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HomeMy WebLinkAboutSEPA EPIC-18-79 - CHARTWELL DEVELOPMENT - TUKWILA CITY CENTER (TUKWILA POND)TUKWILA CITY CENTER EIS CHARTWELL DEVELOPMENT CORP DEVELOPMENT OF RETAIL NEAR TUKWILA POND EPIC- 18 -79 -SA FILE#1 CHARTWELL MEETING 2/8/80 1 In Attendance: Mike Farris, Ron Ubaghs (Wilsey & Ham), Ken Chauncey, Keith Cinnamon (Chartwell) Mark Caughey, Fred Satterstrom (City of Tukwila) Ron Ubaghs stated there are overriding issues that Chartwell needs direction on and questions regarding the basic zoning interpretation. The main questions regard: I. ZONING II. PARKING REQUIREMENTS III. YEAR -ROUND WILDLIFE SANCTUARY IV. STORM DRAINAGE ITEM I - ZONING 1. Reconsider interpretation of Kjell's earlier zoning interpretation. 2. Which zoning district is the correct one? Then notify Chartwell accordingl 3. Tukwila Board of Adjustment to determine which interpretation is correct. 4. Mark Caughey as Responsible Official will make decision on interpretation of zoning Monday, February 11. ITEM II - PARKING REQUIREMENTS 1. "The parking resolves itself" according to which zoning district (Mark) 2. Mike Farris made two points regarding parking requirements. a. Whether or not the proposal meets the City requirements as to parking. b. Whether or not the City requirements are adequate. ITEM III - POND WILDLIFE 1. Dr. Erickson (Consultant to Chartwell) did a wildlife investigation of the pond in August and September and turned in some preliminary notes and talked to Ron Ubaghs about the problems of the pond. The water in the pond comes from local parking lots, local surface drainage, and storm - water backing up. Dr. Erickson said the pond is not a "natural" pond, that it is declining in quality, and is not fit for wildlife of any kind. The pond had live vegetation 5 years ago, but that vegetation is now dead. 2. Ron Ubaghs stated that Dr. Erickson's work was given to the architect on the project. Dr. Erickson gave Chartwell a report to use on their E.I.S but there never as a final contract to get a final biologists report. 3. Mark Caughey asked for Chartwell's reaction to the public's suggestion of a Base Line Study. 4. Scott Salzer has been observing the pond for several years. Both Scott and the Audubon Society could contribute to an expanded discussion of wildlife data in a final E.I.S. Chartwell Meeting 2/8/80 Page 2 5 Chartwell stated that after the project is built the pond will be smaller with fewer species. The dead trees will be gone. It will not be a "natural" environment, but Chartwell claims it isn't "natural" now. 6 City Res. 656 Guidelines - states that we want to keep the "natural" state of wildlife. Chartwell stated that the pond is not a "natural" habitat, but a santuary for displaced wildlife from other ponds that are now eliminated in the area. When Chartwell builds it will reduce the size of the pond, but Chartwell will try to keep the best things: a. Stabalize the wildlife so it will stay (the wildlife comes in and stays for a few weeks then leaves). b. Flood some areas for nesting. c. Drain some areas for beach areas in the summer (control the area). COMMENTS: Mark commented that Chartwell had gone out of its way to protect the wildlife pond according to the Guidelines of 656, but the E.I.S. doesn't really show this. The project wasn't given due credit for so doing, but there is a need to get experts into the process. Mike Farris: Res. 656 doesn't define the kind of wildlife. What is the Council trying to do with the pond in regards to species, kinds of habitat for the pond, and how feasible is it to combine the wildlife with urbaniza- tion? Ron Ubaghs: Chartwell is not sure what they will have to do as far as moving earth, buildings, etc., for modifying the water level of the pond. Ron again stated the need for Chartwell to have some direction from the City. The City wants to keep wildlife in the pond, Chartwell wants a "clear cut guideline ", in order to do a final E.:[.S. The suggestion of a park was one alternative. Keith Cinnamon: Wanted to know if the Council was going to review Res. 656. Mark stated that it would not be appropriate to do so until the final waiver application stage. Keith asked these questions: 1. Would it be in the best City interest to review 656 until they have approved Chartwell E.I.S.? 2. How much modification is necessary for the Chartwell E.I.S.? • • Chartwell Meeting 2/8/80 Page 3 ITEM 4 STORM DRAINAGE 1. Mark felt there was a need to get together with Phil Fraser, Acting Director of Public Works, and go over storm drainage questions. 2. How much storage capacity does the pond and site have? Ron stated that in the past water has come up within a few inches of Andover Park West, but that nobody knows what the hydrology of the catchment basin is. 3. Ron then questioned whose responsiblity to do this portion of the study. The E.I.S. doesn't need a complete drainage study. CONCLUSION: In response to a comment by Mark Caughey, Mike Farris clarified the role of Wilsey and Ham, Inc. as consultants to the project proponent.- They are not in themselves propo- nents of the "City Center" Development. Mark wanted to know what Chartwell's reaction is to the public comments. Ron Ubaghs stated he has been working on cataloguing the comments in the publics' letters. Mike Farris stated they will need one week to go over "point by point" Ron's chart of public comments. There were 180 separate comments with 30 to 40 subject areas. He then suggested coming back for another meeting with the City. Mark concluded that Chartwell shouldn't generate any more time on the project until he makes his zoning interpretation. The transcript of the public hearing will also be ready on Mon., November 11. Follow -up meeting will be scheduled in one week. mkb JAN Mr. Kjell Stokeness Director of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Dear Mr. Stokeness: King County, St Washington John D. Spellman, C unty Executive Department of Budget and Program Development Mary Ellen McCaffree, Director Budget Division Room 400, King County Courthouse 516 Third Avenue Seattle, Washington 98104 John M. Rose, Manager (206) 344 -7370 January 25, 1980 Attached is an additional response received by this office in regard to the draft EIS for Tukwila City Center. We would appreciate it, if you would add these comments to those previously submitted. Thank you for the opportunity to review this draft EIS. MEM /pt Attachment Sincerely, .Mary Ellen cCaffree, Chairman 'Environmental Impact Committee Page 1 January 17, 1980 City of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Attention: Mr. Kjell Stoknes, Director of Planning Reference: Chartwell Project, Application 78 -111 -W Draft Environmental Impact. Statement Gentlemen: li A] ✓ ^ O.C.D. CITY Of TUV,',YIIA JAN 1 8 19SO I would like to preface my comments regarding the above referenced pro- ject by saying that I am not a resident of Tukwila. I have lived in the Burien area for approximately 25 years, and as everywhere, have seen many changes occur within South King County. The basic points of the Draft EIS I would like to address are comments relative to the impact of the proposed project on the flora and fauna in and around "Southcenter Pond ". I am aware that the existing pond is in a sense "man- made ", but it has developed into a truly unique habitat. My close association with the pond started in 1974, with observations of various birds and mammals to. be found in the area. These observations were made regularly throughout the year. Because of this my comments will be limited to sections involving the wildlife to be found there. In this letter I have attempted to confront the points chronologically with the Draft EIS and therefore wish to apologize for any redundancy this correspondence may contain. In the summary it is stated that at least:2 /3 of the site would be al- tered in some way, some of which would be to improve wildlife habitat. To put it simply, one cannot improve on the remaining 13 acres and have it support the number or diversity of the wild animals currently oc- cupying the site. This is further made impossible by the fact that "The existing pond would be reduced to half its present size ". Ecosystems, large or 'small, have a finite carrying capacity. By decreasing the pond size, total usage by animals would decrease. I would also be very interested in how the pond will be "controlled" to'!'recreate existing seasonal fluctuations ". This fluctuation is very important to the nesting ducks, particularly in the southeast portion of the pond and the brushy area in the southwest corner. There is a passing reference to "larger numbers of domestic duck ", I would like to point out that currently there are no, I repeat no, do- mestic ducks on the pond. Although with the pond development, large numbers of domestic ducks and geese would become a reality, which would compete heavily with the wild waterfowl for nesting sites. These ducks would also create "crossbreeds" wich in no way would "enhance" the remaining pond. • Page 2 .According to the summary, "most of the existing vegetation would be removed ". This vegetation provides valuable cover throughout the year for birds and mammals. Food producing plants would be of :Little help, due to the fact that most of the waterfowl are currently not utilizing the pond as a primary food source. An example of this are the large flocks of American wigeon that feed at Longacres and then fly to the pond to roost or rest. Another are the groups of wigeon and mallard that feed in the vacant lot to the immediate east of the pond. The pond is not used primarily as a food resource, but as a resting and breeding area. I would strongly challenge the statement on page 5 that "This habitat is found frequently throughout the region and the loss of this isolated site is of minor overall impact ". .I,would agree that the :Loss of this site would be of minor overall impact to the Pacific flyway, but even the Draft EIS consultants state "The variety and productivity of the site are unmatched on any comparably sized site in the Green River Valley or the Greater Seattle area ".(page 50, paragraph 2). This is a powerful statement and deserves much consideration. I am further convinced that the proposed "islands" would not "replicate" the habitat that is found in the southeast corner. This area is the major waterfowl nesting site on the pond and its present state did not come about through management. I will concede that no significant recreation currently exists, but a few people, like myself, have come to appreciate the pond of the unique area that it is. » Further, the recreational uses of the pond could be improved without a major building complex. As far as the alternatives are concerned, by now my sentiment are obvious, I would like to see the site remained unchanged. I am also a realist and understand that this is a valuable piece of property in a rapidly growing area. I feel :the.pond is a valuable asset as it now exists and it will become more valuable as the Greater Seattle arelcontinues to grow. From here on my comments will be directed to the section entitled:° "Existing Conditions, Environmental. Impacts and Mitigation" One major concern on my part is the lack of year round observations on which comments were made, and definite conclusions drawn. To use the month of August-as a yearly indicator is not possible. August is a good time to see a few, nesting species, but the largest concentrations of waterfowl is during the late fall through early spring. I do think further on site observations are warranted due to the scope of the pro- posed development. The tree /shrub border not only provides habitat for song sparrows, but also for nesting ducks. I do agree that the "pond edge is the most productive and critical habitat of the site ", but this includes the entire perimeter not just part of it. The comment that "the open pond • Page 3 41/ is used relatively lightly... ", is totally in error. 'A visit to the pond during the winter months will confirm this, which further supports my claim that August observations are not adequate. The pond also remains open water during most of the winter (with exceptions) thereby providing a roosting site when many of the smaller ponds are frozen. Statements regarding the success of nesting, esp;ecialiy in the southeast corner, seem to be a conclusion that cannot be substantiated based upon the limited observations made by the consultants. Studies using esta- blished nest censusing techniques would be required to reach such con- clusions. .I have observed no nest predation or desertion in the southeast corner. I have seen the results of nest predation on exposed coot nests. Again the Draft EIS makes an important statement; "Overall,, there would be a substantial reduction in the abundance of wildlife, but only a minor' reduction in species on the site ". What makes the site unique is its abundance of. wildlife and if one loses this, the site becomes just another pond with white domestic ducks, geese and assorted crossbreeds. And what constitutes a minor reduction in species? If the site has a reduction of 20 species, more are likely, that's 25% of'the total number I have observed since 1974! Again, I don't think this area can be artificially improved on as mentioned on page 50. Ideally this 'sounds great, but the fact remains that alot of species will no longer be .found on the pond. Sure they will find other areas, but their presence is what makes the area truly° unique. Tukwila has gone through tremendous change in recent years and I hope serious consideration is given to the development of "Southcenter Pond ". The Draft EIS states the case for the pond very clearly; Tukwila stands to gain a large yearly revenue plus the promise of future development, or to quote the Draft EIS, it can retain an area in which "The variety and productivity of the site are unmatched on any comparably sized site in the Green River Valley or the Greater Seattle area ". In closing, the Draft EIS lacks certain data in order to make a final determination. Further data is needed on specific displacement of wild- life and more explanation on how the qualit f the water and seasonal water level fluctuations will be accomplished. Thank you for your patience and I hope I have contributed some input concerning this project..I would be more than willing to further respond to any questions or comments you may have. Regards, SCOTT SALZER To: From: Subject: Department of Planning and Community Development DIVISION OF PLANNING MEMORANDUM Karen Rahm, Manager W-217 King County Courthouse Seattle, Washington 98104 (206) 344 -7610 Bob Edmundson Karen Ra Tukwila City Center Draft EIS Date: January 22, 19 80 We have reviewed the Draft Environmental Impact Statement and have the following comments regarding the transportation section: 1. The method used to reduce trip generation rates is valid only at a cordon line level. This method will give an approxi- mate impact on major facilities outside the cordon line, but under- states the considerable impact on local streets. 2. The ITE trip generation rate of 12.3 trips /1,000 square feet or 3.59 trips /employee for an office building would yield from 7,380 - 8,620 vehicle trips per day. The probable trips (4,800) used in the study therefore assumes a reduction of 2,580 - 3,820 or a daily mode split of 35 -49 %, an extremely unrealistic estimate for a suburban office complex. The estimated peak hour mode split for a METRO Transit ridership level of 120 million is only 11.4% for Tukwila. 3. The effective trip generation rate of 15 trips /square foot for the retail shopping area (obtained by subtracting 6,000 from 18,000 and dividing by 800) is much too low. This would correspond to a shopping center size of 15,800,000 square feet based on the graphical method of estimating trip generation presented in the ITE manual. On a cordon level basis, the trip rate of 22.5/1,000 square feet (18,000/800) may be acceptable. This would yield an overall rate, including Southcenter, of 27.5 trips /1,000 square feet. 4. At a local level, in the vicinity of the proposed development, trips are grossly underestimated. The two shopping areas will not be interconnected, therefore the number of people willing to walk from Southcenter to the Tukwila City Center development will be very limited. Most will drive from one parking area to the other, particularly in inclement weather. The impact on Strander Blvd. and Andover Park West is grossly understated. The mitigating N. REVIEW CRITERIA O.C.D. CITY OF TUKWIIA 9,^ (1) New housing activities should be located in -designat1 j 2 centers, existing urban areas. or on land locally desig- \nated for urban development. Policy References: • King Subregional Plan Phased Growth Policy #1 New commercial and other intensive activities should locate in existing urban and suburban centers: New residential development, offering a variety of housing opportunities should locate in existing centers, in skipped -over lands and in locally selected lands on the suburban /rural edge which have been committed to development. o King Subregional Plan Phased Growth Policy #5 The responsibility for implementing growth management policies remains with local government. Activity Centers Policy ;',`4 Retail, office, government and employment growth should locate in existing urban and suburban centers. Project is consistent with 7-7 consistent with conditions /-7 inconsistent with /-T is not applicable to the above policy criteria. Consistency cannot be deter- mined from the information available / -7 2 1980 (2) Projects should not (as a secondary impact) encourage addi- tional urban development on land not designated for urban growth. - ' • Policy References: • King Subregional Plan Phased Growth Policy #1 New commercial and other intensive activities should lo- cate in existing urban and suburban centers: New resi- dential development, offering a variety of housing oppor- tunities should locate in existing centers, in skipped - over lands and in locally selected lands on the suburban/ rural edge which have been comitted to development. (2) (continued) <• .King Subregional Plan Transportation Poli.cy- #2 The development of transportation facilities and services should not generate pressures for development incompatible with local or subregional objectives. Project is consistent with tT consistent with conditions inconsistent with /7 is not applicable to /T the above policy criteria. Consistence cannot be deter- mined from the information available / f Tukila City Center will nc:: cause additional urban de- velopment outside of the designated urban area (as de- fined in city plans and the county communities' plans). It may discourage such development by reducing the . de- mand for a major shopping center on the Soos Creek Plateau if the forecasts of population and retail sales growth con- tained in the EIS are correct. (see comment #5) (3) Adequate public services should be immediately available to serve the project or plans should exist for the provision of needed services and these plans should be consistent with re- levant local land use plans. Policy References: e King Subregional Plan Phased Growth Policy Guideline =1.1 New Development should locate in areas with compatible zoning and existing services (principally water and sewer. o King Subregional Plan Phased Growth Policy Guideline = =2 Highest priority should be,given to programs and funding proposals which improve or maintain the capability of local governments to provide necessary services and public improvements in areas where growth is encouraged. (3) continued • King Subregional Plan Public Utility Policy 01 The responsible units of government should..guide the extension of sewer and water service areas to expand ' the buildable land supply consistent with the policies of the subregional plan .^ Project is consistent with; 1 consistent with conditions inconsistent with /-7 is not applicable to /–% the above policy criteria. Consistency cannot be determined from the information available /7 According to the EIS, adequate public services are avail- able to the Tukwila City Center site. The PSCOG does not dispute the adequacy of water and sewer services or the ability of Tukwila to provide police and fire protection. However, transportation in the upper Green River Valley is of more concern. The following comments are addressed to the transportation section of the EIS. (a) The P.M. peak -hour trips -In /Out cited in the DEIS (probable - 650/1150, maximum 1100 /1800) are incon- sistent with those preliminary values cited in the Entranco Plan (1550/1800) *City of Tukwila, Transportation Improvement Plan - 1979, Entranco Engineers. What is the reference(s)_for the estimates of "im- pulse and local trips, and reduction in "Southcenter trips, shown on page 71, Table X? (b) To better illustrate the impacts associated with the proposal, we would recommend that peak -hour volumes, capacities and /or level of service be provided for 1985, with and without the proposal. The capacity and /or level of service analysis should provide data and information (on impacted highway links and intersections) previously illustrated under the existing conditions section (Figure 11). (c) What are the traffic hazard and safety implications of the proposal (auto -auto, auto - pedestrian)? (d) It is important to point out that the 1985 traffic figures on page 75, Figure 13 should reflect in- creasing trip generation trends by industrial -type developments east of Tukwila in Renton. This point is particularly important with respect to arterials and intersections providing access to 1 -5 and 1 -405. (3) (.continued) (e) Mitigative measures for offsite transportation im- provements are quite well addressed in the DEIS.. However, specifics should be provided as to who would be responsible for the necessary improvements, what degree the party will be responsible and how the improvements will be- financed (i.e. road im- provement district, bond issue, developer - full or partial,responsibility). (see comment #7) (4) A variety of housing types should be available to people throughout the region including disadvantaged and minorities in locations consistent with the Phased Growth Strategy. Policy References: • King Subregional Plan Phased Growth Policy #7 A choice of housing opportunities should be available to people of all income levels. • Activity Centers Policy #5 Activity centers should be located and developed in a manner that encourages a wide variety of housing choices which are highly accessible to centers. Project is consistent with !7 consistent with conditions /% inconsistent with /7 is not applicable to the above policy criteria. Consistency cannot be determined from the information available (5) New commercial, retail, and government activities should be located in existing locally designated urban and suburban centers to maintain their vitality and reduce the need for additional public investments in facilities and services. Policy References: • King Subregional Plan Phased Growth Policy #1 New commercial and other intensive activities should locate in existing urban and suburban centers: New residential development, offering a variety of housing opportunities should locate in existing centers, in skipped -ver lands and in locally selected lands on the suburban /rural edge which have been committed to development. (5) (continued) • King Subregional Plan Activity Centers Policy #1 Concentrations of jobs, shopping, government, business, service and cormercial activities should locate in de- signated activity .centers.. • King Subregional Plan Activity Centers Policy #3 The ultimate designation of activity centers rests with local governments. Local governments should affirm or revise the preliminary activity centers based upon the criteria in Table 1. The subregional council shall re- view and adopt designated activity centers within 18 months of adoption of the King Subregional Plan. King Subregional Plan Activity Centers Policy #4 Retail, office, government and employment growth should locate in existing urban and suburban centers. King Subregional Plan Activity Centers Guideline #4.2 Rehabilitation or redevelopment projects in designated centers should be given the highest priority for public investments that stimulate retail and office development and for economic development funds. • King Subregional Plan Activity Centers Guideline #4.3 The public sector, through land use regulation, should discourage duplication or dispersion of activities (re- tail, cultural, institutional) that will damage the cost effectivensss of public investments being made to rein- force designated centers. Dispersion of activities that should locate in centers would reduce the arket for public transit and pedestrian facility improvements, thereby con- tradicting the public access and energy conserving objectives of the activity center concept. Project is consistent with J7 consistent with conditions /--T inconsistent with /-7 is not applicable to [ the above policy criteria. Consistency cannot be determined from the information available /% The location of hotel, office, and retail development on the Tukwila City Center site is consistent with this policy cri- teria. Although no specific part of Tukwila has been desig- nated as an activity center, the Southcenter /Andover area . is certainly a logical candidate for such a designation. The PSCOG is encouraged by the plans being made to encourage (5) (continued) transit use for trips to and from the site; however, auto - \ mobile trips will clearly remain the prime mode of travel. The EIS should consider the impacts of an alternative de- sign in which parking for employees and shoppers is con- siderably reduced. Would such a design be acceptable to shoppers and office tenants? The King Subregional Plan Activity Centers Policies cited on P.30 of the EIS encourage activity centers to become more public transit oriented and to reduce their depend- ence on private automobiles.