June 18, 2015 City of Seattle Department of Planning and Development Attn: Gordon Clowers 700 5th Avenue, Suite 2000 PO Box 34019 Seattle, WA 98124 Re: Draft Environmental Impact Statement & Growth and Equity Analysis for the Seattle Comprehensive Plan Update Dear Mr. Clowers: Thank you for the opportunity to comment on the Draft Environmental Impact Statement (DEIS) for the Seattle Comprehensive Plan Update s Growth Alternatives. Futurewise works to ensure that Washington State s cities are vibrant, equitable and healthy. Creating great cities takes coordinated action at various scales and through public and private market actions. The sustainability of our cities as measured by both the quality of life they provide today, and the long-term environmental protection they promise to future generations will determine the success of our region. Considering the host of social and environmental challenges we currently face including global warming, air quality concerns, water quality, food and energy security, poverty and declining social equity our communities must be part of the solution. Recent growth in Seattle has proven there is demand for compact, complete communities. Ultimately, the Urban Village strategy has been successful in locating growth in our centers and villages. Now, it is time for the City to commit to a renewed focus on how to continue this pattern in a more equitable, distributed way to avoid continued disparity in levels of service and outcomes based race, ethnicity, language or geography. For this reason, we do not believe Alternative 1 is a viable strategy to achieve the core values identified by the City. The attached table summarizes the potential impacts of Alternatives 2, 3 and 4 on five outcomes which are critical to supporting health, equity and the environment in Seattle. These components have been chosen because of their multiplier impact and relationship to other identified outcomes and include: A. Prevent displacement and increase access to opportunity, B. Maximize opportunities for equitable development throughout the city, C. Take proactive action to achieve climate and environmental resiliency, D. Integrate planning, design, investment, and implementation to deliver holistic placemaking, and E. Balance community benefits and burdens through growth, goals, policies, and investments. As shown in the table, no one Alternative provides a total solution to the challenge of growing equitably and sustainably all have both positive and negative outcomes. Of the alternatives presented, Futurewise supports an amended Alternative 4: Guide Growth to Villages near Transit because it provides the best opportunity to leverage our past investments, support transportation choice, and produce diverse and affordable housing. However, Alternative 4 places more growth in areas with high risk of displacement. We are asking the City to expand the number of villages targeted for growth to place more growth in high opportunity areas, as well as to
ensure that there are programs, policies and investment strategies included in the plan that will address displacement risk and ensure that all Seattle residents will benefit from future growth and change. These strategies should include aggressive affordable housing investments, protection for locallyowned businesses and better support for our most vulnerable families. Additionally, there is analysis and information which impacts these outcomes that has not been fully explored in the Draft Environmental Impact Statement. Before a preferred alternative is chosen, we urge you to consider and expand on the following: 1. Give equal consideration to health and equity impacts. While the DEIS considers environmental impacts and some quality of life impacts, health and equity is a critical component for the future of our city. While not legally binding, using the Equity Analysis in the same way that the remainder of the DEIS is used is the only way to achieve the core value of Race and Social Justice. This equity lens should go beyond displacement to analyze other areas of disparity such as, jobs, health, food access, transportation choice and safety, education and adjudication. 2. Target additional high opportunity neighborhoods for growth. As demonstrated by the Equity Analysis, opportunity is not equally distributed throughout Seattle. None of the alternatives fully capitalize on the potential benefits of targeting additional growth in these high opportunity areas. The preferred alternative should include a broader distribution of growth which targets existing high opportunity areas. 3. Include a greater focus on the total impacts of growth. The DEIS in general does a good job of comparing the relative impacts related to the different alternatives. However, the DEIS is deficient in identifying the overall impacts of growth independent of alternative. These absolute impacts are critical in terms of policy development and mitigation. This approach does not sufficiently capture the overall impacts we will see with 120,000 new residents in demand for housing, transportation, and other critical facilities and services. Our city s ability to absorb this growth requires mitigation of these total impacts regardless of alternative. 4. Analyze economic displacement risk. Vulnerable communities are not only negatively impacted by residential displacement. Individuals and communities are affected by business and job loss when an area experiences high growth, redevelopment and changing demographics. As areas gentrify, it is hard to retain commercial viability when the historic customer base is displaced or when rising rents and redevelopment make a neighborhood unaffordable for a locally owned business. 5. Maintain the goal of homeownership and incorporate the impact of the alternatives on homeownership. The DEIS states that homeownership is an outdated goal and therefore no longer needs sufficient in-depth analysis or mitigation. In Seattle, there is significant disparity in homeownership by race and ethnicity, and this disparity is increasing rapidly. In 2013, 51% of white households owned their homes, while only 25% of Black or African American households owned their homes. From 2000 to 2013 the rate of black homeownership in the city decreased over 10 percentage points. Other communities of color have similarly disparate rates of homeownership, such as 22% of Native Hawaiian and Other Pacific Islanders, 18% of other races and only 25% of
