering, or can suggest improvements in this alert or in the more detailed analysis that underlies it, please send them to firstname.lastname@example.org, or call (206) 322-5463.
Why and how to contact the City Council
Although the Mayor’s proposed Comprehensive Plan amendments would devastate Seattle’s neighborhoods, the decision on whether and how to change the Comp Plan is really up to the City Council, but they are being rushed into the destructive changes, and must be urged to take greater care not to destroy the safeguards for growth to be accompanied by livability and involvement. Please send in your comment today–your neighborhood’s future depends on it!
It is urgent to contact the City Councilmembers soon, and if you can, to speak at the public hearing Thurs., Sept. 15 (see top of page). Click here for a list of the specific policies and goals that we need to save, and for the City Councilmembers’ contact info.
Be sure to communicate with the City Councilmembers individually, rather than by a collective e-mail or letter (which is far less likely to be heeded). The City Council e-mail addresses are currently as follows: email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, email@example.com, firstname.lastname@example.org, and email@example.com. You can also reach City Councilmembers by letter at 600 Fourth Avenue, 2nd floor, P.O. Box 34025, Seattle, WA 98124-4025, or by fax at 206-684-8587. Please cc the Eastlake Community Council at firstname.lastname@example.org, so we can keep you in the loop as these debates continue to heat up.