= The EIS mentions that the sponsors hope that their project will become a focus for activity in Tukwila. To accomplish this ambitious goal, the King SRC believes Tukwila must en- courage developers of additional office, hotel,, -and retail space to design their projects in a way that will complement the Tukwila City Center project. The creation of scattered pockets of office and retail activity isolated by parking lots and intervening low- density activity should be avoided. The EIS should provide a more detailed discussion of how well the Tukwila City Center concept meshes with the City of Tukwila's plans. What other activities are planned for the vicinity of the Tukwila City Center site? Will such activities be consistent with the city center approach. (6) Existing neighborhoods should be conserved and revitalized. Policy References: o King Subregional Plan Phased Growth Guideline #1.6 Infill development, consistent with this policy, should be substantially compatible with the type of use or density prevailing in the area. o King Subregional Plan Phased Growth Guideline 02 Highest priority should be given to programs and funding proposals which improve or-maintain the capability of local governments to provide necessary services and public improvements in areas where growth is encouraged. Project is consistent with /% consistent with conditions /--7 inconsistent with /7 is not applicable to 4sir the above policy criteria. Consistency cannot be determined from the information available /--T • (7) Development should not damage and, if possible, should strengthen the fiscal condition and tax base of urban communities • -7,;Policy References: • King Subregional Plan Phased Gro• wth Guideline #2.1 The relative public costs of providing facilities and services should be carefully considered by local govern- ments when they designate areas with high priority for development. • King Subregional Plan Phased Growth Guideline #5.1 Local Government land use plans should consider the impacts of concentrating subregional growth. • King Subregional Plan Phased Growth Guideline ?7.4 The review of programs and allocation of funds should include incentives for communities making a clear effort to provide a reasonable amount of housing opportunity for people needing low and moderage- income rental units. Project is.consistent with i--7 consistent with conditions / inconsistent with /7 is not applicable to /-7 the above policy criteria. Consistency cannot be determined from the information available The EIS does not discuss the fiscal impact of the Tukwila City Center project in any detail. If the DEIS is correct in stating that only one new fireman and two policemen would be hired as the result of the project,and no signifi- cant water sewage improvements would need to be constructed, the fiscal impact would appear to be favorable. However, significant transportation improvements will be required in the Tukwila City Center vicinity due to this project and others such as the adjacent Orillia Industrial Park. Tukwila has estimated these improvements will cost at least $13 million. The EIS should discuss, as was re- quested in Comment #3d, alternative methods of financing the improvements and the sponsor's willingness to co- operate in such an effort. The impact of the Tukwila City Center project on other activity centers is also of concern to the King Sub - regional Council. The EIS spends a considerable amount of space discussing this issue but the use of forecasts to prepare the analysis raises some questions. ) ' (continued) (a) What is the source of the population and employ- ment forecasts for King County 1980 - -1990 found in the tables on pages 100 and 103? We note that while these forecasts show some similarity to PSCOG's forecasts there are some very significant differences. The most significant difference is the population forecast for the county sectors . found on page 100 of the EIS on Table XV. The comparison between the EIS and PSCOG figures is found below: POPULATION GROWTH 1980 1980 - 1990 1. NW Seattle - Shoreline 2. Eastside Bellevue - Issaquah .3. Southwest - Federal Way 4: Southeast Renton Auburn E15. (PSCOG) EIS PSCOG (TRENDS) (POLICY) 560,000 (560,000) 53,000 ( 6,000) (22,000) 259,000 (240,000 66,000 (59,000) (53,000) 185,000 (176,000) 52,000 202,500 (233,000) 50,000 Outlying 28,000 ( 28,000) 5,000 King County Total 1,235,000(1,235,000) 225,000 (32,000) (39,000) (92,000) (44,000) ( 2,000) ( 2,000) (190,000) (160,000) All of the above figures are approximate and some of the differences between the EIS and PSCOG figures may be accounted for by the geo- graphic differences in the boundaries of the subareas, but there remain a couple of major differences which need to be explained. These are the very large growth forecast by the EIS for Seattle - Shoreline and the relatively low - growth forecast for southeast Renton - Auburn. (b) What are the implications for Seattle and the south- east area from these different forecasts? It would appear that impacts on Seattle would be more severe than the EIS claims if the PSCOG forecasts of popu- lation growth are closer to the mark than those pre- sented in the EIS. It would also appear that the southeast county could support a shopping center even if the Tukwila City Center is built if the PSCOG Trends forecast of 1990 population is approached. continued) While the Subregional Plan does not give preference to expansion of one activity center over the others, it is important that the impacts on existing acti- vity centers from projects,such as Tukwila Center, be adequately described before a final decision to allow them to go ahead is made. (8) New employment activities are encouraged to expand the job - opportunities available and accessible to minorities and the unemployed. Policy References: o Regional Development Plan Economic Policy #7 Encourage public /private coordination in the planning and development of job creating activities to assure the pursuit of common economic objectives. • Regional Development Plan Economic Policy #8 Encourage ..the location of new economic activity which generates employment opportunities that are accessible to areas with high concentrations of low- income and unem- ployed residents Regional Development Plan Economic Policy #9 Encourage the coordination of public manpower training and affirmative action programs so that unemployed, underem- ployed and other disadvantaged citizens can more equally compete for job opportunities. Project is consistent with LT consistent with conditions /-7 inconsistent with /% is not applicable to [/ the above policy criteria. Consistence cannot be determined from the information available /77 Tukwila City Center will be located on a site that will be reasonably accessible to disadvantaged people in south Seattle, Highline, White Center, Renton, and Burien. The sponsors and City of Tukwila have indicated a willingness to make the project compatible with public transit and a desire to see transit service improved in Tukwila. 111 III (9) Projects located in non -urban areas should be compatible with existing land uses and should not foreclose the option for ur- banization of the area in the future. \\Policy References: • King Subregional Plan Phased Growth Policy #3 A supply of buildable land should be maintained that is sufficient in area to meet the subregion's housing and employment requirements, and located so as to be effi- ciently provided with public facilities and services. • King Subregional Plan Phased Growth Policy #4 Local governments should identify lands to be reserved for future development. • King Subregional Plan Phased Growth Guideline #5.3 Guidelines for the retention of a minimum amount of non - developed vacant skipped -over land should be set by local government to provide for continuation of the open, di- verse and natural feeling of urbanized King County. Planned unit developments, dedication, acquisitions and "fee in lieu" programs may all contribute. • King Subregional Plan Phased Growth Policy #8 Local land use plans should recognize and protect areas where open space or extremely low intensity uses are of local or subregional benefit. Project is consistent with /7 consistent with conditions /7 inconsistent with /7 is not applicable to ? the above policy criteria. Consistency cannot be determined from the information available /-7 (10) Only activi•s.-compatible with agricural uses should be located on lands in designated agriculture districts. Policy References: -• King Subregional Plan Phased Growth Policy #8 Local land use plans should recognize and protect areas where open space or extremely low intensity uses are of local or subregional benefit - :- • King Subregional Plan Phased Growth Guidelines #8.1, #8.2 Tax incentives, development rights purchase, open space _ easements and other measures should be applied to rein- force agricultural activity where it is still a productive, beneficial and financially feasible land use. Encourage land use regulations and economic development pro- grams that foster retention or creation of agricultural support activities, such as food processing or transportation facilities • Regional Development Agriculture Policy #4 A -95 and EIS reviews shall support the exclusion of any lands designated for continuance in agriculture from local improve- ment districts established for the construction and /or maintenance of non -farm improvements. Project is consistent with /-7 consistent with conditions /T inconsistent with /--7 is not applicable to the above policy criteria. Consistency cannot be determined from the information available /% (11) The.guidelines for Phased Growth Policy #8 should be observed' when new developments are to.he located 1;n hazardous areas, Policy Reference: • o King Subregional Plan Phased Growth Guidelines #'s 8.4, 8.5, and 8.6. Development should be prevented or curtailed in environ- mentally hazardous areas. Nonstructural solutions to be environmental hazards should be encouraged. Urbanization of designated flood -prone areas should be dis- couraged. Project is consistent with /77 consistent with conditions /7 inconsistent with./--T is not applicable to LRT the above policy criteria. Consistency cannot be determined from the information available /7 • (12) Important natural areas should be protected. Policy Reference:. •. King Subregional Plan Phased Growth Policy, #8 Local land used plans should recognize and protect areas where open space or extremely low intensity uses are. of local or subregional , benef i"t . • Regional Development Plan Natural Environment Policy #2 All planning should recongize the need to conserve areas where critical natural processes whould be endangered by development. Project is consistent with /7 consistent with conditions / inconsistent with /% is not applicable to the above policy criteria. Consistency cannot be determined from the information available /7 (13) Transportation Projects should be consistent with the priorities set in Transportation Policy i1.• Policy Reference: • King Subregional Plan Transportation Policy X41 Transportation projects should be developed with emphasis placed in the following order (within each category, im- provements to benefit transit and other high occupancy vehicles, when appropriate, should be given preference): A) Improvements to facilities necessary to correct existing safety problems and maintain structural integrity and operational capability of facilities and systems; B) Improvements necessary to implement the King Subregional Plan by insuring the viability of designated activity centers, consistent with the character defined for each type of center; C) Low capital solutions to transportation problems, compatible with subregional activity center and phased growth objectives, which better utilize existing trans- portation facility and service investments; „(13)`.' (.continued)Aw._ D) Capital intensive improvements, compatible with sub - regional activity center and phased growth objectives, which increase the capacity of existing. facilities; New facilities in areas suitable for increased develop- ment as defined by subregional and local plans. . Project is consistent with /% consistent with conditions /% inconsistent with _/% is not applicable to the above policy criteria. Consistency cannot be determined from the information available /--T • Bob Edmundson January 22, 1980 Page 2 measures proposed for Andover Park West and for Strander Blvd., however, will probably provide an adequate level of service (D or better) for 1985 with the development of Tukwila City Center. The level of service at the intersection of Strander Blvd. and Southcenter Parkway will require short range improvements which were not discussed in the mitigating measures section, in order to remain at Level of Service if Tukwila Center is constructed. 5. Trip generation rates used for the retail shopping center and the office complex are completely unrealistic at a local level. More likely rates and trips produced are shown below: Square Weekday P.M. Peak Building Feet Rate Trips Trips Shopping 800,000 31.6 22,720 2,380 Office 600,000 12.3 7,380 1,320 The net increase in local trips over those shown in the DEIS is 7,300 weekday trips and 1,300 P.M. peak -hour trips. These trips would impact Strander Blvd. and Andover Park West, with severe impacts on that intersection and the intersection of Strander Blvd. and Southcenter Parkway. 6. A more likely total number of vehicle trips into and out of Tukwila City Center is 34,800, not the 27,500 used in the DEIS. The pre- Christmas shopping period would then yield 45,500 weekday trips, not 36,000. The associated impacts would therefore be much greater. 7. On a peak -hour basis, the local impact of Christmas shopping would be more severe than stated, with an increase of 1,350 trips. This is 49% higher than the number in the DEIS. 8.' The Tukwila City Center project appears to add only 21,500 trips as plotted on Figure 13, not the 27,500 as stated on page 72. 9. Traffic accidents and hazards are not addressed. In addition, potential hazards posed by turning movements into and out of Tukwila City Center are not addressed. KR:CC:co PSC • GGrand Central on the Park • 216 First Avenue South • Seattle, WA 98104 • 206/464 -7090 January. 28, 1980 Mr. Fred Satterstrom Planning Director 6200 Southcenter Blvd. Tukwila, Washington 98188 Dear Mr. Satterstrom: The King SRC Staff, acting regional Council, reviewed Statement for Tukwila City earlier last week. Puget Sound Council of Governments Li L 0.C.D. CITY OF TUMIIA JAN 3 1 1980 on a request by the King Sub - the Draft Environmental Impact Center, which was sent to you The King SRC, by policy, reviews only those environmental impact statements that propose actions which have signifi- cant implications for achievement of the goals and policies of the King Subregional Plan and Regional Development Plan. The DEIS was reviewed against a set of policy criteria which are intended to summarize the thrust of the policies and suggested guidelines of these two plans. In each case the reasoning used in deciding whether the action would be consistent, inconsistent, or not applicable to the policy criteria is included on the comment sheets. We hope that these comments will be useful to you. Sincerely, AP .r- J mo m Billing King Subregional Council • 666 Bellevue Way S.E. • Bellevue, Washington 98009 • 206/455 -7669 ROGER L. SHIDLER GEORGE W. McBROOM WILLIAM H. GATES WILLIAM F. BALDWIN JAMES R. IRWIN JAMES C. MIDDLEBROOKS RICHARD B. DODD FREDERICK ROSS BOUNDY WILLIAM H. NEUKOM JAMES L. FLETCHER DAVID T. MCDONALD PATRICIA J. PARKS DALE K. ROUNDY GARY D. HUFF WILLIAM A. BUTLER DAVID H. BINNEY ROBERT A. ESHELMAN CONSTANCE L. PROCTOR • SHIDLER, McBROOM, GATES & BALDWIN A PROFESSIONAL SERVICE CORPORATION LAW OFFICES 1000 NORTON BUILDING SEATTLE, WASHINGTON 99104 January 23, 1980 Mayor Frank Todd, City of Tukwila Members of the City Council City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Re: Southcenter Response. Chartwell (Tukwila City Center) DEIS Gentlemen: (206) 223 -4666 RECEVED ;..,: O.C.D. •.. c CM OF TUKWILA [JAR. 2.4 1 In reviewing the supplemental memorandum to Southcenter's response to the above DEIS, I discovered two obvious mathematical errors explained in a memorandum to Mr. Kjell Stoknes which is attached. With this I enclose, new copies of pages 4 and 1.3 to the supplemental memorandum and request that you insert them in place pages 4 and 13 of the supplemental memorandum previously sent you. Because of time pressures in making these responses, there very well may be other mathematical errors, but I certainly wanted to correct these. GWM:pj Encs. s very truly, George McBroom To: From: Kjell Stoknes 40DLER, McBROOM, GATES & BALD• A PROFESSIONAL SERVICE CORPORATION 1000 NORTON BUILDING SEATTLE, WASHINGTON 98104 Memorandum , George W. McBroom Re: Chartwell (Tukwila City Center) DEIS - Southcenter Response Date January 23, 1980 In reviewing the supplemental memorandum to my client's, Southcenter, response to the above DEIS, I discovered two obvious mathematical errors. The figure of "2.82 sf" appearing in the last line, second paragraph, Section 2.1 at page 4 and in the first line of the last paragraph of that Section should be "3.47 sf ". At page 13, beginning the sixth line from the top, reference is made to "6. • 5'" The reference should be "6.5 acs. ". The percentile reduction in the next line is 38% rather than 27 %. I have enclosed revisions of these two pages and ask that you insert them in our supplemental memorandum. 2. Rezoning from C -M._to C -PR (or Development to PUD Concepts) is Essential: 2.1 Intensity of Developer's Proposed Land Use: At DEIS p 60 the Developer tells us that the building to land ratio will be 1.2 sf to 1. Developer here includes the entire 38.9 acs and forgets that 1/3 of this acreage has been reserved as a type of "nature conservancy" by Guideline 6, City Resolution 656 (DEIS p 28), reducing available land use to 27.9 acres. On this basis the ratio of building to land becomes 1.63 sf building to 1 sf land. Developer, however, fails to include in building area two stories of underground parking, each of approximately 25.5 acs or 51 acs total. On this basis the ratios become 3.47 sf of building per 1 sf of land. Even assuming Developer's 1.2 building to 1. land ratio, Developer says at DEIS p 60: "The proposed floor -area ratio of approximately 1.2 square feet of building for each square foot of land would represent a more intensive land use utilization than now exists on any parcel this size in the region outside of a few major downtown areas." With this we surely concur. We assert that a 3.47 sf building - to -land ratio would be difficult to find on any 27.9 ac tract in Downtown Seattle. 2.2 C -M Classification Under the City Zoning Ordinance Never Intended to Permit Such Intense Use: Regional shopping center use of 800,000 sf with 2 or 3 major department stores was intended only under the C -PR classification. It is no doubt true that the C -M use provi- sions at Code 18.32.010 permit C -1 (Neighborhood Retail Business) and C -2 (Local Retail Business) uses. We concede that the types of retail business which may be carried in a C -1 or C -2 zone cover most activities proposed by the Developer except the hotel for which a conditional use permit is required. City planning officials and the Developer well know, however, that such intensive use was never intended to be permitted in a C -M zone. If the drafters of the Code had intended C -PR (Regional Shopping Center) uses in a C -M zone the code would have included C -PR uses as permitted uses in C -M and would not have restricted the character of retail business to the C -1 and C -2 neighborhood and local categories. If such had been the intent, the C -M parking 4 • the water surface of the Pond generally (year -in, year -out) covers approximately 16 -17 acs. This appears again at DEIS p 60. Developer never reveals the surface acreage of the Pond after "redevelopment" but the Site Plan, Figure 4 at p 16, indicates a surface water acreage of approximately 6- 6.5 acs. I do not regard a reduction of the Pond's surface to 38% of its present size as responding to a Criterion that requires that "major portion" be retained. 5.3.10\ Guideline 10: Development Plans, Depicting the Future Utilization of the Entire Site, Should be Submitted at the Time of Waiver Application Review Any Proposal Indi- catin7 Less than Full Development of the Entire Site Should Contain, at a Minimum, Complete Plans Indicating Treatment of the Pond and Adjoining Wetland Wildlife Areas: The Developer responds that the DEIS fulfills this Criterion. I believe it is demonstrated above that this DEIS contains little but promises by Developer to provide future studies for review by the City. Developer does not even offer his survey and study said to have been made by his wildlife biologist. I conclude that the Guideline 10 require- ment has not been met. 6.1 Absence,of Storm Study and Data: 6.1 Inconsistency with Comprehensive Plan: As pointed out in Section 2.3.2 above, the goal of the CLOP is to "encourage the preservation of marshes and ponds for the retention of storm water. runoff." Developer, at "Unavoidable Adverse Impacts" DEIS p 117 cites as one of these "reduction in flood water storage capacity of the local storm drainage system." As pointed out in paragraph 6 of our letter, unless a full and detailed study and report is made by a responsible engineer and attached to the DEIS, it is impossible for the City, or for ourselves, to assess the degree of "reduction in flood water storage capacity" Developer's Project will cause. DEIS at p 94, however, says that: "The principal impact of the Proposal on the City's storm drainage system would be the loss of the existing flood waters storage capacity of the Pond." Without expert data, we can only assume the entire storage capacity of the Pond would be imperiled. 6.2 Mitigating Measures: As pointed out in our letter, DEIS at p 94 suggests: "Measures which could be studied include (1) provision for 13 . C 4,1 King County, Stateshington John D. Spellman, C unty Executive Department of Budget and Program Development Mary Ellen McCaffree, Director Budget Division Room 400, King County Courthouse 516 Third Avenue Seattle, Washington 98104 John M. Rose, Manager (206) 344 -7370 January 23, 1980 Mr. Kjell Stokeness Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Dear Mr. Stokeness: The draft EIS for Tukwila City Center has been reviewed by our Planning Division. Attached are their comments on this draft EIS. Thank you for the opportunity to review this draft EIS. Sincerely, Mary Elle Chairman Environ mmittee MEM /pt January 22, 1980 King County te of Washington John D. Spellman, County Executive Department of Public Works James W. Guenther, Director 900 King County Administration Building 500 Fourth Avenue Seattle, Washington 98104 Telephone: (206) 344 -2517 Mr. J. R. Edmundson Department of Budget and Program Division C O U R T H O U S E Re: Draft Environmental Impact Statement - Tukwila City Center Dear Mr. Edmundson: This department has reviewed the subject draft environmental impact statement and forwardsthe following comments: 1. Drainage from this site should not be allowed to enter the P- 17 drainage system. If this diversion was allowed, the P -17 drainage system would be inadequate to handle a 100 year frequency storm, and flooding to developments could result. 2. A drainage system should be provided so additional flood- ing will not result. 3. We have analyzed the transportation and circulation section. The mitigation measures as set forth in the "ENTRANCO Roport" should be implemented during the construction of this project which will assure orderly and safe movement of vehicles and pedestrians within the total Southcenter area. JAMES W. GUENTHER Director JWG:OHR;ch *ILA 1908 City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 Frank Todd, Mayor MEMORANDUM TO: Kjell Stoknes, Community Development Department FROM: John A. Sheets, Chief of Police DATE: January 21, 1980 SUBJECT: Chartwell Development - Preliminary E.I.S. C.C.D. CM CF TIVI1LA JAN 2 1 1980 A perusal of the Tukwila City Center Draft E.I.S. document generates several questions: #1 - Page 86 - Environmental Impact - "one of two officers would be required to adequately serve the development" - how was this conclusion determined? We feel there may be a need for more officers because the document alludes to a traffic increase of 27,500 vehicle trips per day; an increase in area employment of 4,500 persons; and an undetermined number of visitors to the retail- office -hotel complex on a daily basis. ;✓62 - Will construction of the Center commence prior to: a. Agreement as to the necessary road improvements. b. Funding of improvements. c. Implementation of the improvement program. #3 - Many questions arise as to the overall security measures to be employed in all areas of the facility. Has consideration been given to consultations regarding security, between two site engineers /architects and the Tukwila Crime Prevention Director? #4 - Prior to commencement of construction will final detailed plans of the facilities be available for study along with the general security outline for the proposed site? Department of Energy Region X 1992 Federal Building 915 Second Avenue Seattle, Washington 98174 (206) 442 -7285 Kjell Stoknes Director of Planning Office of Community Development 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: .V• CM OF TU :4ItA JAN 2 3 1980 January 21, 1980 The Department of Energy (DOE) appreciates the opportunity to comment on the Draft Environmental Impact Statement (EIS) for the Tukwila City Center in Tukwila, Washington. Three of the responsibilities assigned to the. DOE when,Congress enacted the DOE Organization Act (42 USC 7101) were: (1) To promote efficiencies in the use of energy resource (15 USC 764(b) (7)); (2) To place major emphasis on the development and commercial use of solar, geothermal, recycling and other technologies utilizing renewable energy. resources (42 USC 7112 (6)); and, (3) To provide for the cooperation of Federal, State, and local governments in the development and implementation of national energy policies and programs (42 USC 7112 (11)) (emphasis added). This Regional Office is utilizing the EIS comment process as one way to fulfill these responsibilities assigned to the DOE by Congress. This Office, therefore, reviewed the referenced Draft EIS to determine not only the specific impact of the alternatives on energy consumption, but also to assess: (1) the adequacy of the EIS's broad consideration of energy use, (2) the type-and nature of energy use, and (3) the consideration given to energy conservation/ efficiency and renewable energy measures. We would like to commend you on your consideration of energy expenditures for both construction and occupant use. The EIS addresses completely and concisely primary areas of energy use /consumption associated with a project of this type, and suggest many excellent mitigating measures. 