Hispanic or Latino households. This is critical because homeownership is an important strategy to increase the stability, wealth and financial security of some families. Dismissing this as a goal or focus of analysis while this disparity exists is unacceptable. 6. Explore neighborhood jobs/housing balance. Much of Seattle has not seen the economic growth and prosperity of neighborhoods like South Lake Union and Downtown. Residents in many neighborhoods have repeatedly expressed the need for economic development and increased jobs in their communities. This expands economic opportunity for all and reduces commute distances and trips. The DEIS does not adequately address the geographic distribution of job growth by alternative and provide mitigation strategies which will improve economic conditions in those areas which have not participated in our recent economic growth. All jobs are not the same; beyond the number of jobs, understanding the industry or job type related to skills and wages is critical to ensuring that all villages have a diverse and viable job base. 7. Need a housing choice analysis. As with jobs, not all housing units are equal. A diverse population needs diverse housing stock, in terms of affordability, size, and neighborhood amenities. For example, communities of color typically have larger family sizes and without producing these units, the City will continue to displace these families and be unable to attract and retain a diverse population. A more detailed view of the impact of these alternatives on the type and affordability of new housing units is needed. 8. Recognize and account for a wider range of community assets. Many low-income neighborhoods develop rich social networks with cultural, social and religious ties to support one another and provide needed services such as childcare, transportation and support mutual political and civic engagement and economic development. These networks are critical for low-income populations to survive. Disrupting these activities through displacement can be devastating for families with limited resources. Acknowledging and accounting for these types of community assets and the impact of growth and displacement on them should be included in the DEIS. 9. Expand the earth and water analysis to include impacts on public health. The DEIS examines growth impacts on air quality, natural systems. The linkage between these impacts and public health should be more explicit. As the air quality assessment acknowledges the link to cancer risk, other health impacts of environmental quality should also be included. 10. Revise transportation impact models. As the City choses a preferred scenario for the Final Environmental Impact Statement, the transportation impacts should be calculated using more up-todate travel behavior which better accounts for recent trends in mode-split and other transportation factors. 11. Recognize a variety of placemaking typologies for Urban Villages. Updating the FLUM designations and zoning codes to produce greater clarity and flexibility should be explored. However, many residents feel that all new development is too similar and that the unique character of Urban Villages are being diminished. Ensuring that any streamlined development regulations protect and respond to these variations should be prioritized. Additionally, examining growth
impacts on Urban Village historic and cultural resource including structures, vistas and institutions should be added. 12. Expand monitoring of growth by village. Currently, the City monitors housing and job growth towards targets by Urban Center and Village. As the city continues to grow through infill development, it is important to track capacity utilization, not just progress towards the growth target. This should be supplemented with annual updates with detailed demographic and economic data by village to measure progress towards growth targets, total capacity utilization and to monitor for any potential adverse impacts like displacement. This information should be used to adjust policies, prioritization and investment to respond to changing conditions on a more regular basis. 13. Explore impacts to other government services such as the departments of Planning, Housing and Neighborhoods. As the DEIS looks at the impact of growth on our schools, parks, public safety, utilities and other services, the DEIS should examine the need for other government services. As demonstrated over the past twenty years, providing neighborhood planning city-wide has been difficult to accomplish and maintain. Targeting growth in a wider-range of geographic areas will require more planning and implementation resources which should be considered and mitigated. The DEIS and Growth and Equity Analysis have gone a long way in addressing the challenges that our city is facing in a robust way. Overall, we feel that the DEIS and Equity Analysis are useful documents which will help Seattle prepare for future growth and address long-standing service gaps. It is a sophisticated analysis that highlights some of the different experiences across Seattle in services, risks, and opportunities. We feel, however, that the analysis can be expanded and improved in the ways listed above. We ask that you consider these additional items for review as you develop the preferred alternative and set the policies and goals which will implement the preferred alternative. We recognize that there is no perfect alternative and that with growth comes risks, burdens, and unintended consequences. At the same time, there is great potential for benefit through growth and investment and it is possible to share these benefits equitably. Selecting a targeted growth strategy balanced with mitigation efforts and the right goals and policies will ultimately help the city achieve equity and sustainability goals while ensuring a better quality of life for Seattle residents and employees. Thank you for your consideration. We look forward to continuing to work with city staff and the public to integrate health and equity into Seattle2035. Sincerely, Spencer A. Williams, AICP, Assoc. AIA Urban Designer and Planner