5 Letter to Kjell Stiles from Nan Evans January 21, 19 Page 2 of 2 However, the EIS does not estimate the increase in motor vehicle fuel consumption caused by the 27,500 additional vehicle trips per day generated by the completed project. This is equivalent to approximately 3.6 billion Btu's per day. Your mitigating measures for improvements in mass transit, carpooling and vanpooling are good. These measures would significantly reduce energy expenditure. The EIS specifies some.excellent mitigating measures to be taken to reduce energy consumption.such as; insulation to - reduce -heat loss-and-solar heat gain, use of skylights and interior lighting systems to eliminate unnecessary energy use, and air balance to minimize. outdoor loss of the heating ;and air' conditioning systems. You should also consider double glazing of windows and, as mentioned in the EIS, building configuration. Design factors can be incorporated :into the proposed buildings to provide, for example, for optimum-use-of available solar energy. These factors include the placement of major.windows on the south side of the building; locating major living areas in the southern portions of the buildings; placement of a thermal mass.(e.g.,,a concrete wall) where it will receive the rays of the winter sun, end shading or minimization of windows on the western side of the building to keep outdate afternoon sun (thus, reducing need for air conditioning). Significant energy saving opportunities exist if these design factors are considered. .We request that 'King County encourage the project developer and contractors .to •consider'these factors within the . discretion allowed them by the specific site characteristics, local zoning requirements, and applicable building codes. This Office again thanks you for the opportunity to review and comment on your Draft EIS. We'hope our comments will be helpful in the preparation of a more specific and quantitative Final EIS, and in,further consideration of alternatives. If we can be of further assistance, please do not hesitate to contact us. Sincerely, Nan Evans Environmental Programs Coordinator Office of Assessment and Integration cc: Lee Johnson, Director External Affairs Staff, Region X, DOE Dr. Robert Stern, Director, Division of NEPA Affairs, Office of Assistant Secretary for Environment, NDOE Paul Brumby, Director, Federal Program Office, Office of the Assistant Secretary for Conservation and Solar Applications, NDOE Stan Springer, Environmental Review Section, Washington State Department of Ecology, Olympia, Washington JCPenney Kjell Stoknes, Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Dear Mr. Stoknes: January 21, 1980 RE: PROPOSED ALL DEVELOPMENT, "TUKWILA CITY CENTER" Thank you very much for the opportunity to review the environmental impact statement regarding this proposed development. I have several immediate concerns in regard to this E.I.S. Because of the nature of these concerns, and because of the short time since my receipt of the draft Environmental Impact Statement, I would like to request additional time to prepare more complete comments for your consideration. I believe that within two weeks I could draw together from earlier traffic studies and marketing surveys specific data which would be needed to support my following comments. Because today is the published deadline for comments, I am preparing these in a preliminary form so that they will be on record with. you. I am the District Manager for the JCPenney Company for the Puget Sound district and, as such, am responsible for the operation of Penney stores and facilities in the Tukwila area. We are major co- tenants in the existing Southcenter shopping center, as well as occupants of the warehouse and office facility located at 17200 Southcenter Parkway. As such, I am concerned with several areas in the E.I.S., but particularly with the following: I. Vehicular traffic and circulation analysis: ..The trip generation rates used area in the summary table X on page 71 of the E.I.S. seem to have been interpreted based on "suppositions" which are suspect, in that they seem to have been carefully selected to minimize the resultant estimate of trips generated. This is of serious concern, not only in regard to vehicular traffic itself, but perhaps as well in regard to the pollution and noise impact discussed elsewhere. ..The parking ratios for the proposed retail and other commercial uses appear inadequate. Our experience as tenants in Regional Shopping ....continued J.C. Penney Company, Inc., Post Office Box 24087, Seattle, Washington 98124 Kjell Stoknes, Director of Planning page two Centers has led us to develop minimum criteria for parking of one parking space per 200 square feet of gross space. While current zoning for the City of Tukwila would allow one space for 400 square feet, I do not believe this would be adequate for a retail project such as the one proposed. ..Under "existing conditions" in regard to arterial streets and traffic volumes (pages 67 - 69) the proposed project's impact on area -wide . traffic accessible "cordon area" seem to have been drawn without consideration of proposed and /or probable future development in the Southcenter and surrounding areas. Given that the freeway ramp termini and arterial street intersections providing access to this area would be impacted in the future by such development,to look at the effect of the proposed Tukwila City Center as a free - standing entity would seem unrealistic. ..While the cost of the arterial road improvements proposed in the E.IS. would obviously be tremendous, I see no reference as to where the costs would be borne. As a major tenant bearing financial implications in regard to taxes .and /or assessments, at least indirectly, we are concerned with this question. These concerns and others which I have would require some time to prepare a more complete form as I indicated above. It is to be hoped that we could be heard from more fully at a later date. I would also like to request that I. be put on the mailing list to be informed of any and all public hearings to be held in regard to this project. Again, I appreciate the opportunity to comment an the E.I.S. Sincerely, JCPENNEY CON.PANY, INC. W. R. Lewis District Manager WRL:ib cc: Mark Caughey, Office of Community Development City of Tukwila M. Lowenkron, JCPenney Company • QV-eafit • A Washington Chapter of National Audubon.Soci''eyyPy.C.D. 714 Joshua Green Building • Fourth Avenue and Pike St., Seattle, Wash. 9 13`1 r('01°F (a ) 622 -6695 Mr. Kjell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 January 21, 1980 Re: "Tukwila City Center" draft EIS, December 17, 1979 ATTENTION: Mr. Mark Caughey Dear Mr. Stoknes: 'JAN 2 2 1980 , You have got to be kidding. This draft EIS is actually a form of black humor, an unseasonal April Fool joke, right? Surely you are not serious in trying to pass this off as a "retail shipping office and hotel complex focusing, an a wildlife pond and natural area . modified to maximize the effectiveness of this wildlife habitat . . •" as quoted from the lead -off description of the "Proposed Action" on page 1. Let's get serious real fast. i Page 50: "The variety and productivity of the site are unmatched in any com- parably sized site in the Green River Valley or the Greater Seattle Area. This factor combined with the close proximity to intensively developed adjacent land makes this site truly unusual and gives it regional significance as wildlife habitat." Not bad, so far; we agree completely with this statement from the draft EIS (one of the few statements where we are in agreement) and wish to emphasize the key thought - "unmatched habitat"in the greater Seattle area ", "truly unusual ", (of) "regional significance as wildlife habitat ". Much more could and should be said about this aspect of this site. The draft EIS is completely inadequate in its characterization of the wildlife of this site and the significance of the site for regional wildlife. The proposal includes an 800,000 square foot shopping center, 600,000 square feet of office buildings, 600,000 square feet of hotel space including 400 rooms and 375 suites, two ten -story buildings, and parking for 6,300 cars. Paragraphs 60 -61: "The proposed development would convert about 70 per cent of the site from its present undeveloped state to retail shopping, office and hotel use. The proposed floor -area ratio of approximately 1.2 square feet of building for each square foot of land would represent a more intensive land utilization than now exists on any parcel of this size in the region outside of a few major downtown areas." Please explain to us how this type of development can be proposed under the guise of "focusing on a wildlife pond ". That is, on a pond with wildlife. All the attempts to gloss over this situation in this draft EIS are not simple obfuscation, but direct insult to the intelligence of the reviewers. • • 2. Data on the Existing Conditions, Environmental Impacts, and Mitigation are completely lacking. For example, what species of birds and other wildlife have been documented to utilize this site? Which ones are expected to continue using the site during construction (over a five year period)? After the proposed project is com- pleted? Which ones will be "displaced" (to use the disgracefully common EIS expression)? Please review the definition of mitigation. Your use of it in this draft EIS is painful to confront and totally unacceptable. One does not "mitigate" destruction of waterfowl habitat by erecting "interpretive displays" (page 5) nor mitigate" soil settling by scheduling trucks to "avoid traffic peak hours" (page 3). Who wrote this draft anyway? City of Tukwila Resolution #656 establishes a number of guidelines for the use of this specific site. The discussion on pages 26 -30 of the draft EIS on these points and "responses" (rebuttals, side - steps, obfuscations)`to each is worse than inadequate; it is grossly misleading in its attempt to portray an open -and -shut case on all the points, when in fact no data are supplied in the document to justify any of the state- ments made. Example: guideline #1 requires that surface runoff not be routed into the pond ,unless measures are taken to assure water quality; response #1 begins "detailed drainage designs for the site are not completed ". flow then can impact be assessed? We could go on and on, but what is the point? This draft Environmental Impact Statement is required by state law to describe adequately the existing site, the proposed activity, and its impact. It accomplishes none of these objectives and is unacceptable in its entirety. We demand that a new draft EIS be peepared which is serious in meeting state -law. Don't be bullied into acquiescence on this proposal by threats of legal action against the City of Tukwila;,; such as those on page 111. Do a proper, legal review of the proposal beginning with a new, proper legal draft EIS under S.E.P.A. Thank you for the opportunity to comment. Please keep us informed of all action on this project. Very truly yours, David V. Galvin Conservation Chairman Seattle Audubon Society DVG /JS cc: Washington State Dept. of Ecology Washington State Dept. of Game Metro environmental Planning King County Planning Puget Sound Council of Governments U.S. Fish & Wildlife Service STATE OF WASHINGTON DEPARTMENT OF GAME 600 North Capitol Way, GJ -11 Olympia, WA 98504 206/753 -5700 Dixy Lee Ray Governor January 18, 1980 Mr. Kjell Stoknes Director of Planning Office of Community Development 6200 Southcenter Boulevard Tukwila, Washington 98188 Mr. Stoknes, CITY OF ILi ;'.'iILA JAN 2 1. 1980 DRAFT ENVIRONMENTAL IMPACT STATEMENT: Tukwila City Center Your document was reviewed by our staff as requested; our comments follow. Your impact statement is basically would have a significant impact on figure 7 on page 48, it appears at classified as wetland and critical well written. However, this proposal the public's wildlife resources. From least 75 percent of the site would be wildlife habitat. • The waterfowl value of Tukwila Pond is well known and well documented in your statement. Wetlands in King County, and especially Green River drainage areas, are especially important since so many of the wetlands have already been lost to industrial and urban development. Important wetlands have been lost to diking as well as other actions in Auburn and Kent areas. The wetlands in the Green River Valley are important for water quality and quantity in fish bearing streams, as well as providing habitat to varieties of songbirds, resident waterfowl, small mammals, and raptors. However, their greatest value may be to migratory waterfowl of the Pacific Flyway. These birds rest, feed, winter, and depend on this habitat. As your document accurately states, the proposal will cause a reduction in the number of waterfowl and other wildlife. Loss of over ten acres of wetlands (pond and wet grasslands) could set serious precedent that might make it difficult to prevent wetland loss in other areas. Because the project, as proposed, would result in the uncompensated loss of the public's resources, we suggest you reconsider this action. Tukwila Pond is a unique type of wetland, as it has not evolved as part of a natural system. It does hold potential for enhancement. Therefore, it may be possible to work out a compromise, but this would require partici- pation of resource agencies such as the federal Fish and Wildlife Service, State Game Department, and citizen groups such as Audubon societies. A compromise proposal would require a substantially different: development proposal for the property that would have less impact on the wildlife resources. 3 • • Mr. Kjell Stoknes January 18, 1980 Page Two We have the following comments on your impact statement. 1) Page 4 and 45: Deepening the pond and adding water circulation and aeration facilities would not benefit wildlife. We do not recommend these actions. 2) Pages 26 -30: We wonder if this proposal does not conflict with some portions of your comprehensive land use policy. Does it not conflict with city resolution 656 guidelines 2 and 8 that call on the use of the pond for wildlife and waterfowl habitat? The proposal would also conflict with King County sensitive areas zoning ordinance and ordinance 1838 that call for the protection of wetlands. While these ordinances are not in force in the City of Tukwila„ they demonstrate a change in local attitudes and a recognition of the public value of wetlands. 3) Page 41: What is the size of the pond in the months of January or February? In the final impact statement could you show a drawing depicting the pond and wetlands in winter. 4) Page 45: Stormwater would need to be cleaned of silt and oil before it is discharged to the pond. Maintenance and frequent cleaning of pollution abatement facilities would be essential. 5) Pages 47 -50: If the existing pond edge is "the most productive and critical habitat of the site" and if the brushy pond edge on the north is removed, how would the most productive habitat types currently found on the site be preserved? 6) Page 51: The most significant human disturbance factor on wildlife would result from hotels. There is human activity at hotels 24 hours each day. 7) We strongly recommend you choose the alternative of the ,applicant resubmitting with a substantially different development for the parcel. Due to the enhancement potential of the pond, a compromise proposal that would not result in a significant loss of public resources may be possible. Work in the pond would require Hydraulic Project Approval from our agency and the Department of Fisheries. If you have any questions, please call us at 753 -3318. • • Mr. Kjell Stoknes January 18, 1980 Page Three Thank you for sending your document. We hope our comments are helpful. Sincerely, THE DEPARTMENT OF GAME Bob Zeigler,, App 'tied Ecologist Environmental Affairs Program Habitat Management Division BZ:cv cc: Agencies Regional Manager DOUBLE rirlztlE JE ZMg January 18, 1980 Mr. Kjell Stoknes Director of Community Development City of Tukwila 6200 Southcenter Blvd Tukwila, Washington 98188 Dear Kjell: J SOUTHCENTER • 205 STRANDER BLVD. • SEATTLE, WASHINGT0 98188 • TELEPHONE (206) 246 -8220 c(r( tU "" SAN Z 1 108 In response to the DRAFT ENVIRONMENTAL IMPACT STATEMENT on the proposed Chartwell Development, my only concern are those of future traffic and pedestrian flows. This past fall the City of Tukwila directed the traffic consulting firm of Intranco to develop a "short range" solution to the current traffic situation. But to my knowledge no long range planning or study has been done or is under serious consideration to address the traffic situation that will exist when the Tukwila Industrial 's /Commercial /Ret.ail areas are fully developed. •I believe this type of study is imperative, for it is a certainty that the Intranco remedies would be willfully inadequate to handle the development that is being considered now and other developments that will occur in the months and years ahead. Thank you for your consideration. Cordially, Ti o . 'ubois Gen al Manager TSD:dc OTHER DOUBLETREE LOCATIONS— Doubletree Inn of Phoenix • At Park Central, Mall • 212 West Osborn • Phoenix, Arizona 85013 • Telephone (602) 248 -0222 Doubletree Inn of Tucson • At Randolph Park • 445 South Alvernon Way • Tucson, Arizona 85711 • Telephone (602) 881-4200 Doubletree Inn of Scottsdale • At Fashion Square • 4710 North Scottsdale Road • Scottsdale, Arizona 85251 • Telephone (6021947 -5411 Doubletree Inn of Scottsdale • At Scottsdale Mall • 7353 East Indian School Road • Scottsdale, Arizona 85251 • Telephone (602) 994.9203 Doubletree Inn of Monterey • At Fisherman's Wharf • Monterey, California 93940 • Telephone (408) 649 -4511 Mr. Kjell Stoknes January 18, 1980 Page two In addition, we note that the proponent envisions building parking facilities for 6300 automobiles and that this figure exceeds the City of Tukwila's zoning code require- ment of 4400 for this proposal (DEIS pg. 23). In view of the proponent's desire to increase transit service and to make transit a more viable alternative for the proposal, Metro staff recommends that: . the planned parking facilities be sized to needs identified in a thorough demand analysis or the minimum requirements as specified in the City of Tukwila zoning ordinance. . incorporation of transit access and potential loading zones in the site plan for the proposal. . the proponent provide a one (1) month transit pass to employees and tenants. . the proponent provide bus information at central locations inthe shopping center and hotel. ` Mr. Larry Coffman of Metro's Marketing Division is avail- able to assist the proponent regarding transit informa- tion and passes and can be reached at 447 -6571. As the 208 Water Quality Planning Agency for the Cedar - Green River Basins, Metro staff reviews proposals for their potential impacts on areawide water quality. In this regard, we believe that the measures designed to protect water quality and minimize the effects of erosion and drainage problems appear adequate. However, the DEIS contains insufficient information for us to concur with the analysis that the water quality of the pond will be maintained at a level suitable for a wildlife habitat as specified in City of Tukwila's Resolution #656. Thank you for the opportunity to review and comment. Very truly yours, 4tAld Rodney G. Proctor, Manager Environmental Planning Division RGP:apj cc: Jerry Dow Larry Coffman I .rflE R® � Municipality of Metropolitan Seattle Exchange Bldg. • 821 Second Ave., Seattle, Washington 98104 January 18, 1980 Mr. Kjell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: Draft Environmental Impact Statement Tukwila City Center O.C.D. CITY CF TUn'IlLA JAN 2 1 1980 Metro staff has reviewed this proposal and would like to make the following comments. In regard to the statement, "The proposed development would be adequately served by these existing sewer lines and the Metro system is capable of handling the additional sewer volume generated by the project" (DEIS pg. 91), it should be noted that the proposed development falls within the Renton service area and will contribute to increased flows to the Renton plant. In order to assess the impacts of this proposal on Metro's wastewater treatment facilities, we recommend that the FEIS outline the expected wastewater flows that this proposal will ultimately generate. Metro is studying the Renton system with a grant from the Environmental Protection Agency and the Washington State Department of Ecology, in part because the Renton plant is currently at capacity and because continued development is occurring within the service area. The study will propose options for upgrading the Renton system so that water quality and public health will continue to be protected. In regard to the statement, "Metro transit should be encouraged to investigate the need and opportunity to focus additional regional service on the strength of the increased employment density which the proposed project will bring about" (DEIS pg. 84), Mr. Jerry Dow of Metro's Transit Development Staff is available to answer questions regarding future transit service and can be reached at 447 -6796. STATE OF WASHINGTON Dixy Lee Ray Governor DEPARTMENT OF ECOLOGY Mail Stop PV -11 206/753-2800 Olympia, Washington 98504 January 18, 1980 Kjell Stoknes Tukwila Office of Community Development 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: lAN 2 2 1980 Thank you for the opportunity to comment on the draft environmental impact statement for the Tukwila City Center development. Headquarters and regional personnel have reviewed the EIS and offer the following comments for your consideration. A flood control zone permit will be required for this project as identified in the draft EIS. The final EIS should include a discussion of the project's compliance with the requirements of the flood control zone act. The discussion of sewage disposal in the EIS should indicate how much sewage flow will be generated by the proposed development. Impacts of this additional sewage on the Metro Sewage Treatment Plant at Renton should be evaluated and addressed in the final EIS.. If you have any questions, please contact Nan Johnson or Mike Dawda of our Northwest Regional Office at 885 -1900. BJR:mgh cc: Sincerely, v � Barbara J. Ritchie Environmental Review Section Nan Johnson, DOE, Northwest Region Mike Dawda, DOE, Northwest Region SERVING: KING COUNTY 410 West Harrison St. P.O. Box 9863 Seattle, 98109 (206) 344-7330 KITSAP COUNTY Dial Operator for Toll Free Number Zenith 8385 Bainbridge Isla. d, 98110 Dial 344 -7330 PIERCE COUNTY 213 Hess Building Tacoma, 98402 12061 383-5851 SNOHOMISH COUNTY (2061 259 -0288 BOARD OF DIRECTORS MET MUM A,ON POO LLUITOOO a CON4G°30L M[ 1©7 Mr. Kjell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: 410 West Harrison Street, P.O. Box 9863 (206) 344 -7330 P FT,, r• Seattle, Washington 98109 O.C.U. CITY OF (lt,ri:ILA JAN 2 1 1 J January 18, 1980 Tukwila City Center The following comments are submitted in response to the Draft EIS for Tukwila City Center. Below level parking facilities: are discussed on page 21, We recommend that the section on. Air Impacts and Mitigating Measures be expanded to cover air quality aspects of the garage areas to insure that carbon monoxide levels would not. exceed State Occupar tional Health Standards required by WAC- 296 -62- 075 -15. Impacts and mitigating measures for suspended particulate from construction activity are discussed on pages 4 and 41. It is suggested that, to assist the action sponsor, he be advised that Section 9.15 of PSAPCA's Regulation I governs. A copy of Agency Guidelines pursuant to Section 9.15 is enclosed. On page 39 Linder Environmental Impacts, potential sources of air pollutants including space heating and solid waste incineration are noted. The action sponsor should advise his tenants that permit approval in accordance with Article 6 of PSAPCA Regulation I is required for fossil - fueled space heating sources exceeding one million BTU/hr rating and other air contaminant sources. Thank you for the opportunity to comment. Very truly yours, sj Enc. CHAIRMAN: Gene Lobe, Commissioner Kitsap County; James B. Haines, Commissioner Snohomish County; Harvey S. Poll, Member at Large, A. R. Darrankoehler Air Pollution Control Officer Glenn K. Jarstad, Mayor Bremerton; William E. Moore, Mayor Everett; Charles Royer, Mayor Seattle; John D. Spellman, King County Executive; VICE CHAIRMAN: Patrick J. Gallagher, Commissioner Pierce County; Mike Parker, Mayor Tacoma; A. R. Dammkoehler, Air Pollution Control Officer. `''Puget Soun.Air Pollution Co4Prol Agency SERVING: KING COUNTY 410 West Harrison St. Seattle, 98119 (206) 344 -7330 KITSAP COUNTY Dial Operator for Toll Free Number Zenith 8385 Bainbridge Island, Dial 344 -7330 PIERCE COUNTY 213 Hess Building Tacoma, 98402 (206) 383 -5851 SNOHOMISH COUNTY 506 Medical - Dental Bldg. Everett, 98201 1206) 259 -0288 410 West Harrison Street, Seattle, Washington 98119 (206) 344 -7330 GUIDELINES FOR CONTROL OF AIR POLLUTION FROM PARKING LOTS, ROADWAYS AND OPEN AREAS Air pollution from private roads, parking lots and open areas shall be controlled so as to meet the requirements of Reg- ulation I, including Sections 9.03, 9.04, 9.11 and 9.15. Pursuant to Section 9.15 of Regulation I the Control Officer has established the following control measures as reasonable requirements and precautions to prevent particulate matter from becoming airborne: ROADWAYS Private roads shall be controlled by paving, oiling or other surface treatment which prevents visible dust: emission and mud carryout. Good housekeeping measures shall be used to minimize the accumulation of mud or dust on the surface of roads. Unpaved shoulders shall be maintained in such a way as to minimize visible dust being generated by wind or traffic. PARKING LOTS Parking lots shall be controlled by paving, oiling or other surface treatment which prevents visible dust emission and mud carryout. Good housekeeping measures shall be used to minimize the accumulation of mud or dust on the surface of parking areas. OPEN AREAS Unpaved open areas shall be controlled by vegetation cover or other equally effective method of minimizing wind blown dust. CONSTRUCTION, REPAIR AND CLEANING Visible dust generated by construction, repair and cleaning of roads and parking areas shall be minimized by methods such as wetting and the use of chemical suppressants. In addition, at the end of each shift all public roadways shall be cleaned of mud and dust. LOG STORAGE AREAS Visible dust from roadways within log storage area shall be minimized by the use of water and /or chemical suppressants. In addition log storage areas shall be equipped with truck wash doian.facilities whereby trucks and /or log hauling- equip- ment can be cleaned prior to entry upon public access roads. Form 50 -164 ^4/74 BOARD OF DtR €CTORS CHAIRMAN) Gene Lobe, Commissioner Kiteap County; VICE CHAIRMAN: Gordon N. Johnston, Mayor Tacoma; N. Richerd / /Forsgren, Commissioner Snohomish County; Patrick J. Gallagher, Commissioner Pierce County; Harvey S. Poll, Member at Large; John D. Spellman, King County Executive: Wes Uhlman, Mayor Seattle; Robert C. Anderson, Mayor Everett; Glenn K. Jarstad, Mayor Bremerton; A. R. Dammkoehler, Air Pollution Control Officer. OF R4, .. o t$ n BARBARA Y. SHINPOCH, MAYOR • PLANNING DEPARTMENT o E: 235-2550 • • THE CITY OF RENTON MUNICIPAL BUILDING 200 MILL AVE. SO. RENTON, WASH. 98055 90 co' 0 �P 47' SEP'���� January 17, 1980 Mr. Kjell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Blvd. Tukwila, Washington 98188 CITY OF 11:',\ LA JAN 2 1 En RE: Tukwila City Center Draft Environmental Impact Statement Dear Mr. Stoknes: We have reviewed the above document and offer the following comments: 1. The project appears to create significant traffic impacts -- 20 to 40 percent or more increase in traffic volumes on local arterials -- especially along West Valley Highway, Strander Boulevard and the freeway access routes. Despite mitigating improvements, these impacts seem unavoidably adverse. The Draft EIS is unclear as to who would install proposed traffic improvements and when they should be completed. 2. A large portion of the retail growth predicted for the proposal . appears to occur at the expense of growth in other areas of King County, especially the Southeast Area. A more complete analysis of this impact seems appropriate, as well as consideration of potential indirect impacts such as higher energy use required by longer trips to reach the proposed site. 3. Will an 11 -acre pond environment, though potentially well designed, be adequate to maintain a viable habitat for anything but domestic ducks? What is the critical size habitat given the potential disturbances for various wildlife species which currently frequent the site? 4. Would the region be better served by a reduced project that would still retain a hotel - commercial- office mix with concealed parking, but with larger habitat area and proportionately lesser impacts? This alternative seems appropriate for consideration in the EIS review. ■•i • • Letter to Kjell Stoknes January 17, 1980 Page 2 Thank you for the opportunity to review the Draft EIS. If we can be of further assistance or if you have any questions, please contact this department. Very truly yours, Go d.n Y. Eric P.a ing D. David R. Clemens, Senior Planner GYE:DRC:sh CITY COUNCIL COMMENTS ON CHARTWELL SITE PLAN January 14, 1980 Bud: Approval process is OK. Problems: 1. Pond is covered with birds. EIS says it is not. 2. Pond totally reconstructed. 3. One -third of site in natural state. 4. Retain SE portion of site. 5. Encourage visual access from Strander and Andover Parkway to pond. 6. Retain southern one -third in natural state. 7. Dr. Erickson to be at meeting on preliminary approval. Mae Harris: Goofed in resolution 656: 1. To enjoy visibility have to stop - car potential hazard (traffic) 2. Review res. 656 to see if we agree (amend if necessary) Dan Saul: 1. Wants Dr. Erickson to answer questions. a. Will wildlife come back if drained and graded. b. Have someone write letter to EIS so Dr. Erickson will answer. Natural State: reconstructed or remain unaltered. Mayor Todd: P -17 was reconstructed and wildlife came back. Dan Aul agreed. Not a natural pond (Gary & Mae) Likes plan they have. Dan SEPA - when do we publish 60 day period to appeal on basis of EIS Larry: 1. Get written comments to city to get expert responses to certain questions. STATE OF WASHINGTON Dixy Lee Ray Governor January 14, 1980 DEPARTMENT OF FISHERIES 115 General Administration Building, Olympia, Washington 98504 206/753 -6600 City of Tukwila Planning Division Office of Community Development 6200 South Center Boulevard Tukwila, Washington 98188 Attention Kjell Stoknes, Director of Planning Gentlemen: fir, 4 O.C.D. CITY OF TU!{; A JANN 1 6 1980 Draft Environmental Impact Statement Tukwila City Center King County WRIA B -09 The proposed project will have little or no impact on the salmon resources of the Green River provided stormwater is controlled as indicated. Thank you for the opportunity to comment. If you have any questions please contact our Natural Production Division at 753 -6650. Sincerely, GGord, San &son Director mr cc: Game • JCPenney Real Estate Department Post Office Box 4015 Buena Park, California 90624 (714) 523 -6366 February 6, 1980 O.C.D. CITY OF ruYl'1►lA FEB 8 19rlp Mr. Mark Caughey Assistant Planner Office of Community Development City of Tukwila 6200 South Center Blvd. Tukwila, Washington 98188 • Re: Proposed Chartwell Development,, "Tukwila City Center" Tukwila, Washington Dear Mr. Caughey: This letter concerns the proposed Chartwell Development, "Tukwila City Center" and is supplementary to the letter sent to Mr. Stoknes dated January 21, 1980, by Mr. W. R. Lewis, District Manager, of the Penney Company. As Mr. Lewis indicated, Penney is concerned about several aspects of the DEIS for the Chartwell Development; we are par- ticularly concerned with the vehicular traffic that will be generated by the proposed development and its impact on the existing traffic circulation system, and with the in- sufficient amount of parking that is to be provided by the proposed development. With regard to the traffic portion of the DEIS, the report minimizes the amount of traffic that will . be generated by the proposed development and the impact that this traffic will have on the existing street system. While the report notes that four of the intersections in the vicinity of the proposed development currently are over capacity, it does not adequately deal with the impact of the traffic generated by the proposed development on these intersections as well as many others in the vicinity of the development. It also makes no provision for or recommendation respecting the im- plementation of the improvements recommended in the DEIS. An analysis of the traffic portion of the DEIS was done by Transportation Planning and Engineers, Inc. dated January 17, 1980, a copy.of which is attached. This analysis supports J. C. Penney Company. Inc.. 6131 Orangethorpe Ave.. at Valley View. Buena Park, California 90624 • • Mr. Mark Caughey February 6, 1980 Office of Community Development Page 2 City of Tukwila Tukwila, Washington Re: Proposed Chartwell Development, "Tukwila City Center" Tukwila, Washington Penney's concerns with regards to the trip generation estimates that were utilized in the DEIS, the impact of the trips that will be generated on the surrounding street.sys- tems, and how the proposed transportation improvements will be funded if the proposed development is permitted. With regard to the amount of parking that is to be provided for the proposed development, Penney's concern' is that if adequate parking is not provided, customers and employees utilizing the proposed development will park in the existing Southcenter Shopping Center parking areas. Obviously, this would have a negative impact on Southcenter Shopping Center as. there would be less parking available for customers of the shopping center. Since the amount of parking to be provided is a function of the existing City zoning ordinances, con- sideration of the zoning of the proposed development site and the uses permitted thereon is needed. The site is currently zoned C -M (Industrial Park) which would allow uses permitted in the C -1 and C -2 zoning uses. It is our understanding that the zoning code permits neighborhood retail businesses in the C -1 zoned areas and local retail businesses in the C -2 zoned areas. It is difficult to believe that a regional retail shopping center development of 800,000 square feet consisting of a two level mall and three major department stores can be considered either as a neighborhood retail use or a local re- tail use. If this project is considered under the more appro- priate existing zoning category of C -PR (Regional Shopping Center), the amount of parking required would be increased from 2.5 cars /1,000 sq. ft. of gross floor area to 5.5 cars/ 1,000 sq. ft. of gross floor area. Further, it should be.noted that the proposed new zoning code for the City of Tukwila eliminates the C -M zoning category and designates the proposed site as C -P (Planned Business Centers) which includes shopping centers and shopping malls. The pro- posed zoning would require 5.5 cars /1,000 sq. ft. of gross Mr. Mark Caughey February 6, 1980 Office of Community Development Page 3 City of Tukwila Tukwila, Washington Re: Proposed Chartwel'l Development, "Tukwila City Center" Tukwila, Washington floor area for this use. Based on Penney's expertise as a department store located in hundreds of regional shopping centers throughout the country, it is our judgment that the parking requirement of 5.5 cars /per 1,000 sq. :Et. of gross floor area under the existing zoning code category of C -PR and under the proposed zoning code category, C-P would be sufficient to provide adequate parking for a shopping center. However, the developer's proposal to provide a minimum of 2..5 cars /1,000 sq. ft. of gross floor . area of retail use under the existing zoning code category C -M is completely inadequate. As a member of the Tukwila business community, Penney appreciates the opportunity to comment on the DEIS for a project with the impact that the proposed Tukwila City Center development will have on the surrounding area. Very truly yours, Thomas W. Rowe TWR :bhm cc. Mr. W. R. Lewis Mr. Michael Lowenkron Mr. John V. Faltermeier • I City of Tukwila Edgar D. Bauch Mayor Fire Department Hubert H. Crawl ey Fire Chief • To: Kjell Stoknes, Director 0.C.D. From: Hubert H. Crawley, Fire Chi e Re: Comments on the I.E.S. for the "luu wila City Center" Project. ►4,:L Date:danuary 3, 1960 Public Services Fire Protection !JAN 3 19 Existina Conditions: It is extremely difficult to indicate whether there is adequate water for this size of problem, until drawings are submitted indicating the size and nature of construction of the buildings, We have not given any indication of the adequacy of the water supply for this project. Environmental Impact: In deference to the statements regarding the manpower requirements for this project, at least nine (9) and with the contract obligation, twelve (12) nen should be added to man th.e department equipment. As of this date no person in the fire department ever indicated the number of personnel that would be needed to protect the complex. Projected impact on the Fire Department is an additional 20 -25% increase or number of incidents. The project as presented will represent an extremely more City of Tukwila Fire Department, 444 Andover Park East, Tukwila, Washington 98188 (206) 575 -4404 P. 2 complex problem to an emergency situation. The number of multi -story buildings, large open spaces, limited access, underground parking, and large number of people will mandate an increase in manpower in excess of the number presented in the E.I.S. This tyre of dense develop- ment will cause greater damage from fire and smoke over the conventional type of shopping center. The people that will be on site will far exceed anything the City presently has to prgtect, thereby adding new dimensions to the protection_ of life, At the present time the fire depart - ment operates two stations with an average of 6.8 people on duty, It is not unusual to find only six and at times, five people on duty at the two stations. With the increase in calls for the surrounding communities, the dependability on their responses lowers each year. At the present ti;-rne, th.e fire department keeps at least 1,5 people husy' Going th.e fire inspections on the South- Center Complex, This' project is larger with considerable more life 1Qss potential, The Fire Prevention Bureau will need at least one more full time fire inspector and at least one full time inspector during the construction period, The above information reflects an increase, starting with construction, of at least ten men and with contract obligations, thirteen. This will give the City an impact of at least $292,500 in salary alone. Pg. 3 At the present time the department cannot operate, nor does it have any device for people to evacuate upper floors by jumping. Initial impact to equipment would be a one -time cost of approximately $50,000. Mitigating Measures: Under the responsibilities of the Fire Chief of the City of Tukwil a, as outlined in Section 1.201 of the Uniform Fire Code, the development of this magnitude will require that we require rather than recommend the safety precautions to be taken for this development, before we will approve any set of drawings for issuance of building permit. Should the City be unable to increase the manpower and equipment needed for this development, it is my recommend- ation that the project not be built as proposed, since the most dangerous time for any new building is early in the construction stage and personnel should be on board at that time. The. Fire Departnjent is totally inadequate to handle not only the spread of fire and smoke, but the panic that would almost certainly be caused by a major incident. Since the plans as presented, represent only a theory of low' the development will go, the department can only address a very few items at this time. This is the second proposed set of plans for development and until we get firmer information on what the development will be, we cannot answer the E.I.S. fully. 16052 - 46th. Avenue South Seattle, WA 98188 January 21, 1980 Mr. Kjell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: Please find attached specific comments regarding the proposed Chartwell Development Draft Environmental Impact Statement. The comments include discussions of traffic flow, air quality, pond /wild life protection and secondary impacts. Due to the magnitude of the proposed project there is a need to coordinate the implementation of mitigating measures with approval of the various phases of the proposed project. This is particularly significant for issues involving the pond and transportation. The discussion of alternatives for the site should receive considerable more cover- age than offered in the draft EIS. The proposed project will have significant impact on the quality of life of both residents and the daytime working population of the Tukwila area. Considerable effort should be exerted to increase awareness of the project and to encourage public involvement in the review process. Such involvement could significantly reduce later delay from potential litigation. I appreciate the opportunity to comment on this proposed project and look forward to working with the city in the review process. Attachment Yours truly, .r 16052 pt1' t�,� Ronn Griffin • • Ronan. 1(21/80 Traffic /Air Quality The most significant off -site direct impact would be traffic congestion and related air quality impacts. The draft EIS suggests that to a large degree these impacts will be mitigated, by future improvements that are not yet implemented, in traffic flow, vehicular emissions and mass transit service. No concrete proposal is offered to ensure that these mitigating factors will be implemented; nor does the project proponent state the cost of these systems or how they are to be financed. The baseline traffic study was conducted in August 1979. It does not appear that recent development of property in the immediate area and the resulting increases in traffic were incorporated in the analysis. As a result the quality of the existing traffic flow may be overstated. The air quality analysis does not appear to consider the important impacts of idling time on air quality. It is recommended that: o The traffic study be updated to incorporate current and near term traffic increases. o That the air quality analysis be revised to include idling time and anticipated congestion resulting from the project. • That the project permits be conditional to the suggested traffic flow improvements. o A cost /benefit analysis to the local community be prepared on the traffic issue. Ronn Griffin 21/80 THE POND The Tukwila pond represents one of the few remaining wet bird habitants in an area which previously contained extensive tracts of similar habitat. As such it must be considered an area of high biological significance and accorded reasonable protection. It must be clearly understood that the present pond is utilized extensively by wild bird populations. The draft Environmental Impact Statement (EIS) does not adequately determine the species and number of individual birds using the pond at various times of the year. Without such data it is difficult to quantify the impact of the development on the natural system. The draft EIS at present offers only a vague qualitative assessment of suspected impacts. Particular attention should be given to eliminating public access to the pond. The present proposal suggests that the public will be free to interact with the bird population. Such interaction would materially change the pored use from utilization by wild migrating birds to use by domesticated stock. The following items should be considered: A systematic baseline study of current pond use. A quantified analysis of various project alternatives on the pond habitat and bird populations. Involvement of the Audubon Society and /or the State Fish and Wildlife agencies in the planning process. Protection of the pond should proceed development. Use of vegative buffers on the southern and western property borders. Elimination of direct public access to the pond. Impact of high buildings on the bird populations. Ronn Gin 1/21/80 Engineering Feasibility The proposal represents ambitious engineering objectives in the areas of building support and hydraulics. The draft EIS discussion on settling and displacement and impacts to neighboring properties was quite general. Of particular interest is the disposal of water pumped from underground structures during periods of high water. It appears that on -site holding capacity at such times would be quite limited and river discharge prohibited. It is recommended that: o Detailed information be provided regarding anticipated settling and displacement. • The pumping and removal of excess water be investigated in detail. • City engineers review or hire consultants to review the impacts of the development on neighboring properties. Ron Secondary Development iffin 1/21/80 The draft EIS states that the development will have no significant adverse impact on housing or population and will increase direct employment in the area by 4,500 (about 30%). It seems incongruous to state that no significant impact in local housing and employment are anticipated. It should also be noted that secondary employment impacts are not considered. It is recommended that: o A quantified analysis of employment, housing, population and related impacts on the local area be undertaken. o The above analysis should include cost /benefit studies relevant to the local population. ROGER L. SHIDLER GEORGE W. MCBROOM WILLIAM H. GATES WILLIAM F. BALDWIN JAMES R. IRWIN JAMES C. MIDDLEBROOKS RICHARD B. DODD FREDERICK ROSS BOUNDY WILLIAM H. NEUKOM JAMES L. FLETCHER DAVID T. McDONALD PATRICIA J. PARKS DALE K. ROUNDY GARY D. HUFF WILLIAM A. BUTLER DAVID H. BINNEY ROBERT A. ESHELMAN CONSTANCE L. PROCTOR SHIDLER, McBROOM, GATES & BALDWIN A PROFESSIONAL SERVICE CORPORATION LAW OFFICES 1000 NORTON BUILDING SEATTLE, WASHINGTON 98104 Mr. Kjell Stoknes Director of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 January 21, 1980 (206) 223 -4666 RE: Draft Environmental Impact Statement ("DEIS ") Tukwila City Center ( "TCC ") Southcenter Shopping Center ( "Southcenter ") Response Gentlemen: With this I respond to the DEIS for the Tukwila City Center ( "TCC ") dated December 17, 1979. I write as attorney for Southcenter, operator of the 87 acre regional center immediately north of the TCC Project proposed by Chartwell Development Corporation ( "Developer "). I write as well for Southcenter's indirect parent, Allied Stores Corporation ( "Allied "), d /b /a The Bon Marche. Through corporate sisters of Southcenter, Allied operates 7 regional shopping centers nationwide, including Northgate, Tacoma Mall and Columbia Center in the State of Washington. It also operates over 170 major department stores, many in shopping centers. Approximately 30 of these are located in the Pacific Northwest under Seattle management. I. Introductory Observations By long representation of Allied and its subsidiary corporations the writer cannot be said to be unfamiliar with the requirements of Washington State Environmental Policy Act ( "SEPA "), similar state environmental laws, local (city and county) implementing ordinances and procedures for compliance with these laws. It goes without saying that SEPA requires an EIS to be a "full disclosure" document and requires the lead agency, here the City of Tukwila ( "City "), to consider the proposed Mr. Kjell Stoknes Page two action ( "TCC" or "Project "), the environmental impacts of the proposed action, impact mitigation, alternatives, if any, etc. The law requires the Developer to supply the City with data essential to environmentally sensitive consideration of the Developer's proposal. If the City decides the data base is in any extent insufficient it may require more data from the Developer. It can be assumed that the Developer will and, in practice almost invaribly does, present the Project in its best possible environmental light. The extent of the Devel- oper's data supply depends upon many factors including (a) the environmental or public sensitivity of the Project, (b) his monetary resources and willingness to spend the often times enormous sums required for studies, (c) time constraints, (d) the extent to which, at the "threshold" point in time, he can identify the configuration of the development which will actually be constructed and many other factors which do not in any way impugn the Developer's integrity, though may or may not constitute comments upon the Developer's financial capability and sophistication. The degree of the City's review depends somewhat upon the same characteristics, none of which bear any relation to the staff's devotion to their task of insuring that government be responsible for gauging and mitigating or preventing environmental deterioration. These factors include, for example: (a) staff availability for environmental review and (b) the priorities which the City Council places upon such review. Finally the DEIS is issued, presumably after months of study by the City and Developer and their experts concerning feasability, construction, design, marketing, traffic, economics, air and water pollution etc. This DEIS was "issued" on December 17, 1979. The respondents (my clients) are by law required to answer within 30 days, extended here to January 21, 1980. Adequate response within that short period is difficult if not impossible but the best is done: II. CONCLUSIONS With apologies for errors or omissions resulting from the 30 day time frame, I conclude, in respect to the TCC DEIS that: Mr. Kjell Stoknes Page three 1. The Project Is Not Economically Feasible for the Developer: The TCC, as proposed, is not economically feasible (to say nothing of environmental soundness) for the Developer. Example: at DEIS p 13 and p 21, Developer proposes a total of 6300 parking stalls and states at p 23 that only 4,400 are required (2.5 stalls per 1,000 sf retail per the present C -M zoning of the site). Developer knows, or if sophisticated should know, that no 800,000 sf shopping center is feasible without 2 or more "anchor" (major department store) tenants and that no anchor would lease or buy unless an industry minimum of 5 to 5.5 stalls per 1,000 sf retail were provided. If Developer were to meet the City's C -PR (regional plan business center) requirements of 5.5 stalls per 1,000 sf rather than escape under C -M (industrial park) parking requirements of 2.5 stalls per 1,000 sf retail, Developer would be required to provide 2,400 stalls in excess of what Developer says is required (DEIS p 23). Even allowing that part of the overage on 1900 stalls suggested at DEIS p 23 is realistic, Developer would still be 500 stalls short of industry requirements. Even if parking configurations shown at figure 4, DEIS p 17 were realistic (which they are not) my client's experience shows a Developer stall shortage of 960 spaces. On this basis Developer's Project is economically not feasible. As Developer knows, or should know, no major department store would become an essential "anchor" in Developer's proposed regional shopping center. 2. SEPA Requires Identification of all Governmental Approvals for Project Developement: (We observe, parenthetically, that the DEIS does not specifically identify the City approval which "triggers" or is the "threshold approval" necessitating this DEIS. I learned only from the Responsible Official and Contact Person, Mr. Stoknes, that the trigger was the Developer's request for a conditional use permit allowing hotel construc- tion in C -M zoning.) The Proposal, as we will later demonstrate in an attached momorandum, requires a rezoning of Developer's property from Mr. Kjell Stoknes Page four C -M to C -PR or, as suggested in the proposed new zoning code, to C -P. Both C -P and C -PR require 5.5 stalls per 1,000 sf retail. 