Growth Alterative Impacts on Health & Equity Priorities Alternative 2 Alternative 3 Alternative 4 Additional Analysis Needed or Other Considerations. A Prevent displacement and increases access to opportunity Alternative 2 concentrates growth into the urban center which takes away commercial and business from these areas as business is replace. Reliance on mid-rise and high-rise development increases demand for older units in cheaper development types will go up as the market prices out the urban centers. Benefit to transportation costs does not outweigh increased housing costs. Focus on station areas, light rail disproportionately burdens areas at risk of displacement, especially the areas with lower densities that are currently more affordable and have family-friendly housing. Focus on station areas, light rail disproportionately burdens areas at risk of displacement. Increases the potential for additional development in areas outside of existing station area. Alternatives 3 and 4 can be mitigated for these risks and present strong opportunities to provide stability in areas well served by amenities. Develop an economic/job displacement risk and attempt to quantify its role in community stability and needed mitigation. Homeownership is dismissed one of the areas with the highest disparities. Must be dealt with, have increased equity and wealth and benefits. More jobs should be concentrated in a variety of village typologies to maximize household-job colocation. Short trips have benefits in health, VMT, and mode choice. B Maximize opportunities for equitable development throughout the city Alternative 2 does not take full advantage of transit infrastructure. Ignores single family high opportunity areas from growth. The market trend has not seen a great diversity of unit sizes and number of bedrooms in these construction types. As a result, housing diversity may be limited. Takes full advantage of station areas for growth, but leaves out some areas that are well served. Takes full advantage of station areas and expands target areas for growth along frequent transit. This leads to greater choices throughout city, provides greater diversity of housing types, and increases supply of land for development which can lower cost and increase access. Areas with high access to opportunity but limited housing capacity should be considered for additional villages. Need housing types that the market is not producing. Identifying assets in high risk areas. Dismissive of concentrated pockets of poverty and communities or color Have not fully assessed the value that exist in areas childcare, reasons to cultivate or celebrate these areas. C. Take proactive action to achieve climate and Focus on core limits vehicle trips, smaller units, new construction is more energy efficient. Reduces impacts on tree canopy in other city areas. Positive influence on mode-split. Creates more walking trips by locating housing by transit and neighborhood commercial development. Takes from benefit Alternative 3 and applies them to more areas. The relationship between air quality, natural system function, and noise with the growth and changes to the built environment should be more predictive to assess degree of mitigation anticipated on infrastructure and human health. Transportation modeling should include most up to date travel behavior information. Does not predict increase in mode split in spite of recent trends. D. Integrate planning, design, investment, and implementation to deliver holistic placemaking In order to deliver growth there, have to be a substantial level of planning coordination and investment focuses planning and investment in smaller, more heterogeneous areas. Drains resources from other areas. Focused on and tailored to station areas. A more focused geographic scope likely assists in the delivery of high-quality, high-functioning station areas that foster complete communities. A broader geographic scope could mean greater distribution of planning and investment resources. The strength of market forces may assist the city in focusing planning and investment in underperforming areas to stabilize against the risk of displacement and increase baseline level of service in areas that have been historically underinvested in. Future Land Use Map (FLUM) designation should reflect the different placemaking typologies; however, careful considerations must be given to recognize different geographic needs including displacement risk to respond to community character and market forces. Growth estimates should be replaced with full capacity reporting for all villages and areas outside villages. Actively monitor village and city-wide growth in terms of permits, demolitions rents and sales will help guide citywide investment and guide policies for changes to market forces. E. Balance community benefits and burdens through growth, goals, policies, and investments Focus on urban centers are well located to service communities across Seattle, are ultimately restrict effectiveness. Do not have proximity to priority populations to influence health and equity through housing development, transit development etc. While city wide indicators may increase, other places will not benefit and disparities will likely increase. Capitalizing on existing transit investment and leveraging to increase access to opportunity & amenities expands performance throughout the city. Capitalizing on existing transit investment, leveraging to increase access to opportunity & amenities expands choices throughout the city. Distributes growth in a way that puts more people in more types of communities greater diversity in lifestyle choice, density, and distributes benefits in close proximity which gives more choice for goods and services. Consider planning resources in the same way you consider fire, schools, police, and other services. Many neighborhoods have reached out for planning attention to respond to outdated plans, growth and new opportunities though the city has limited resources. View elements of the DEIS through a health an equity lens. One example is crime. While there may be a loose correlation between growth and increases in crime, there is a disparity in how the criminal system impacts communities of color. This disparity should be addressed.