3. At a Minimum, SEPA Requires that a Developer Fully Disclose All Facts which the Developer Knows or Ought to Know Touching upon a Project and its Environmental Impacts: Developer has not done so. Example: setbacks required by the Uniform Building Code ( "UBC ") shown by Developer's design at "Site Plan," Figure 3, DEIS p 16 cannot be met if Developer's traffic consultant's recommendation (Figure 15, DEIS p 78) for Strander Boulevard widening (20') is adopted. Example: Developer's proposal to underground about 5,600 of the total 6,300 parking stalls per design, Figure 4, DEIS p 17, does not account for 10 -story building cores and support columns for 2,000,000 sf of overlying building, elevators, escalators, lower -level utility system housings essential to support 2,000,000 sf of buildings above and the possible requirement for truck deliveries to approximately 110,000 sf of shop areas immediately adjacent the Pond. 4. Soils Data is Not Supplied: SEPA and the City's implementing environmental ordinance ( #986, 8/16/1976) require the Developer to supply realistic descriptions of the proposed Project, its environmental impacts, mitigations, alternatives, and data to support these. Soils data is not supplied. "Elevations and Sections" at Figure 5, DEIS p 18, tells us that underground parking will be approximately at elevation 10.5' or at approximate ranges of 5' to 4.5' below the existing water table. Figure 4, DEIS p 17 shows excavations within 25 to 30' of widened Strander Boulevard, after deducting 20' for Strander Boulevard widening. These excavations are within 40' of the Olympic Pipeline Company 12 3/4" OD jet fuel line to Sea -Tac Airport (City Franchise 496, 10/2/1967), a 4" pressure natural gas line which, Developer says, will service the massive complex (DEIS p 91) and within the same or lesser proximity to the City's 12" sanitary sewer line (DEIS p 91). "Geology and Soils" at DEIS pps 31 -34 tells us that the Project overlies 150' depths of silt, sandy silt, sand and peat and may result, as at Southcenter,, in 3 1/2' • • Mr. Kjell Stoknes Page five of settlement. In addition 220,000 cubic yards must be excavated to accommodate 2 stories of underground parking. Despite this, no data of a responsible soils engineer has been supplied. No attempt has been made to design a widened Strander Boulevard and construction of the underground parking to insure against the hazards of ruptures in the jet fuel, pressurized gas, and sanitary sewer lines. Such a study is particularly necessary since these utilities are located adjacent to and subject to seepage to an underground, high fire risk parking garage sitting below 8 and 10 story motel and office structures and 4 story department stores. 5. Wildlife Biologist Data Is Not Supplied: The same SEPA and City environmental requirements for full disclosure apply here as to soils in the preceeding paragraph. The obvious purpose of City Resolution 656 (10/16/1978) was to preserve the Pond as a human amenity and as a bird refuge. Developer bought his property March 1, 1979, full - knowing the City's 656 constraints and those of Ordinance 1035 (12/18/1978). Developer knew, by the terms of these, that the City had, in effect rendered 1/3 the 38.9 acs a "nature conservancy" area and that the developable land approximated 26.9 ac. Developer tells us that he has employed a wildlife biologist to make a wildlife study to determine how the 656 and 1035 requirements might be met. But where, by appendix, does Developer attach the biologist's study for review by the City, its Council, and by others? Where does Developer even identify the wildlife biologist among his consultants at DEIS p i? My clients are more interested in Developer's compliance with City laws and policies than with wildlife except as the Pond's preservation ripple- affects impacts of the Project upon Southcenter. Nevertheless I observe that the lengthy discussion of "wildlife" and DEIS pps 46 -52 emphasizes the "lick and promise" character of this DEIS: a "lick" at the environment and a "promise" to mitigate without divulging realistic data as to "how" that promise is to be kept. • • Mr. Kjell Stoknes Page six 6. Storm Sewer Study and Data: These same SEPA and City requirements for full disclosure rendering a DEIS or FEIS legally supportable apply here as with wildlife and soils studies mentioned above. At DEIS p 92 Developer recognizes by "lick" that the existing storm sewer system is incapable of draining the "cordon area" and the drainage basin into the Green River at the Green's peak water levels. At page 93 DEIS, Developer tells us that the Pond and adjacent arterial (Andover Park West) frequently store up to 140 ac feet of flood waters backed up from the existing system. Yet Developer proposes a Project which would interdict this back -up and handle only, but inadequately, on -site surface and storm waters pouring from impervious surfaces of 14.2 acs of buildings and 6.0 acs of parking or 879,912 sf of impervious on -site surfaces (DEIS p 20). "Promises" and mitigation are suggested at DEIS p 94, but the fact is that no responsible civil engineer has appended data necessary: (a) to gauge present inflow - outflow capacities or (b) to design mitigations such as are suggested at DEIS p 94, (additional storage in the existing 108" drain pipe system, trapping and diverting higher -basin run -off, or increasing the design capacity of "P 17," a City retention and pumping station.) [Example: is it realistic to mitigate identified impacts to increase P -17 pumping capacity (DEIS p 95) when the Green River's water level or the Army Corp of Engineers may prohibit drainage of the increased pumping capacity into the Green ?] Most importantly, the expert's data should analyze the cost to the City of the Developer's mitigation "promises." (One remembers that the capital costs of the P -17 system to taxpayers were in excess of $540,000. The operating costs are not known. Data should demonstrate economic costs and irretrievable commitments of resources of the City. The one page "lick," at DEIS p 109 relative irreversible or irretriev- able commitments does not mention these. Where is the data? 7. Traffic and Circulation Data: Although Developer employed responsible and respected traffic consultants, inadequate data appears. I am not a Mr. Kjell Stoknes Page seven traffic expert. The data and their insufficiencies are dealt with in a response from an equally responsible and respected traffic engineer in a letter attached. As a generalist, however, I make the following presumptuous but perhaps common -sense observations: DEIS p 117 lists as an "unavoidable adverse impact," 20 -40% increases on local ( "cordon area ") arterials. I assume that by the "cordon area" Developer and its traffic consultant mean the "island ": south and east shores the Green River, west shore I -5, north shore I -405. At Figure 14, DEIS p 77, Developer suggests signalization as a mitigating measure. Three of the signals exist. Nine do not. Four of the proposed signals require pedestrian wait -times (DEIS p 81) and may create more traffic congestion and air - polluting "idle" time than they cure. A partial solution may be computerized signals. What is the municipal cost of signali- zation? What is the cost of computerization? At the same Figure 14, DEIS p 77 and following, Developer suggests the widening of arterials within the "cordon area." What will be the cost to the City? Example: it is proposed to 4 -lane Minkler Boulevard from Andover Park West to Southcenter Parkway. What is the cost and particularly how does this alleviate congestion? The DEIS does not consider that railway lines presently run down most of Minkler west to the Parkway. DEIS speaks naught of this, the practicality of railway relocation, the capacity of Minkler to alleviate if the railway remains, or any expense to the City. Has the DEIS overlooked the requirements of the City's Transportation Improvement Plan ( "TIP "), 10/19/1979, in respect to the Project? At p 77 the Study says: "The proposed Chartwell development . . . would have a profound traffic and environmental impact on the C I D of a magnitude approaching that of South - center Shopping Center." At p 78 the same Study says: "Certain mitigating traffic measures should be taken prior to approval (italics added) and construction of the Chartwell development to lessen this overloading • • Mr. Kjell Stoknes Page eight effect of site traffic on circulation in the Southcenter area. . . . The Chartwell development plans should include new access roads along the west and south property boundaries (italics added) the latter linking Southcenter Parkway to Andover Park West . . . to improve circulation to and from the site." Developer's DEIS mentions this naught. What would be the municipal costs of acquiring right -of -way and developing arterials west and south of Chartwell? 8. Parking: Whether measured by "C -M" parking ratio requirements or by industry standards data supplied indicates that parking is inadequate. The figures are as follows: Use Industry /Zoning Requirement Stall No. Retail 800,000 sf at 5.5/M 4400 Hotel 775 rooms at 1 /room 775 Banquet & Dining 1125 225 seats at 1 stall /5 seats Office 600,000 sf & 3.1/M 1860 Spaces required 7260 Spaces provided 6300 Short 960 Developer proposes, as mentioned in paragraph 3 above, provision for 6300 parking stalls, 5600 of which are to be underground per Figure 4. At paragraph 3 above we point out the inadequacy of Figure 4 which must exclude from parking - layout the building core and support requirements, elevators, escalators, utility systems and possible truck docks and delivery routes. We conclude that the Developer may be in excess of 2000 stalls short of industry or code requirements. What are the costs of short -fall? What are the costs in terms of Architectural Control Review acceptance? What are the costs to Southcenter if patrons of TCC utilize • 1 Mr. Kjell Stoknes Page nine Southcenter's surface parking either by reason of short -fall in TCC's parking or by reason of the time - delays, inconvenient access and an underground 90° parking layout? What are the costs to the City when TCC users park at Southcenter and become pedestrians across Strander Boulevard? Typically, this DEIS fails realistically to deal with these problems although they are inherent in the Proposal. At present configurations, neither Allied nor Southcenter is concerned about competition from TCC. TCC, at present configurations is economically infeasible and will never exist. Allied and Southcenter are concerned, however, about the Developer's unrealistic response to announced policies of the City and to the requirements of law which render the DEIS a less than legally supportable document. Allied and Southcenter are indeed concerned about competition by TCC's overloading of already overloaded arterials and escape from these arterials over bridges across the moats which surround the cordon area island. Allied and Southcenter are concerned about overloading sanitary and storm sewers which are already either at capacity or are incapable of handling existing loads. Allied and Southcenter, as major taxpayers, are concerned, of the failure of the DEIS even to mention the economics of City- support facilities, necessary to accommodate the Developer's Proposal. We have raised above the major deficienies of the DEIS. An analysis of important but less traumatic consequences of the Developer's Proposal are set out in a generalized memo- randum attached. An expert's analysis of the traffic and circulation defects is set out in a second memorandum. III. RECOMMENDATIONS 1. That no further action be taken to process Developer's DEIS and that no City approvals in respect to Developer's property be granted until the following conditions are met: 1.1 Developer produces additional data relative to the proposed Project and additional data relative to the environmental impacts and mitigations. 1.2 Satisfactory sanitary and storm sewer systems are developed necessary to accommodate Developer's Project. 1 Mr. Kjell Stoknes Page ten 1.3 Funds are available for necessary arterial widening, development of arterials west and south of Developer's Project and for acceptable ingress and egress from the Tukwila CID (the "cordon area ") to and from connecting freeway systems. 2. The Developer must demonstrate his willingness and capacity to observe the guidelines and goals set forth in City Resolution 656 and City Ordinance 1035. 3. The City withdraw its preliminary waiver passed at a City Council meeting of January 15, 1979, on the clear basis that Developer continues to refuse to meet Criteria #3 of Resolution 656 which requires proposed buildings at the southeast corner of the Project to be moved to the southwest corner of the Project. In this regard see page 4 of Tukwila City Council regular meeting minutes of January 15, 1979. Sincerely yours, SHI ER, McBROOM, GATES & BALDWIN Mo m`' George M1/24 GWM:np 4 • MEMORANDUM SUPPLEMENT RESPONSE OF SOUTHCENTER TO TUKWILA CITY CENTER DEIS 1 Economic Feasibility: In paragraph 1 of our letter we have concluded that the proposed TCC is not economically feasible primarily because parking is short of industry requirements and those of major retail department stores ( "anchor tenants "). 1.1 "Anchor Tenants" Require 5.5 Stalls per 1,000 sf Retail: For example, by the Frederick & Nelson lease at South - center, Southcenter agreed: . . . that there shall prevail at all times with respect to all parking areas (Phases I & II) a ratio of not less than five and one -half (5 -1/2) parking spaces for each one thousand (1,000) square feet of gross floor area of buildings in the shopping center." In the event Southcenter fails so to do, Frederick & Nelson may terminate the lease. The same lease further provides that such parking shall: "be available for use, without charge, by Tenant, customers and patrons of Tenant and by other tenants and occupants (and their customers and patrons) of the land constituting the Shopping Center . " By way of further example, on September 13, 1979, Tacoma Mall executed a lease with Sears Roebuck & Co. for development of a new major facility. Parking ratios of 5 stalls per 1,000 sf retail were required. As a result, Tacoma Mall had to acquire and /or rezone approximately 14.5 additional acres of land for the center. 1.2 Phased Development and Additional Costs: At DEIS p 19 Developer tells us that he intends to initiate construction in 1980 and to construct the complex in two stages over a five year period. Occupancy of the final buildings is scheduled for 1985. Redevelopment of the Pond is to occur during the last half (1983 -85) of develop- ment. The Developer does not detail staging but some surmises can be reached by virtue of Table I (DEIS p 20). Here Stage I and II phases are described in terms of square footage. Taking these square footages we have outlined the likely Phase I Development in red on Figure 3 attached (DEIS p 16) and on the Lower Level Parking Plan (Figure 4, DEIS p 17). (Exhibits "A" and "B" attached.) The costs inherent in "phasing" the underground parking which supports all higher elevation construction should be plain. Phase I underground parking would have to be provided along common building lines with Phase II parking, with bearing walls necessary to support structures above. For two years these walls would have to be waterproofed to prevent pollutant seepage into the Pond. At the time Phase II parking commenced, presumably openings would have to be created through these Phase I bearing walls to permit a pass through of vehicles to Phase II parking areas. The additional expense is enormous. 1.3 Underground Parking: Excluding land values, current improvement costs for surface parking areas such as Southcenter's are approximately $1,600 per stall. Per stall construction costs for multi- level parking above ground range from $4,500 to $5,000 per stall. The proposed underground parking would likely cost, including excavation costs, waterproofing, and the "de- watering" pumping systems proposed, a minimum of $5,000 per stall. Developer proposes a total of 6,300 stalls, all of which must be regarded as multi -level since the "surface parking" will lie atop underground parking. The excess cost of $3,400 for 6,300 stalls is $21,420,000. Southcenter contends this is not economically feasible. Additionally, Developer does not say how he will finance an additional $21,420,000 for parking. In fact, nowhere in the DEIS does Developer tell us whether Developer himself will own and construct the hotel, shopping and office building facilities or whether Developer will sell the land for one or more of these improvements to third parties. Nor does Developer discuss his own capacity to finance the huge project proposed. How are the additional underground parking costs to be financed? Developer does not say. Are parking fees to be charged? Developer does not tell us. If charges are to be made will this not invite TCC employees and visitors to park on Southcenter's adjacent lots? that: 1.4 Pond Maintenance as a Wildlife Habitat: City Resolution 656 at Guideline 2 f, DEIS p 28, states "Monitoring of water quality should be done on a continual basis. Measures must be taken to prevent eutrophication. The pond must be maintained." At DEIS p 52 Developer remarks, in respect to Pond quality preservation that: "The success of the proposed habitat preservation and modification is dependant upon diligent design, careful construction practices, maintenance and permanent protection from further encroachment of human activity." At the same page, Developer states that it will be necessary to: "8. Control . . . the water level to replicate natural seasonal fluctuations." At Guideline 1, City Resolution 656, the City requires: "Surface runoff from paved areas on the site should not be channeled into the pond unless approved water filter devices and other measures are implemented in order to maintain suitable water quality for wildlife." Developer suggests that he will control vehicle - related pollutants from seeping from the underground garage (elevation 10' - 10.5') into the Pond (elevation 15.1) by waterproofing and pumping or "dewatering" the garage. I am informed by our engineers that the "state -of- the -art" of cleansing parking area water pollutants to match water wildlife preser- vation has not yet been developed. That is a recognized engineering fact. Is it possible, as Developer responds to this pollution problem at p 27, to say that "detailed drainage system designs are not completed . . . final drainage system designs will be carefully developed to control silt, oils, nutrients, and toxicants to the degree necessary to maintain the long- term viability of the pond as a wildlife habitat. ?" Question: What will preservation of the Pond as a wildlife habitat cost the Developer and how does he intend to raise the money to pay these costs? Of this the Developer says nothing. 3 • 2. Rezoning from C -M to C -PR (or Development to PUD Concepts) is Essential: 2.1 Intensity of Developer's Proposed Land Use: At DEIS p 60 the Developer tells us that the building to land ratio will be 1.2 sf to 1. Developer here includes the entire 38.9 acs and forgets that 1/3 of this acreage has been reserved as a type of "nature conservancy" by Guideline 6, City Resolution 656 (DEIS p 28), reducing available land use to 27.9 acres. On this basis the ratio of building to land becomes 1.63 sf building to 1 sf land. Developer, however, fails to include in building area two stories of underground parking, each of approximately .25.5 acs or 51 acs total. On this basis the ratios become C3'42.82 sf of building per 1 sf of land. Even assuming Developer's 1.2 building to 1 land ratio, Developer says at DEIS p 60: "The proposed floor -area ratio of approximately 1.2 square feet of building for each square foot of land would represent a more intensive land use utilization than now exists on any parcel this size in the region outside of a few major downtown areas." With this we surely concur. We assert that a 2.82 building - to -land ratio would be difficult to find on any 27.9 ac tract in Downtown Seattle. 2.2 C -M Classification Under the City Zoning Ordinance Never Intended to Permit Such Intense Use: Regional shopping center use of 800,000 sf with 2 or 3 major department stores was intended only under the C -PR classification. It is no doubt true that the C -M use provi- sions at Code 18.32.010 permit C -1 (Neighborhood. Retail Business) and C -2 (Local Retail Business) uses. We concede that the types of retail business which may be carried in a C -1 or C -2 zone cover most activities proposed by the Developer except the hotel for which a conditional use permit is required. City planning officials and the Developer well know, however, that such intensive use was never intended to be permitted in a C -M zone. If the drafters of the Code had intended C -PR (Regional Shopping Center) uses in a C -M zone the code would have included C -PR uses as permitted uses in C -M and would not have restricted the character of retail business to the C -1 and C -2 neighborhood and local categories. If such had been the intent, the C -M parking 4 • ratios at Code 18.56.170 would not be at the 400 sf building per stall ratio (2.5 stalls per 1,000 sf building) but would have been as required under C -PR: 5.5 stalls per 1,000 sf building. 2.3 Consistency with Comprehensive Plan and Land Use Map: Developer purports compliance with the City "s Comprehen- sive Land Use Plan and Map and implementing City Ordinance #1035 at DEIS pps 24 -26. I discuss my views that the Project proposed is not consistent with the Comprehensive Land Use Plan ( "CLUP ") under discussions of particular subject matter below but I list the divergences here. The Project is inconsistent because it does not comply with the following goals: 2.3.1 Natural Environment: "Strive to retain viable areas of . . . wetlands . . . for wildlife." (See 5.2.1) 2.3.2 Unnatural Environment: "Encourage the preservation of marshes and ponds for the retention of storm water runoff." (See 6.1 below.) 2.3.3 Open Space: "Encourage the preservation of marshes, ponds and water courses for open space purposes and include them in the open space system." 2.3.4 Commerce /Industry: "Promote adequate provisions for parking for all land uses." (See 8.1 below.) 2.3.5 Commerce /Industry: "Commercial uses should be located functionally convenient to major traffic ways." (See 7.1.1 below.) 2.3.6 Transportation /Utilities: "Minimize conflict between moving traffic and parked vehicles." (See 7.1.2 below.) 2.3.7 Transportation /Utilities: "Discourage the maneuvering of automobiles or trucks on public rights -of- way." (See 7.1.2 below.) 2.3.8 Transportation /Utilities: "Support efforts to increase transit use." (See 7.1.3 below.) 2.3.9 Transportation /Utilities: "Create a sidewalk or pathway system where every link is a part of an integrated network." (See 7.1.4 below.) 2.3.10 Transportation /Utilities: "Provide for pedestrian overpasses over other transportation routes which 5 otherwise restrict safe pedestrian movement across them." (See 7.1.4 below.) 2.3.11 Transportation /Utilites: "Where possible, make provisions for local storm water which cannot enter the Green River during periods of high flow." (See 6.3.4 below.) 2.4 City Ordinance No. 1035 and Preliminary Waiver Granted Thereunder: The reasons for adoption of City Ordinance No. 1035 as a method of waiving inconsistencies with the CLUP until passage of a new zoning code are adequately detailed by the Developer at DEIS pps. 25 and 26. Section 4 of 1035 requires a "Complete Application" prior to processing a waiver request: "The City shall not process any waiver until such time as a com lete application for the applicable permit has been received, including compliance with [SEPA] as set forth in RCW 43.21C." (Emphasis added.) Developer states at DEIS p 26 that "A preliminary waiver was granted in January 1979, after review of the conceptional development plan. A final waiver requires SEPA compliance, and the final waiver request will be considered following finalization of the SEPA EIS process." I am convinced that the preliminary waiver, conditionally granted on the basis of later compliance with SEPA, ought now to be withdrawn since Developer, by this DEIS has demon- strated repeatedly that it does not now intend to comply with SEPA's requirements of full disclosure by supplying adequate data. Developer further does not intend to comply with the conditions set out in City Resolution No. 656 enacted to place specific conditions, as binding as "covenants running with the land," upon any purchaser of the City Light Property (Developer's property) which the purchaser would be required to meet prior to development. A comparison of the minutes of the regular meeting of the City Council dated January 15, 1979, with the Criteria set forth in Section 5 of Ordinance 656 raises the question whether "a majority of the City Council" found "that the proposed action is consistent with those Criteria ": 2.4.1 Criteria 1: "That the proposed action does represent a unique condition which is insignificant in scale. ": On this issue the vote was 5 that the Project was in fact significant and 2 the Project was not significant. 6 On this issue alone no waiver should have been granted to Chartwell. 2.4.2 Criteria 2: Developer to Explore Alternatives: Section 5 requires affirmative findings that the proposed Project is consistent with all Criteria prior to granting a waiver. In respect to Criteria #2, the City Council unanimously responded "no answer." No affirmative finding was made. By this criterion no waiver should have been granted to Chartwell. 2.4.3 Criteria 3: "Sufficient" Mitigating Measures: This, in effect, required that the Developer incorporate "sufficient mitigating measures" in its plan. Plainly, I am of the view that in this "best- shot" DEIS, Developer has not yet identified on any responsible basis these "sufficient mitigating measures." Nor has Developer identified the experts who are to answer these questions. However, at the time the Council took action I am not aware that the Developer had suggested any mitigating measures. One mitigation was a matter of particular focus at the Council's meeting: "Councilman Johanson asked if Chartwell has agreed to move the building from the southeast corner. Mayor Bauch said they have to comply with Resolution No. 656 and it says they will have to move it." (Emphasis supplied.) The. Developer cannot possibly have overlooked this specific requirement: the Developer was required to move a proposed 10 -story office building from the southeast to the southwest corner of the site. (See "Site Plan," Figure 3, DEIS p. 16). Councilman Hill's "yes" response to the meeting on this Criterion was conditioned upon moving the building and presumably he would have voted "no" had that building not been moved as now indicated by the DEIS. Councilman Harris evidently based his "yes" vote on the mistaken assumption that to fulfill Criterion 3 requirements Developer was not required to offer sufficient mitigating measures. We respectfully suggest that Criterion #3 requires "that sufficient mitigating measures are provided . ." and that properly understood, particularly in view of the insuf- ficiency of mitigating measures presented by Developer in this "best- shot" DEIS, Councilman Harris would reconsider his affirmative vote. 2.4.4 Criteria 4: Consistency with Comprehensive Plan: Although the Council unanimously found this Criteria met, we respectfully suggest reconsideration in view of the inconsisten- cies set out at Section 2.3 above. 7 2.4.5 Criteria 5: Special Hardship to a Site: Did the requirements of the ordinance present a "special hardship ?" How a unanimous affirmative vote could be cast that the Ordinance imposed special hardships on this Developer, I do not comprehend. City Resolution 656 set out the "ground rules" for development of the Chartwell property prior to the time Developer purchased. Developer was well aware and specifically assumed the "hardships" imposed by that Resolution. Developer assumed this risk and cannot be heard to say that he was not aware of these. As a specific example, the writer assumes that the new Comprehensive Land Use Plan Map adequately informed the Developer that his property was to be rezoned "C-P" (precisely as Southcenter's) and from that could reasonably anticipate that he would be required to supply 5.5 parking stalls per 1,000 sf retail. Developer nevertheless proposes otherwise. Is this a "special hardship ?" I request that Developer specifically answer this question: How does the Developer resolve the inconsistency between "hardship" and fully- informed "risk taking ?" 3. SEPA Requires the Developer Fully Disclose All the Facts Which the Developer Knows or Ought to Know Touching Upon a Project and its Environmental Impacts: 3.1 Setbacks and Developer's Site Plan: We mentioned in paragraph 3 of our letter that the Uniform Building Code ( "UBC ") requires 70' setbacks from property lines and that the Developer's Site Plan, Figure 4, DEIS p 16, is in this fashion not consistent with the 20' widening of Strander Boulevard mentioned at Figure 15, DEIS p 78. Setbacks are reduced to 50', 20' short of the UBC requirement. We have mentioned, at paragraph 7, page 7 of our letter that the City's TIP requires that prior to approval of Developer's Project, Developer be required to supply right - of -way and developed access roads west and south of the property boundaries. We assume that these, at a minimum, would be 4 to 5 lane access roads and that 50 to 60' of right -of -way would be required. If these assumptions are correct, UBC setback areas are invaded 50 to 60' along the entire south and west boundaries of the Project. Developable and "nature conservancy" areas are seriously reduced. 8 Why does the Developer not comment upon these possibili- ties? TIP was issued 10/19/1979, 2 months before issuance of Developer's DEIS. He must have known of this,. If Developer were required to dedicate right -of -way in the range of 50 -60' along the west and south boundaries, whole new sets of figures relative to parking, building, landscaped areas and the proposed 11 ac pond and "natural habitat" would necessarily emerge. 4. Soils Datas Not Supplied: To paragraph 4, page 4 of our letter little supplement need be made. Developer should mention and reckon with the effect of unstable soils conditions at the Project site in the event that TIP's requirements for development of 50 -60' access roads south and west of the property are adopted. How does Developer propose to prevent settlement along the west and south access roads when in fact, according to site plan, Figure 4, DEIS p 16, such rights -of -way would invade water surface areas of the Pond and would no doubt disturb nesting and feeding areas shown on the Site Plan to be located within Pond areas. How does Developer propose to protect new access roads from subsidence resulting from intrusions of right -of -way to close proximities with Developer's proposed underground parking shown at Figure 4, DEIS p 17. In discussing "Geology and Soils" at DEIS p 33, Developer discloses that "heavily loaded buildings may require support on relatively long piles." That is true. Those piles must support buildings of 10 stories and 2 stories of underlying parking or a total of 12 stories. Piles might be in the order of 150 -200'. Existing arterials, with fragile utility lines east and north of the Project, lie upon the same unstable soils. In reckoning with the pressure impacts of such piling, how does the Developer propose to protect against hazards to these arterials and utility lines during the course of construction? 5. Wildlife Biologist Data Is Not Supplied: 5.1 Importance of the Pond as a Wildlife Habitat: At DEIS p 50 the Developer describes this importance: "The variety and productivity of the site are unmatched on any comparably sized site in the Green River Valley or the Greater Seattle area. This factor combined with 9 the close proximity to intensively developed adjacent land make this site truly unusual and give it regional significance as wildlife habitat." 5.2 Divergences from Comprehensive Land Use Plan: 5.2.1 At paragraph 2.3.1 above the CLUP goal is to "strive to retain viable areas of . . . wetlands . . . for wildlife habitat." Bearing in mind that the underground parking will lie 4 -5' under the 15' water table, the Developer proposes to prevent seepage into the garage and to prevent vehicle - related pollutants from entering the Pond by water- proofing and equipping with emergency pumping units or permanent dewatering pumping systems. How does Developer, by these systems, intend to prevent vehicle - related pollutants from entering the environmentally- fragile Pond area? Can any wildlife biologist responsibly state that the state of his art can separate water from vehicle pollutants? If so, let him say so. 5.2.2 At DEIS p 90 and elsewhere Developer tells us that during the December 1975 and 1978 floods those from off -site surfaces raised the Pond level to 21.5' due to inadequacies of the existing P -17 storm system. These are approximately 10' above surface of the proposed underground parking garage of 23.5 acs. If that system is not improved will not the Developer be pumping auto - related garage pollu- tants from the garages approximate elevation of 10.5' feet into the Pond in contervention of the Comprehensive Plan's goal? What comment might be made by the City's fire chief to movement of fire equipment thru possibly 10' of flood water within the high fire risk garage? 5.3 DEIS Does Not Reveal Compliance with City Resolution 656: City Resolution 656, as we have said, adopted general guidelines for future development on Developer's property then owned by Seattle City Light. These and Developer's Proposals to mitigate are discussed at DEIS pps 26 -30. The precautions Developer promises to take are inadequate in the following respects: 5.3.1 Guideline 1: Control of Surface Water Runoff to Avoid Pollutants: I assume the runoffs mentioned are primarily parking lot runoffs since roof runoffs are relatively non - polluting. I assume further that such runoffs would include runoffs from the underground parking which Developer intends to pump back into the drainage system. Most would enter the Pond area. 10 Developer responds that "detailed drainage system designs for the site are not completed." "Final drainage design will be carefully developed to control silt, oils, nutrients and toxicants to the degree necessary to maintain the long -term viability of the Pond as a wildlife habitat." I ask the Developer: Do these unidentified, to -be- supplied detailed designs comply with Guideline 1? I ask that the Developer tell us whether the existing state of art of drainage design from parking surfaces really permits filtering or separation of parking area pollutants. 5.3.2 Guideline 2 a: Separate Human Access Areas from Prime Feeding and Nesting Areas: The Developer promises that "final development proposals for both human and wildlife uses of the pond environment will be carefully reviewed." This "promise" is insufficient, stressing the necessity for the detailed study and recommendations which Developer says he has obtained from a wildlife biologist. 5.3.3 Guideline 2 b: Separate Nesting Area and Possibly Create Island for Nesting Purposes: "Developer promises that these will be developed with consultation from a recognized wildlife biologist." Where is the biologist's study? 5.3.4 Guideline 2 c: Setback Access :Roads, Parking Areas and Future Developments from Pond: Developer promises to setback the Pond and natural areas but does not tell us how or to what extent. We have pointed out that Figure 4, DEIS p 17 indicates that the underground garage will be setback approximately 25'. If Developer is required to place 50 -60' access roads along the south and west boundaries these roadways would actually intrude into the surface water of the Pond as shown at Site Plan, Figure 3, DEIS p 16. 5.3.5 Guideline 2 f: Continual Monitoring of Water Quality: Developer promises that "Proposals will be made to the City on how to achieve this during the planning and design stages" but makes no promise for continual monitoring during the life of the Project except as this may be touched upon briefly at DEIS pps 50 -53. Discussion at these pages indicates that recommendations were made by a wildlife biologist but the study of the wildlife biologist employed by Developer must be appended to this DEIS. 11 5.3.6 Guideline 4: "Requires . . . Coordinated Development . . ." and to this end . . . "Review All Building and Site Development Plan for Compatibility with Surrounded Development Areas as well as for Compatibility with the Objec- tives of Water Life and Water Fowl Enhancement ": "The Developer's responds that "additional design review on approval is required prior to issuance of permits." In my view, Developer here admits that the Project he proposes is not "ripe" to demonstrate compliance with City Resolution 656 and the general SEPA requirements for "full disclosure" consideration of environmental impacts. 5.3.7 Guideline 6: Approximately 1/3 of the Total Area of the Site Should be Retained in its Natural State: The Developer's response is to preserve an 11 ac parcel for pond and natural area to which Developer would add 1 to 2 acs of adjacent landscaping. I comment that "additional landscaping" hardly meets the intention of Guideline 6 that approximately 1/3 of the total area should be retained in "natural state." In the event Developer's recommendation that the north end of the site be reduced 20' for widening of Strander Boulevard is accepted, Developer should tell us what effect this will have on the Guideline 6 requirement. In the event TIP's requirement before development, that 50 -60' roadways be developed along the south and west boundaries is accepted, Developer should tell us the conse- quences in respect to nature - conservancy of 1/3 of the entire site. Developer has already reduced the 12.96 acs to 11. How does he intend to cope with more reduction? 5.3.8 Guideline 7: The Area Retained for the Natural Condition is to be Located on the Southeast Portion of the Site: As discussed in paragraph 2.4.3 above, Developer insists upon locating the office building in the southeast corner of the site rather than move to the southwest corner. Developer's justification is that "the biological survey conducted indicates that the southwest corner of the site is more valuable . . ." Where is the biological survey appended to this DEIS? How can Guideline 7 and the requirements of City Ordinance 1035 be met or justified without it? 5.3.9 Guideline 8: A Major Portion of the Pond's Should be Retained . . .: The DEIS at p 41 indicates that 12 the water surface of the Pond generally (year-in, year -out) covers approximately 16 -17 acs. This appears again at DEIS p 60. Developer never reveals the surface acreage of the Pond after "redevelopment" but the Site Plan, Figure 4 at p 16, indicates a surface water acreage of approximately 6- 6.5'. I do not regard a reduction of the Pond's surface to 3 P7 %3of its present size as responding to a Criterion that requires that "major portion" be retained. 5.3.10 Guideline 10: Development Plans, Depicting the Future Utilization of the Entire Site, Should be Submitted at the Time of Waiver Application Review Any Proposal Indi- cating Less than Full Development of the Entire Site Should Contain, at a Minimum, Complete Plans Indicating Treatment of the Pond and Adjoining Wetland Wildlife Areas: The Developer responds that the DEIS fulfills this Criterion. I believe it is demonstrated above that this DEIS contains little but promises by Developer to provide future studies for review by the City. Developer does not even offer his survey and study said to have been made by his wildlife biologist. I conclude that the Guideline 10 require- ment has not been met. 6.1 Absence of Storm Study and Data: 6.1 Inconsistency with Comprehensive Plan: As pointed out in Section 2.3.2 above, the goal of the CLUP is to "encourage the preservation of marshes and ponds for the retention of storm water runoff." Developer, at "Unavoidable Adverse Impacts" DEIS p 117 cites as one of these "reduction in flood water storage capacity of the local storm drainage system." As pointed out in paragraph 6 of our letter, unless a full and detailed study and report is made by a responsible engineer and attached to the DEIS, it is impossible for the City, or for ourselves, to assess the degree of "reduction in flood water storage capacity" Developer's Project will cause. DEIS at p 94, however, says that: "The principal impact of the Proposal on the City's storm drainage system would be the loss of the existing flood waters storage capacity of the Pond." Without expert data, we can only assume the entire storage capacity of the Pond would be imperiled. 6.2 Mitigating Measures: As pointed out in our letter, DEIS at p 94 suggests: "Measures which could be studied include (1) provision for 13 • • additional storage capacity along the 108" pipeline corridor along I -405, (2) provision of separate storage for a portion of the runoff from the higher elevation areas, possibly in storage ponds in the vicinity of the freeway interchange, (3) collection of runoff water from all or a portion of those watershed areas of sufficient elevation to gravity drain to the river at maximum river level, and provision of a pressurized outfall to the river, thereby reducing the overall basin storage needs, and (4) increasing design capacity of the adjacent P -17 system to handle the overflow." Developer suggests only "measures which could be studied." We comment that without thorough and responsible analytical studies, the DEIS is obviously insufficient. 6.3 Factors Not Discussed by Developer: At various points in the DEIS Developer proposes measures which may or may not increase flows of water into the City's storm drainage system. Without an expert study, this writer would not know. However: 6.3.1 At DEIS p 50 Developer states that he intends to preserve the Pond a wildlife habitat in the following way: "the present fluctuation upon water levels would be replicated artifically." What does this mean in terms of adding to the load of the off -site drainage system? 6.3.2 At DEIS pps 33 and 34 I can only assume that Developer intends to prevent seepage into the underground parking area (below water level elevations) by equipping "with emergency pumping units or permanent dewatering pumping systems." What does this mean in terms of waters and pollu- tants added to the City's existing drainage system? 6.3.3 At DEIS p 34, the suggestion is made that the Pond may be particularly sensitive to nutrients . "possible accelerating eutrophication of the pond. This pond is particularly vulnerable since there is no significant through -flow of water to provide flushing." Observing that City Resolution 656 (intended to preserve the Pond as a wildlife habitat) requires, at Section 2 f that "measures must be taken to prevent eutrophication," Developer proposes "mitigating measures" at DEIS p 45. Without review of the study of Developer's wildlife biologist, this writer is unable to determine whether these mitigating measures require periodic and artificial flushing of the Pond. If this is required, to what extent does such flushing outflow into the City's existing storm drainage system? 14 • 6.3.4 If further study indicates that on -site storm waters will flow into the existing drainage system, to what extent is Developer's proposal inconsistent with the CLUP policy mentioned at Section 2.3.11 above? 7. Traffic and Circulation Data: 7.1 Inconsistency with Comprehensive Plan: 7.1.1 Commercial Uses Located Functionally Conven- ient to Major Traffic Ways: This CLUP policy is mentioned at paragraph 2.3.5. Developer's traffic consultant appears to assume that the "short -range goals" of TIP set out at TIP pps 36 -37 exist. In fact they do not exist and will not exist in 1985. They are part of the City's "Six Year Transportation Improvement Program" submitted annually to the State for consideration but at this time some improvements are not funded and no State or federal funding is in sight. (E.g. projects numbered 11, 29, 1, 2, 3, 27A and B shown on TIP Figure 12 at p. 33.) Some are not even included in the Six Year Program. TIP's insistence upon development of new access roads west and south of the Chartwell property prior to any development of that property evidently responds to the above CLUP goal. (TIP p 78.) Developer plans no such access roads and makes no reference to TIP's condition for improvement. 7.1.2 As pointed in paragraphs 2.3.6 and 2.3.7 above, CLUP goals are to "minimize conflict between moving traffic and parked vehicles" and to "discourage the maneuvering of automobiles or trucks on public rights -of- way." Figure 15 at DEIS p 78 shows "Recommended Site Traffic Improvements." It proposes four exits and entrances to and from. Strander Boulevard. For example, at peak levels shown on Figure 15, 550 vehicles would exit from underground and elevated parking at the major access upon Strander located directly opposite the major southerly access from Southcenter. Some vehicles would right turn easterly, some left turn westerly. The traffic consultant's assumption is that 9.2 vehicles per minute, right- turning and left- turning against what might be similar volumes from the Southcenter project could move onto Strander Boulevard despite the obvious fact that signalization would provide pedestrian "wait- times" for pedestrian traffic in 4 directions. At the same time the expert proposes that 200 vehicles or 3.3 vehicles per minute enter Developer's 15 Project. Common sense tells us the system, as proposed, would simply break down at this point. One who has entered or exited underground facilities in any major Seattle building knows the "queue time" before exiting and has experienced the undeterminable delays in trying to enter such a facility at peak exit hours. At our reproduction of the Site Plan (Exhibit "A" attached) we have indicated what Developer tells us will be built in the first and second stages of the Project and have further indicated the square footages involved. Observe that portion of the shopping center area outlined in blue, indicating 109,800 sf of shop area. Note that absolutely no ground level truck access has been provided to serve this area. We conclude that truck access is available to this area only by truck routes passing through the underground garage, although Developer has not shown such truck routes on his Parking Plan, Figure 4, DEIS p 17. Have we or has the Developer overlooked something? If access is not so provided how does Developer's proposal become consistent with the CLUP goal to "discourage the maneuvering of . . . trucks on public rights -of- way." With the peak hour congestion at points of access to underground facilities mentioned above, how does the Developer plan to avoid maneuvering of trucks on Strander Boulevard and Andover Park West? 7.1.3 As set out in paragraph 2.3.8 above the CLUP guideline requires Developers to "support efforts to increase transit use." Mass transit is mentioned many times throughout the DEIS. At DEIS p 22 "people movers" are mentioned largely, we assume, for charismatic effect. We wondered how a "people mover" would aid circulation to and from the Project. Developer tells us that the system would be used "to transport people from transit stops and parking areas to the malls and lobbys." However, observe Developer's Site Plan, Figure 3, p 16 and Developer's Recommended Site Traffic Improvements, Figure 15, DEIS p 78. No provision whatsoever is made for bus stop terminals along either Strander Boulevard or Andover Park West. We believe on -site bus terminals would be virtually impossible by reason of the configurations of the Developer's points of access into elevated and underground parking facilities. Absence of such on -site bus terminals would not "support efforts to increase transit use." 7.1.4 CLUP Guides mentioned at 2.3.9 and 2.3.10 speak to pedestrian traffic. Developer is to "create a 16 sidewalk or pathway system" and to "provide for pedestrian overpasses over other transportation routes . " Developer does provide sidewalks through widenings of Strander Boulevard and Andover Park West which, as we have mentioned, intrude upon Developer's property and upon building setbacks required by Building Codes. Has Developer's traffic consultant considered the efficiency of the signalization proposed to increase the vehicle- movement capacities of these arterials when faced with the necessity that signals provide pedestrian "wait - times?" Who is to provide a passage for pedestrians by "over- passes" of Strander and Andover Park West? In these regards, Developer's Proposal falls short on one or another of the CLUP goals mentioned above. 8. Parking: 8.1 Inconsistency with Comprehensive Plan: At 2.3.4 above we mentioned that one of the CLUP goals is to "promote adequate provisions for parking for all land uses." Our previous conclusion has been that -the Developer's plan falls 960 stalls short of what the City Zoning Code or industry would require. Our further conclusion is that Developer cannot possibly provide the 6300 stalls he promises to provide because of the invasion of building support systems into underground parking levels Developer proposes and because the site will be diminished by widening of existing streets creation of new streets south and west of Developer's property. We predict Developer will fall in excess of 2,000 stalls short of those required for consistency with the CLUP. 8.2 Employee Parking: At DEIS p 9, Developer predicts that the Project will attract 4500 on -site employees; 1700 in shopping center operations, 2400 at office buildings, 300 hotel employees and 100 general operations employees. We ask: how many of the 6300 parking stalls Developer promises will be preempted by these employees particularly when Developer has made no provision for convenient on -site 17 bus terminals. Southcenter figures indicate that 850 -1000 stalls are preempted in its parking area by employees. Please note the transient reference to bus service at DEIS p 84: "Metro transit should be encouraged to investigate the need and opportunity to focus additional regional service on the strength of the increased employment density which the proposed project will bring about." (Emphasis added.) Note also Metro's response to this DEIS dated January 18, 1980, in which Metro recommends ". . . incorporation of transit access and potential loading zones in the site plan for the proposal" and recommends that the Developer "provide a one (1) month transit pass to employees and tenants." How does Developer intend to accomplish these recommendations? 8.3 Existing Traffic Congestion: A picture is worth thousands of words. At Exhibit "D" we attach aerial photographs showing existing congestion within parking areas, upon adjacent arterials and at points of access to the freeway systems. M1/27 GWM:np 18 �pE VICTOR H. BISHOP P.E. President TRANSPORTATION PLANNING & ENGINEERING, INC. Mr. George W. McBroom Shidler, McBroom, Gates & Baldwin Norton Building, 10th Floor 801 Second Avenue Seattle, WA 98104 Dear Mr. McBroom: 1126108th AVENUE NORTHEAST— BELLEVUE, WASHINGTON 98004 TELEPHONE 455 -5320— AREA CODE 206 January 17, 1980 Re: Transportation Review of Chartwell Development Corp. DEIS At your request I have reviewed the transportation and circulation section of the Draft Environmental Impact Statement (DEIS) for Tukwila City Center, a proposed development by the Chartwell Development Corporation, in the southwest quadrant of the intersection of Strander Boulevard and Andover Park West in Tukwila, Washington. In my opinion, the DEIS is insuf- ficient in several respects related to the transportation and circulation elements, including the following: I. The vehicle trip generation estimates of Table X are substantially underestimated. II. The impact of the acknowledged trip generation is substantially understated in the Traffic Impact Analysis and Mitigating Measures sections of the DEIS. III. The DEIS has disregarded the local circulation recommendations of the Tukwila Transportation Improvement Plan, October, 1979, Entranco Engineers (Tukwila TIP)for traffic circulation in the super block that the proposal is included within. • TRANSPORTATION PLANNING & ENGINEERING, INC. Mr. George W. McBroom January 17, 1980 Page 2 of 9 pages IV. The DEIS does not discuss the potential cost nor the potential funding sources for the wide range of transportation improvements that will be re- quired to mitigate the impacts of this proposal if the proposal is accepted. I will discuss each of the above four items in some detail below. I. UNDERESTIMATED TRAFFIC GENERATION A. Retail facilities The trip generation rates available from the Institute of Traffic Engineers (ITE) are rates that are commonly used to predict traffic flows at future shopping centers. These rates, how- ever, are average rates compiled from several shopping centers with a minimum and maximum rate also given which shows a relatively wide range of vehile trip ends ( VTE's) generated per 1,000 sq. ft. of gross feasable floor area (GLFA) per day by various sized shopping centers. The DEIS has combined the existing Southcenter Shopping Center with the proposed shopping center for a total of approximately two million square feet of GLFA, to arrive at an average rate for the new center of 26.5 VTE's /1000 sq. ft. /day. This number is then further reduced by using some of the same reasons that the lower rate comes about in the first place, (i.e., the on -site office employee customers and improved transit service) and then calls this a "probable" trip generation in Table X. The "probable" retail shopping trips of 18,000 works out to a trip generation rate of 22.5 VTE's, per day per thousand square feet. The existing Southcenter shopping center is an extremely successful shopping center and is in the upper 10% of all shopping centers of its size in the country in terms of dollar volume per square • TRANSPORTATION PLANNING & ENGINEERING, INC. Mr. George W. McBroom January 17, 1980 Page 3 of 9 pages foot of GLFA. It is one of the top ten centers on the West Coast using the same method of measurement, and should not be referred to as an "average" center. Therefore, it is not.appr.opri -- ate to take a published number for average centers and then reduce that number and apply it to trips produced by Southcenter or a center that expects to compete with Southcenter. See attached exhibits. The DEIS identifies the substantially re- duced trip generation as "probable" average week- day vehicle trips in Table X. The average trip generation per the ITE published data is identi- fied as "maximum" in Table X. In my opinion, the. "probable" number is un- realistically low; the "maximum" number is in truth an average for similar retail shopping centers..: Neither a "probable" nor "maximum" number of vehicle trips expected to be generated for this retail center which expects to compete with the highly successful Southcenter are realistically identified. B. Office Facilities The ITE studies show an average trip rate of 12.3 VTE's per 1,000 gross square feet per day for general office buildings with a range from a low of 3.6 to a high, or maximum of 43.5 VTE's per 1,000 sq. ft. per day. Other ITE office categories have significantly higher average trip generation rates such as 20.65 VTE's for an office park, 25.0 for a civic center, 68.93 for a government office building, and 75.0 for a medical office building. To arbitrarily reduce the average published data by over one third from 12.3 to 8 VTE's per day per thousand square feet and call it "probable" for the Tukwila City Center is an underestimate of a realistic expectation for trips to be generated by this office facility. Again, Table X of the DEIS calls the reduced rate "probable. and the ITE average rate "maximum" which gives the reader an erroneous impression. TRANSPORTATION PLANNING & ENGINEERING, INC. Mr. George W. McBroom January 17, 1980 Page 4 of 9 pages C. Hotel /Suite Facilities Again, the DEIS makes a rather arbitrary reduction of about 25% in the trip production rate for hotel rooms and suites from 8.1 VTE's per day per total room to 6 VTE's per day per room. This arbitrarily reduced rate is called "probable" and the average rate is labeled "maximum" (in fact, the ITE rate is 10.5 VTE's per day per occupied room and the 8.1 VTE's per day per total room used in the DEIS is unsub- stantiated by any documents referenced in the DEIS. D. Average Weekday Versus Average Friday Traffic Flows When analyzing the impacts of a development such as the proposal, it is common practice to re- view the traffic generation on an average Friday. It is standard practice to design arterial streets for a time period which is somewhat less than the expected peak traffic flows of the year, in the range of the 30th to 50th highest hour of the year. It is well accepted that the normal street p.m. peak hour on a Friday of an average week approxi- mates this 30th to 50th highest hour of the year. The DEIS acknowledges on pages 71 and 72 that the Friday traffic exceeds the average weekday traffic by approximately 10%. This then is discounted in the DEIS on page 72 by the reference to lower Friday volumes for the office and hotel complexes. To my knowledge there is no substantiation for this reduction of vehicle trips generated by offices and hotels on a Friday. Experience with business - oriented hotels such as the proposal shows that Friday, Saturday and Sunday evenings have less occupancy in the hotel, but the occupants that are utilizing the facility are very much auto- mobile oriented as opposed to the business - orientation during . the mid -week. Therefore, the vehicle trips generated to the hotel facilities are substantially higher on Friday during the • TRANSPORTATION PLANNING & ENGINEERING, INC. Mr. George W. McBroom January 17, 1980 Page 5 of 9 pages afternoon and evening than any other weekday. The hotel's restaurant, lounge, and banquet facilities will also have a substantially higher VTE generation on Friday than any other weekday. It is also common for the peak hour of office employee traffic to be higher on Friday than the other weekdays because of the lack of overtime and business meetings on Friday night as compared to other nights of the week. A conservative, low estimate, therefore, for average Friday traffic versus average weekday traffic would be to increase the total average weekday traffic for retail, office and hotel facilities by 10% to reflect an average Friday daily traffic volume. E. The Accumulative Effect The accumulative effect of the above discussion is that the vehicle trip generation estimates of Table X of the DEIS are substantially low. The numbers identified as "probable" are extremely low, the numbers identified as "maximum" are really in the range of an average weekday type of operation and a true probable situation given the exceedingly successful Southcenter operation would be higher than anything shown in Table X. If we were to use the average numbers (shown as "maximum in Table X) and increase them by 10% to reflect an average Friday situation, we would then be in the range of an acceptable traffic flow to use for traffic capacity analysis of the arterial streets in the area. The net'increase in traffic within the cordon area shown on Figure 11 of the DEIS would then be 110% of 24,300, or approximately 26,700 vehicle trip ends per average Friday. Thus a realistic, conservatively low vehicle trip genera- tion estimate that could be used for analysis of the impact of the project on the arterial and free- way system in the influenced area of the proposal is over 50% higher than the 17,400 vehicle trips utilized in the DEIS. • • TRANSPORTATION PLANNING & ENGINEERING, INC. Mr. George W. McBroom January 17, 1980 Page 6 of 9. pages II. THE IMPACT OF THE ACKNOWLEDGED TRIP GENERATION IS SUBSTANTIALLY UNDERSTATED. The impact of the acknowledged trips in the DEIS on the arterial street system and the critical inter- sections is substantially understated. As an example, the intersection of Strander Boulevard and Southcenter Parkway has a 1979 AWDT (Figure 6 of Tukwila TIP) of 17,000, 19,000 and 15,000 (51,000 total) and p.m. peak hour approach values of 1,022, 941 and 722, for the north, south and east legs of the intersection, respec- tively. The intersection is now operating at level of service "E" on an average weekday, with the possi- bility of being improved to a very low LOS "C" on an average weekday (V /C = 0.79, Figure 8 of the Tukwila TIP) by means of an unfunded project at this intersec- tion, its approaches and the adjacent intersections to the north (all three inter.s.e.cti,ons are so. close :that they influence the flow of traffic through. each ' .other . The DEIS projects 1985 AWDT's to increase to 34,000, 24,000 and 28,500 (Figure 13) on the north, south, and east legs, respectively (86,500 total), or a 70% in- crease •( (86,500 - 51,000/51,000) x 100) in traffic at this critical intersection. When the general underestimation of peak hour trips during a typical design hour (peak hour of an average Friday) is superimposed on the above, it is clear that the impact of the project on the traffic flow at this intersection (and several others in the area) is grossly underestimated and not properly evaluated. Finally, all the recommendations of Figure 14 of the DEIS not shown on Figure 15 are merely "suggested" or identified as "desirable ". TRANSPORTATION PLANNING & ENGINEERING, INC. Mr._George McBroom January 17, 1980 Page 7 of 9 pages III. THE DEIS DISREGARDED THE LOCAL CIRCULATIONS'S RECOM- MENDATION OF THE TUKWILA TIP A project with a land use intensity such as this one should be required to thoroughly analyze its im- pacts on the transportation network within its in- fluence area. This would clearly include all inter- sections shown on Figure 14 of the DEIS recommended for "new or improved signalization desired" plus all the affected intersections. Two extremely important local circulation routes for traffic flow-and bus cir- culation include the streets on the west and south sides of the proposal site. Surely a reasonable trade off between building area that encroaches into the pond area and required circulation streets can be made. The connecting streets into and out of the cordon area shown on Figure 11 are also of serious concern. Virtually all connections have serious problems, some of which can be moderately improved by the Short Range projects of the Tukwila TIP, but all of which will be significantly impacted by the proposal. These connec- tions would include: the southbound I -5 off -ramp to S. 154th Street, the westbound I -405 off -ramp to Southcenter Boulevard, the S -Line bridge, the east- bound I -405 on -ramp, the T -line bridge, the I -405 inter- change with SR -181 including Grady Way, the Strander Boulevard bridge over the Green River at its intersec- tion at SR -181, SR -181 at S. 180th Street and the S. 180th Street bridge over the Green River, South - center Parkway extension to the south, S. 178th Street connection from Southcenter Parkway to SR -99, Klickitat Drive over I -5, and the I -5 northbound off -ramps to Southcenter Parkway. The Tukwila TIP addresses this issue on page 18 as follows: "The substantial proportion of freeway - origin and destination traffic is important to note since the limited number of ramps and wide spacing between streets which serve the. C.I.D. (Commercial - Industrial District) means that traffic growth will • TRANSPORTATION PLANNING & ENGINEERING, INC. Mr. George McBroom January 17, 1980 Page 8 of 9 pages continue to be felt at a limited number of already heavily loaded intersections, such as Tukwila Park- way at S -=Line Bridge and Southcenter Parkway at Strander Boulevard ". The DEIS ignores the former intersection and grossly underestimates the impact on the latter intersection. IV. FUTURE TRANSPORTATION REQUIREMENTS The Tukwila TIP discusses in Chapter IV, Long Range Improvement Plans, on page 51, in a brief manner some of the anticipated traffic projections and transportation requirements to satisfy those projections. It should be noted that the Tukwila TIP projections of Figure 14, page 57, assumes a "...lesser intensity of development for the Chartwell property- - similar to much of the present development outside of Southcenter shopping center - -than is now proposed there ". Yet a strong argument is made for the provi- sion of an arterial connection on the west and south sides of the Chartwell property as well as the construc- tion of Minkler Boulevard from Southcenter Parkway to SR -181. The recommended traffic improvements, of Figure 14 of the DEIS includes only a portion of the long range through lane requirements shown on Figure 15 of the Tukwila TIP. However, in spite of the fact that the proposed project has substantially higher intensity and trip generation than was assumed in the Tukwila TIP, those arterials that are included in the DEIS have virtually the same number of lanes shown for the future as does the Tukwila TIP. It is clear that the proposed development would generate sufficient traffic volumes to require the acceleration of the long range improvements in the Commercial Industrial District shown on Figure 15 of the Tukwila TIP to 1985 or sooner. No discussion of potential funding sources for any of these major im- provement- proj.ects(except those immediately adjacent to the proposal site) is included in the DEIS. • • TRANSPORTATION PLANNING & ENGINEERING, INC. Mr. George W. McBroom January 17, 1980 Page 9 of 9 pages The Tukwila TIP discusses the impact of this proposal on the arterial street system in the area on page 77 and 78. That brief discussion tends to support the above. Several other transportation issues relating to this pro- posal are of concern, such as the provision for parking and assumptions with regard to Metro Transit. However, I am under the impression that others are commenting on those subjects.. Very truly yours, Transportation Planning & Engineering, Inc. Victor H. Bishop, P. E. President VHB:nw ensini mad 51 VANDER BLVD lev. B Ing ifeeser [rte. rralcn tint. .4".. .... • • • - Id . 0 0 cc Ln -J LLJ 0 /to) ase. . 1: Ma Exhiwt "A" neon; roe if CVO . ANCHOR 1 14 3f-coons 244), 4( 4-00 SHOPPING col 43 !IN waler to Et =trued into orsiirg Idi AI m (2 eW —0 CZD ANCHOR 3 3,5P411 - Ire d ectsitng %e:Cato:el CD DlD =1 63 of 11 acres d p:nd netland 0 50 100 200 300 feet LEG END-Ris Pms.f. E=3 011 *ITT** CD R•Tall _DM SIORES HALL OFFICE ROOF 111El RAMP LP RAMP DO "e■ tukwila city center Site Plan FIG. 3. 16 STRANDER BLVD. L L C B HUVd U]AOaNV tukwilci Lower Level City Cef1ter Parking Plan 1'YS I V fd FIG. 4. ACTION ON THE SEATTLE CITY LIGHT PROPERTY Cit- of Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of Community' Development 29. January. 1980 Chartwell Development Co. 555 Hastings St. Vancouver, B.C. Canada V6B4N6 Re: Tukwila City Center DEIS - Further Processing thereof by the City File (EPIC- 18- 79 -SA) Enclosed with this letter are copies of all written comments received by the City of Tukwila during the 35 -day public continent period prescribed by SEPA, WAG- 19 -10- 455(2). The following inventory describes the sources and extent of comments received; if you find the accompanying material incomplete upon comparison with the inventory, please contact me. CCHMENTOR 1) Hubert H. Crawley.. 2) Jamia R. Murray 3) Gordon Sandison 4) Scott Salzer. 5) Tukwila City Council 6) David V. Galvin 7) Barbara J. Ritchie 8) David R. Clemmens 9) A.R. Dammkoehler 10) Timothy S. Dubois 11) Bob Zeigler 12) Rodney G. Proctor.. 13) Lionel C. "Bud" Bohrer 14) W.R. Lewis 15) Ronn Griffin 16) John A. Sheets 17) George W. McBroom,et al 18) Jim Billing 19) William P. Albomn 20) Mary Ellen McCaffree REPRESENTING NO. OF PAGES 'Ilk. Fire Department USDA- Forrest Service Dept. of Fisheries Private Citizen Individual Councilmembers Seattle Audubon Society Dept. of Ecology City of Renton Puget Sound Air Poll.Control Agency Doubletree Inn Dept. of Game Metro Tuk. City Council.' J.C. Penney Co. Private Citizen 'hilt. Police Dept. Southcenter PSCOG Dept. of Transportation King County Budget Div. In addition to . the foregoing material, we shall forward to you are available a set of minutes from the DEIS public hearing to the City on 4 February 1980. Please refer to my letter to you for more information on the matter of a public hearing. 3 1 1 3 1 2 1 2 2 1 3 2 1 2 5 1 .47 13 1 . 5, as soon as they be conducted by of 24 January 1980 Ltr. to Wilsey and Ham, Inc. Tukwila City Center 1) 2) 3) 4) 5) 6) 7) 8) 9) CCMMENTOR Hubert H. Crawley Jamia R. Murray Gordon Sand.ison. Scott Salzer Tukwila City Council David V. Galvin Barbara J. Ritchie David R. Clenunens A.R. Damnkoehler 10) Timothy S. Dubois_ 11) Bob Zeigler 12) Rodney G. Proctor 13) Lionel C.'Bud" Bohrer 14) W. R. Lewis 15) Ronn Griffin 16) John A. Sheets. 17) George W. McBroom,et al 18) Jim Billing Page 2 23 January 1980 REPRESENTING Tuk: Fire Dept:. USDA - Forrest Service Dept. of Fisheries Private Citizen Individual Councilmembers.. Seattle Audubon Society Dept. of Ecology City of Renton Puget Sound Air Poll'.' Control Agency Doubletree Inn Dept. of Game Metro Tuk. City Council... J.C. Penney. Co. Private Citizen Tuk. Police Dept. Southcenter 1 3 1 2 1 2 • 2 PSCOG Please dire t. any questions to my attention. Caughey Assistant Planner MC /mkb Enclosure Ltr. to Chartwell Re: Tukwila City Center DEIS 29 January 1980 According to WAC- 197 -10 -580, the next task of the lead agency in the draft EIS processing sequence is to determine adequacy of the draft document relative to the objectives and intent of the State Environmental Policy Act. Two alternative actions are open to the responsible official's discretion: 1) Determine that the DEIS is adequate, or adequate with minor modifications and circulate the document with sunmaryand.response to' public-comment, as a final EIS per WAC- 197 -10 -600. 2) Determine that the DEIS is . not adequate, and cannot be made adequate with minor modifications, to satisfy the intent of SEPA. • Such determination would almost certainly require rewriting of the draft document. Approval of the responsible official prior to circulation of the "final" (rewritten) document would be necessary. Before making a determination of adequacy, acting as responsible official for the lead agency, it would be helpful to have from Chartwell a summary of the comments received and your response to them. My eneral perceptions at this point, having read the draft document and read the p b lic comments are: 1) The DEIS appears adequate insofar as it identifies the sources of potential environmental impacts associated with the project. 2) The DEIS appears inadequate in its identification of the magni- tude of certain of those impacts. 3) The DEIS appears inadequate in its description of certain proposed solutions to offset the magnitude of certain described impacts. In • most cases, the perceived inadequacies result not so much from the method of mitigation suggested as from the sketchy degree of detail provided to ensure the practical workability of the proposed method. Realistic funding availability for sane mitigating solutions requir- ing public participation also seem to be inadequately supported in the text. Your task at this point is to analyze the enclosed material and to present a con- vincing case for total adequacy of the draft document with or without minor changes in the text or in the project proposal. itself.- Your firm may perform the analysis, or you arrange for the City to prepare the formal response according to pro - cedure�cribed in Ord. 986. Please advise me of your preference in this regard. rk Caughey Acting Responsible Official MC /mkb Enclosures /Attachments cc: Mayor Frank Todd Cityt Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of Community Development .. June 16, 1980 ATTENTION: KENNETH CHAUNCEY, PRESIDENT CHARTWELL DEVELOPMENT CO. 555 West Hastings St., #2800 Vancouver, British Columbia V68 4N6 RE: EPIC- 18 -79 -SA -- DEIS City Center Project This letter is intended to restate some of the understandings reached during our meeting of June 4, 1980 and to transmit the attached des- cription of perceived deficiencies in the December 17, 1979 DEIS. Regarding our June 4 meeting attended by yourself; Keith Cinnamon; City Attorney, Larry Hard; Attorney Dave Oswald; and myself, I believe that a consensus of opinion was reached on the following: 1. Redraft of EIS: Based on Mr. Hard's reasoning, it is highly doubtful that the serious deficiencies of the December 17, 1979 DEIS can be rectified to the extent of avoiding probable litigation on the subject of adequacy. Therefore, it will be necessary to prepare a completely new DEIS and discard the former draft. Of course tome of the material contained in that December 17 draft, and much of its underlying research, can be re -used in the new draft. I should also emphasize Mr. Hard's opinion that a project.specific EIS will be required for any and all development permits required to build the project, and that a single EIS document, properly prepared, should adequately address all concerns relative to those. various required permits. . Rezone to C =PR: To rezone the City Center site to the C -PR (Planned Business Center) category, two optional courses of action are open to Chartwell: A. Chartwell initiates application for rezoning :. To begin this course of action, Chartwell would have to prepare a revised conceptual development plan for the project (TMC 18.34.090) and circulate a final site` specific EIS (RCW 43.21c.030). B. City initiates site rezone: Under this option, Chartwell takes no action but allows the City Council, as part of the current process of adopting a new zoning ordinance and map, to finalize redesignation of your property to C -PR. Chartwell Development Co. June 16, 1980 Page 2 RE: EPIC- 18 -79 -SA -- DEIS City Center Project Chartwell may at'any time initiate rezoning action on its own behalf. However, to do so it will be necessary to prepare a new conceptual plan for the site and to finalize a project specific EIS. Thank you for your participation in the June 9th meeting. TUKWILA P, ANNING DEPARTMENT Mark Caughey Acting Director MC /ch Enclosures cc: Mayor Todd Larry Hard Dave Oswald ! ,a /CIS BAY &VINDING Annette and Mark Caughey 29754 Fourth Avenue South Federal Way . Washington 98003 U.S.A. vor ref.: 171.45oo . IV Kmre Annette. Deres ref.: Ingenir r- og entreprenorfirma Telefon: (02) 81 6622 Telex: 37 322 Bayvin DK Telegram: Bayvin Postgirokonto nr.: 9 02 99 66 A /S -reg. nr. 34615 Kajerodgaard, 3460 Birkerod Den: september 24, 1981 Tak for nogle og togkort, det kom godt frem for laenge siden. Ellers ikke mere til dig - resten er forretning til din tekniske husbond. Dear Mark, What you told me this summer about a huge shopping center seems to be rather interesting in more than one way. I don't remember, how much I told you about this super concrete, called Densit, but the idea is that one could make the piles with a cross section only a fraction of what would be necessary in ordinary concrete. Rather nearer a steel section, but corrosion qualities better than for concrete. But of course, at a price, so I am afraid, we may have to forget it for the structures :, and concen- trate on piles. Even that could give us a handsome profit and reduce the cost for the city. And possibly give me a trip to see you. Could it be . better? Would you help me with all the information, you can find? I am thinking of - a plan, sketch or detailed,,�at whatever stage the project: is, - a time schedule, /li h 4+" (1e —5 ON - what has been thought of for foundations, or what would be customary? - which load per Dile? - how many piles? - do I remember right that the piles will be 250 feet long? - soils qualities, from this site or from somewhere similar, - will it he one main contractor or split up in small contracts? - will the piles be a separate contract? - will any one contractor be more or less predestined to do the piles or even all the structural works? Who? - will bidding be open to all? Fill in the list yourself with whatever you think iluseful information. If some of my many questions are tricky to answer, please send me some words about what is easy, and let me have the rest when it is there. If the piles are to be part of a bigger contract, would it be possible to change the plans and have them separated? If not, I count on giving sub -bids to all likely bidders for the main contract. Will you be able JERNBETON, KABELARBEJDE, VEJ- OG KLOAKARBEJDE, FUNDERING - 2 - • AS BAY &VINDING to give me their names, when the time comes? The idea is that. Bay & Vinding will be together with a Danish company, specialised in foundations, and either bid as such, or rather work together with a US contractor who will and can use our know -how. The Densit was devellopped by my old friend Hans, Henrik Bache - perhaps Jurgen remembers him from the old days - who works in the concrete lab. of Aalborg Portland Cement Company. I give him a copy of this letter and your address, so he can send you some papers about Densit. You ought to know what the whole thing is. I don't know very much about US building codes and standards, but I imagine we shall have quite a job convincing the building authorities that our methods are safe. If necessary, we could make some full scale tests, here or there, proving the bearing capacity. It would be marvellous to get in with the designs people at an early stage, but let us know more about the project first, if there is time. Hils resten of familjen, n$r I ser dem. Kmrlig hilsen, ogsa fra hele min klan ROGER L. SHIDLER GEORGE W. MCBROOM WILLIAM H. GATES WILLIAM F. BALDWIN JAMES R. IRWIN JAMES C. MIDDLEBROOKS RICHARD B. DODD FREDERICK ROSS BOUNCY WILLIAM H. NEUKOM JAMES L. FLETCHER DAVID T. MCOONALD PATRICIA J. PARKS DALE K. ROUNDY GARY D. HUFF WILLIAM A. BUTLER DAVID H. BINNEY ROBERT A. ESHELMAN CONSTP.NCE L. PROCTOR SHIDLER, McBROOM, GATES & BALDWIN A PROFESSIONAL SERVICE CORPORATION LAW OFFICES 1000 NORTON BUILDING SEATTLE, WASHINGTON 96104 March 26, 1980 Mr. Lawrence E. Hard LeSourd,, Patten, Fleming, Hartung & Emory 3900 Seattle -First National Bank Building Seattle, Washington 98154 Re: Tukwila - Resolution 656 Dear Mr. Hard: 12061223-4666 This letter is to reconfirm my statements made at Monday night's City Council meeting concerning the proposed Amend- ment by the Tukwila City Council of Resolution 656. As you know, RCW 43.21C.030(c) provides for a full environmental re- view of proposals for legislation with significant environ- mental impacts. There can be little doubt that the proposed drastic reduction in the scope of Resolution 656 is such an action. We must, with all due respect, further refute the contention of Mayor Todd that the 1975 EIS by City Light satisfies this requirement. There can be little doubt that a five year old Environmental Impact Statement based on a different project does not satisfy the needs herein. GDH:pm ENC: Sincerely, ROGER L. SHIDLER GEORGE W. MCBROOM WILLIAM H. GATES WILLIAM F. BALDWIN JAMES R. IRWIN JAMES C. MIDDLEBROOKS RICHARD B. DODO FREDERICK ROSS BOUNDY WILLIAM H. NEUKOM JAMES L. FLETCHER DAVID T. McDONALD PATRICIA J. PARKS DALE K. ROUNDY GARY D. HUFF WILLIAM A. BUTLER DAVID H. BINNEY ROBERT A. ESHELMAN CONSTANCE L. PROCTOR SHIDLER, McBROOM, GATES & BALDWIN A PROFESSIONAL SERVICE CORPORATION LAW OFFICES 1000 NORTON BUILDING SEATTLE, WASHINGTON 98104 Mr. Mark Caughey Assistant Planner City of Tukwila 6200 Southcenter Blvd. Seattle, Washington 98188 Dear Mr. Caughey: March 4, 1980 (206) 223-4666 i�.t �:7Lz1�JLm 0.c.D. CITY OF TUKWILA MAR 6 1980 This letter is to confirm our understanding that you will notify this office in the event of any appeal by Chartwell of your zoning determination concerning the Tukwila Pond property. This request covers, of course, information concerning the time and place of hearing. GWM:pm cc: Mr. Richard S. Eichler Si -ce ely George McBroom Citytf Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of Community Development 14 February 1980 Chartwel.l Development Co. 555 Hastings St. Vancouver, BC Canada..V6B4N6 Attn: Kenneth Chauncey Re: Rezoning Requirement - Tukwila City Center Project Dear Mr. Chauncey: As I informed you in our telephone conversation on 13 February 1980, I have deter- mined that the existing C -M (Industrial Park) zone for the Tukwila City Center pro- ject site is not appropriate to the type of development concept (i.e. - enclosed . mall) described in the project Draft Environmental Impact Statement (D.E.I.S.) In essence, my determination reverses the zoning ordinance interpretation of 16 November 1979 by former 0.C.D. Director Kjell Stoknes which concluded that shopping malls are an allowed C -M use. As designated Responsible Official and Acting. Planning Director, I am charged with the duty of interpreting the City's zoning and land use regulations. With all due respect to Mr. Stoknes, I believe that several of the findings cited in the 16 November 1979 interpretation do not support the decision reached therein. The following is an analysis of the difficulties which I perceive with the 16 November interpretation and an explanation of why I believe the C -PR zoning district to be appropriate for accommodation of your proposed development concept: A) Regarding Mr. Stoknes' interpretation of 16 November 1979. 1. Findings 1 through 7 discuss the "Narod" waiver application on this site, which included an interior mall. The interpretor's basic conclusion was that the mall concept is permissable in C -M since no discussion. to the contrary took place during the waiver application hearing process. Response: The fact that the City Council minutes are vague on the matter of permitted uses irrcontext of a particular development proposal does not foreclose the possibility of future discussion and re- interpretation of the matter by public officials charged with zoning administration authority. I sincerely believe that the concept of the interior mall as a "use" should have been raised at that time and resolved. It is stretching the`point,though, to construct Chartwell Development • Co. Page 2 p 9 Attn: Kenneth Chauncey 14 February 1980 a binding precedent based on the absence of a specific point of dis- cussion, and to conclude that silence is necessarily consent. `However, even if we were to assume that the City Council believed the interior mall use to be appropriate in the C -M zone, I am sincerely convinced that such belief would be erroneous and would not feel bound toperpe- tuate an inaccurate, though sincere, application of city zoning provi- sions. Thus, it seems that the Narod application gives us little if any guidance on the subject of land use propriety. . 2. Finding 15 concludes that the presence or absence of a common mall or concourse is irrelevant to the question of permitted uses in a given zoning district, in that a mall or concourse is solely a structural amenity. Response: The Tukwila Zoning Ordinance provides a special category of land use controls for .Planned Business Centers. In his interpretation dated 13 September 1979, former Planning Supervisor Fred Satterstrom explained the relationship between the concept of "essential use" in a zoning district, and the requirement for unified and organized arrangement of buildings and facilities in a, functional relationship as required in the C -P zoning district. It 'is my belief that the shopping center con- course with its tenant spaces opening onto that concourse together comprise an "essential use ", and that it is erroneous to separate the common mall from its adjoining tenant partitions when discussing the concept of a planned shopping center environment such as your firm proposes. Further, the mall portion of a shopping center can be considered a "use" in and of itself. One of the great marketing strengths of the shopping mall concept is the high degree of flexible activity space offered by the mall concourse itself. From time to time, activities such as automobile displays, art and craft fairs, cultural and seasonal events are scheduled on the concourse during regular tenant business hours. These mall activities have the potential to attract visitors to the shopping center who may not partronize any of the retail shops. Regarding the intent of land use regulation in the C -P (Planned Business Center District) - TMC Chapter 18.34. 1. The presence of a zoning district specifically tailored to planned, functionally - integral retail developments suggests that the writers of the zoning code, Title 18, envisioned the need to promulgate• specific constraints and,flexibilities to enable the city to respond appropriately to this type of development. I believe that the writers of the zoning code perceived a difference in the manner in which shopping malls are patronized as opposed to more common "strip - type" commercial centers which lack a unified and organized development form. Chartwell Development o. Attn: Kenneth Chauncey • Page 3 14 February 1980 Shopping malls offer a high quality retail environment which often include several vendors of the same general product, inviting compari- son shopping. Protection from harsh weather conditions afforded by the climate- controlled mall invite shoppers and browsers to linger. To some, the mall area itself is a source of private entertainment, offering a place to rest and /or to "people- watch ". On- the -mall cultural and display activities have already been mentioned. 2. The parking ratio of spaces to floor area is greater in the C -P district than in any other retail zoning category. It is conceivable that the writers of the C -P zoning ordinance envisioned the need for more parking in this district, anticipating that the functionally- integrated shopping . center might attract more traffic and experience slower turn-over in occupancy of parking spaces than is the case in . conventional retail configurations. Also, the region- serving scale of a shopping center such as you propose-attracts customers from a wide market area, again necessitating an increased parking requirement. The foregoing material has been offered so that you may better understand my thoughts behind the crucial decision to require rezoning of the Tukwila City Center site. I understand from Mr. Cinnamon of your organization that Chartwell wishes to appeal my decision to the Tukwila Board of Adjustment, . in accordance with Tukwila Municipal Code Section 2.76.070. I commend you for your decision to follow the orderly appeal process provided by the City, and will work with you to obtain a decision from the Board as quickly as possible. Please be assured that my decision to require rezoning of your project site at this late stage of the processing sequence has been difficult to reach. I take no joy whatever in raising a potential roadblock to implementation of the City Center pro- ject. Also, you should understand that the rezone decision is largely a "housekeeping" matter, and does not in any way reflect on the quality of your design concept. cc: Mayor City Attorney Wilsey & Ham, Inc. Sincerely M Caughey Acting Planning Director �11LA 114,4"p s City PTukwila j D Z . � 6200 Southcenter Boulevard a Tukwila Washington 98188 • 1909 Frank Todd, Mayor TO: FROM: DATE: SUBJECT: File Fr Satterstrom, Planner 11 F bruary 1980 CHARTWELL /ZONING ORDINANCE (PROPOSED) MEMORANDUM Mark Caughey and I met with City Attorney Larry Hard at his office on the morning of 7 February 1980. The following topics were discussed: 1. Chartwell waiver application /D.E.I.S. Established that the City had basically two options as far as the draft E.I.S. on the Chartwell project is concerned: 1) do a completely revised draft E.I.S. (pursuant to WAC 197 -10 -495), or 2) complete a very comprehensive final E.I.S. which responds to criticisms raised. This is the responsibility of the Responsible Official. It was brought out that the two major issues at this point are the zoning question and the issue of the adequacy of the draft E.I.S. Insofar as the zoning issue is concerned, it was generally agreed that the question of whether a shopping mall is allowed the C -M zone should be made by the director of planning and Chartwell should be notified immediately. Any appeal to the Board of Adjustment for a resolution of interpretation should be requested by the applicant, i.e., Chartwell. It was also generally agreed that it was the duty of the Responsible Official to analyze the proposed Chartwell project with respect to the guidelines establsihed by Resolution #656. 2. (Proposed) Zoning Ordinance City Attorney generally felt that adoption of any proposed zoning ordinance (which differed from the existing code in its land use regulations) may have varying applicability because of certain re- zoning actions which have/taken place in the past. Generally established that 1) passage of new zoning code will not adversely affect any existing use in existence at the time of adoption; and 2) certain rezones which the City has executed may be likened to "contracts" which may not be unilaterally repealed by passage of a new zoning ordinance; and 3) rezones which merely have a list of conditions attached to them may not "vest" any rights to build under that zoning • designation except where an application for building permit has been applied for. 3. Other City Attorney requested to be informed of any draft E.I.S. issued by the City, all negative declarations made, and any proposed ordi- nance which was in the works.. FS /mkb cc: Acting Planning Director City Attorney Mayor sy City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 1909 Frank Todd, Mayor rt TO: FROM: DATE: SUBJECT: MEMORANDUM Mayor Todd, Kj ell Stoknesc' =�7z� u' 28 January 1980 ZONING INTERPRETATIONS This memo is to follow -up on my earlier memo to you relating to my resignation consistent with our earlier discussions. As a result of my resignation and the high probability of my working for the Chartwell Development Company, I feel certain actions that I took as a city employee should be reviewed, even though at the time these actions took place I had, no knowledge regarding Chartwell's interest in using my services. Based upon this, I'am requesting you to reassess the following actions or decisions that I made as the Community Development Director as it relates to my interprative authority of the city's zoning code, and as the Responsible Official under the State Environmental Policy Act as it relates to the contents of the preliminary environmental impact statement as follows: 1. Whether or not an enclosed retail shopping mall is allowed in a C -M zone. (Please find attached Fred Satterstrom's interpretation of 13 September 1979 to which I agreed, and my interpretation of November 16, 1979 in which I reversed . that interpretation. This relates to whether or not a re- tail shopping mall is an allowed use in a CM zone.) 2. Parking for the retail facility portion of the development shows in the preliminary environmental impact statement as requiring 2.5 parking stalls per 1,000 square feel of retail area. However, they must demonstrate they meet the actual demand for parking. The 2.5 per 1,000 sq. ft. for retail was used rather than the 5.5 per 1,000 parking requirement for shopping malls. 3. Other actions /decisions that I am not aware of relating to Chartwell that other city staff may recognize. (Fred and Mark would be your best sources related to this.) As I mentioned earlier, I have a clear conscience on the above items in that I had no knowledge regarding my potential of working for Chartwell at the time these decisions were made. This is not my concern. My concern is related to how it would appear to`look. • Memo to Mayor Todd Zoning Interpretations Page 2 28 January 1980 On this basis, I am requesting that you reassess the decisions /actions stated in this memo in an objective manner and reach your own inter- pretation on the above items. The results of your decisions, however they turn out, should be reflected in the final environmental impact statement as the city's position. I feel what is requested in this memo is essential to all parties con- cerned. KS /mkb Attachments cc: Larry Hard Mark Caughey PARKING • 1 The present zoning requires the following provision of parking: Commercial: (18.56.170) Office: (18.56.160) Hotel: (18.20.070) 1/400 GFA (Gross Floor Area) 3.1/1000 GFA, or 4.0/1000 GLA (Gross Leasable Area in square feet) 1 /Bedroom, plus adequate parking for special eating, banquet, or entertainment facilities. The parking for restaurants, banquets, and entertainment is contradictory in the present code (18.56.110). . Other places of public assembly: 1:5 persons . Under Clause 18.56.112(c), dance halls, and theatres shall be provided with one car stall /4 persons, with each person to 7 net square feet of the room or space used for such purposes. Under Clause 18.56.112(e), Other Places of Public Assembly, the method of calculation of the number of people is stated as being the higher of either the seating capacity or the total net floor area in square feet divided by seven.. On first impressions these formulae could be assumed to apply to all eating, banquet, or entertainment facilities. An interpretation of Clause 18.20.070, however, does leave an area for interpretation where it states "special eating, banquet, or entertainment facilities." The developer believes that the words adequate parking for special imply parking for facilities larger than those that would be supported by hotel guests only. . Table X shows the number of parking stalls required by the code. TABLE X. PARKING REQUIREMENTS BY CODE USE REQUIREMENT AREA /NO. NO. NEEDED Retail: 2.5/1000 GSF 800,000 GLF 2,000 Office: 3.1/1000 GSF, or 600,000 GSF 1,860 4.0/1000 GLSF Hotel: / 1 /room 775 rooms 775 1 /5..seats in-restaurant's/bars 825 seats say ' 1/5 seats in meeting rooms 800 seats say 165 160 TOTAL 4,960 Lmwn Dins uooa cnr-jcaTneralo 1. • • TABLE 2 PROPOSED PARKING USE Retail: Office: REQUIREMENT AREA/NO. NO. NEEDED 4.5/1000 800,000 2.5/1000 3 ,600 600,000 ' Hotel: .Rooms 0.75 /Room 775 .Entert. /Eating 75% of 1/75 sq. ft. 6825 sq. ft. .Meeting 1/150 sq. ft. 10,000 sq. ft. .Admin. 3.1/1000 sq. ft. 4000 sq. ft. .Employee 1 /employee 100 say 581.2 68.3 .66.6 12.4 100.0 TOTAL BY CALCULATIONS 5,928.5 TOTAL PROPOSED 6,000. From the discussion below it will be seen that the Retail and Office spaces are based on recent studies by the Urban Land Institute and the firm of Barton- Aschmann, and the Hotel space on the basis of a variance recently granted to Double Tree Inn Annex on an adjacent site. Generally the proposal is generated on the basis of the new recommendation of 4.5 parking spaces. per 1000 GLA for shopping with the knowledge that employee parking can use office parking for major shopping days which are usually on non- office days; greater use of car pools and public transit for office workers as discussed in TRANSPORTATION, and, the Double Tree waiver. DISCUSSION ON PARKING PROVISIONS Shopping Center Over the last few years the rates-Tor parking provisions have been reviewed extensively for shopping centers of 800,000 GLA and more. Review of shopping centers has been done specifically by the Urban Land Institute (ULI) in its Technical Bulletin 69: Shopping Center Zoning (1973) and by the traffic engi- neering firm of Barton- Aschmann for maximum parking days. Thanksgiving to Christmas were studies for the years 1973, 1974 and 1975 at 32 centers over 800,000 GLA. The present "industry standard" of 5.5/1000 GLA was based on .: 1965 I study: "Parking Requirements for Shopping Centers, Technical Bulleti 53." In 1965 only 12 of the 270 shopping centers surveyed were over 800,000 GLA (73 total according to "Chain Store Age ", May 1966) , whereas recent estimates by "Shopping Center World" showed 249 in U.S.A. and Canada. m wn wooc 2. For some years now it has been known that much of the demand, and in many cases even the peak, was less than 5.5 vehicles per 1000 GLA. It still appeared, however, that the pre - Christmas period generated the highest demand, and most parking happens between 1 pm and 4 pm Monday through Sunday. . The Barton and Aschrnan :study, reported ` in -ITE Journal, September 1978, and Shopping Center World, August, October and November 1976, collected three types of data: . Daily retail sales volume for one year. . Daily inbound shopper traffic (full year or pre- Christmas). . Hourly and daily peak parking accumulation. Analysis of this data indicated that peak parking demands would most likely occur from 1 pm to 4 pm between Thanksgiving and Christmas, particularly on the Friday following Thanksgiving and the Saturdays between Thanksgiving and Christmas. Less than eight percent of centers surveyed showed a parking accumulation that exceeded or equalled 5.5 vehicles per 1000 GLA, 39% fell between 4.0 and 5.0, and nearly 32% were less than 4.0. The average parking accumulation of counts was 4.4 for the study period, during which • 8 of the highest traffic days of the year occured. The study concluded that 75% ofd parking accumulation observed during the 1973, 74 and 75 highest sales days had a;peak; daily parking value of 5.0 or less vehicles per 1000 GLA.(1976 data was confirming-these results).. And, even on those days, the peak period was for only three hours for those centers exceeding 5.0 per 1000 GLA or 0.1% of approximately 3,600 annual hours of operation. - The recommendations included: . 5.0 parking spaces per 1000 GLA, in general, a valid maximum as a basis for current planning for new, existing, and expanding regional shopping centers which have a GLA greater than 800,000 GLA. A reduction to 4.0 spaces per 1000 GLA is recommended in cases where employee owned vehicles can be directed by prior agreement to "off- site" parking facilities during peak shopping periods such as Thanksgiving - to - Christmas period, pre- Easter, Mothers Day, and other peak sales days. (This directing of staff parking could reduce by another 1.0 to 1.5 spaces per 1000 GLA the provision of parking, i.e., to 3.5 to 4.0 per 1000 GLA.) Alternatively, if a higher rate of spaces per 1000 GLA is provided, compatible or ancillary development that could occupy surplus parking include: public and private offices; movie theaters; hotels or motels; freestanding beverage or speciality food stores; and drive -in banks. The 1973 ULI study found similar indications that the 5.5 per 1000 GLA may be becoming excessive. Page 26 states: twn DaSMS . WOOC 3. "Office space usage up to 20% of the GLA can be added . to the center's complex without increasing the parking space demand. Where there is a significant volume of walk -in customers or arrivals by means of public transit ... then the parking demands can be reduced accordingly. "...The findings lead to the following general conclusions: off- street parking needs have been overestimated by shopping center developers, ' lenders and tenants; similarly, off - street parking requirements are excessive in many zoning ordinances." Hotel The hotel represents an. unusual circumstance. As exposed by the application for variance by Double Tree Inns for their expansion presently under construction, an hotel complex is a multiple use facility with particular arrival patterns of guests. . Because of the proximity to Sea Tac International Airport, many guests will arrive bytaxi and limousine. . Many patrons of the meeting space /banquet facilities will be guests • of the hotel and /or arrive by air for the one day meetings. . Many patrons of the cafeteria, restaurant and cocktail lounge will be guests of the hotel or shoppers to Tukwila City Center. . Hotel occupancy falls off sharply for Friday, Saturday and Sunday nights. On this basis it is considered appropriate to assume a similar variance for hotel parking to that granted the Double Tree Annex on September 1,1977, that is: Rooms: 0.75 /room Meeting Rooms: 1/150 square feet of net meeting room space (800 -1000 seats) Eating /Entertaining: 1/75 net square feet x 75% Administrative Offices: 3.1/1000 square feet Employees: 1 /employee Present assumes provisions in support of 775 rooms: Restaurant: Coffee: . Lounge /Bar: Meeting: Linn pa res ' (.4),�o DcY21r. 175 seats @ 15 ft /seat = 2,625 square feet 125 seats @ 10 ft /seat = 1,250 200 seats @ 15 ft /seat = 3,050 _ = 6,825 square feet 1000 seats @ 20 ft /seat = 20,000 square feet 4. Office Space The large amount of proposed office space (600,000 square feet) will accommodate between 2,400 and 3,000 employees. This number of employees is expected to attract an enlarged public transit service and a greater amount of car pooling, as well as provide an on -site market for the shopping center and the hotel. It is also considered that the pattern of staggered office hours will continue, and, looking into the future, the energy conservation arguments will increase the practice of four day work weeks. nrrwn Haas u-c r�or�o oc o.n 5. N s�Y ` y'� -�� - 316- lielw 4 4 to m `J z Z. 0 c)— 00 V L • xt 0 0 N L 0 - • - - - - V . �D J °'o., oy ek, eh % � s c y � a Q- 1 ' 4 ( " 6 - r \c!- <a s CP°1 II.> \*40 ca. .�• 8 '74,•'. • te �c. H Z 4i ct w Z C. tG W c ; o tti .•t • OR=AU 1-. Mile .-`! n..:...a/.. '""i.... 212--' - : ; alintleiffse=teallialWILMeleilirellaWir El USIBINia= MIME .�1 . _y- „ tsaasssns aala/'4- ._. :+ -1.4.-4.-I - ±-4-.- =Li aflfi a///f =MI is .--e.... » er= wafaEww! - t --. -»- t . . INE=Wal ;. MP _ rai • a 1 a/s/a/aY"s wif a= Cesn aallI /f/faII IISS/afaaiaf r'iai i° suass aaa/a Wye? 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NS ill mamas fass!•alflfam • a rmr.. mums .i si o:= 4' asaaaaaflaasssa�, at. if/ s., i/.. -rasa I' _ "�fa•ass!alaaaiaa /r�ai. �r,.a.Af •a"••" ass mf+t� ss�r'wses i mp•fas' iaiiwii* afsf masseuses* _J1m ille•S• UMW, a q=faalauaasu gisosua sa//daoaaaaiasa SOWS W/1smaau.v G1i/a sass ``..fr °_ •mazs`#aaa�i�a..'�!�i ... • • -•_ -• }y Frei IRaaaa/af1 v .. • ■ �N•R +1 a U? 1 l 1. ,�1uuaf aawae WO aa • a/ • a- OM. assn NOW' • MI LIM MSS aas• • /7E- -77-f o a P -4.6 /.37.) PR-o`n a 1 o0JS Ifs P -o rod 13 y tb �c�.o-Au�e, • V S P+4oui S t o►J • Alet--/t-Aftee. iJ° N? Pfcovn c R rA- LS,S A OoD GLSF af70 driEr 44co 0?-17-1e-c; 0 /I oao . G -c.S-c- U P TO t60 vrno GI.Sf 0 G•' /10:Tz)GxF 20 ooi- boo,CGtF IZ40 - -_ 1-'07e-Le '0.75 ►zzvwv• 775 RAD-o s ' 53 0 f• —6?-2.- arm /aa'wb0 9-7----. 1- ::.: 1'::, •. ", : : : I .... :j .:: ., ::.: ,. ; :: ' ..,: . :It . ,., J ::: :: ,.: ,' .. • ,,. ! i. ?t'1 • i,i1 { 11ti ,; :. 1 ;.' , { • ! ... ; :. •;, J i :. i • ti :, .J 1-. :: � i ÷± :, }i. ,jt• y ilit ;j,i•�,I,t j • •; ,t• _1- J.-4 • i .,'' "i i City of Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of Community Development Wilsey and Ham, Inc. Central Park Building 1980 112th Ave. NE Bellevue, WA. 98004 Attn:- Ron Ubaghs. Re: Comments Received - "Tukwila City Center" Project DEIS W & H File 3-317-01020-39; Tukwila File EPIC-18-79-54 • Accompanying this letter are copies of all written comments received by the City of Tukwila relative to the subject. Draft Environmental Impact Statement. This material is transmitted to you for purposes of preparing a summary of the comments and responses thereto,as required by WAC 197 -10 -580. The summary/ response doctunent,,when complete, should be returned to the responsible official for review prior to circulation. Please note the following relevant information: ;:1) Mr. Kjell Stoknes, 0.C.D. Director and designated Responsible Official for the lead agency has resigned his position with the City; as of 21 January 1980, I have been .designated . by the Mayor as Acting Responsible Official for all matters pertinent to the Chartwell Project. This change should be noted for the record. On 18 January 1980, a petition prepared in. accordance with WAC 197 - 10- 480(2b) was received by the lead agency. The City Attorney has determined that a public hearing on the DEIS must be held within the 51 -day time frame prescribed by SEPA. Accordingly,- said public hearing will be advertised for the evening of ..February 4,:1980. It is expected that the comments received at the hearing will be analyzed by your firm in the aforementioned summary/response docu- ment.— . The following is an inventory of the sources and extent of written comments' received. If you find any discrepancy between the inventory and the accompanying material, please contact me as soon as possible. STATE OF WASHINGTON Dixy Lee Ray Governor • • DEPARTMENT OF TRANSPORTATION KF 01 Highway Administration Building, Olympia, Washington 98504 r 206/753 -6005 J • January 21, 1980 c,TV O' „,” Mr. Kjell Stoknes, Director Office of Community Development City of Tukwila 6200 Southcenter Blvd. Tukwila,. Washington 98188 Dear Mr. Stoknes: JAN 2 4 1980 City of Tukwila Tukwila City Center Draft Environmental Impact Statement The State Transportation facilities in this area are already overloaded. This project will place a burden on the facility that will be intolerable. It is mentioned in the document that improvements to the intersection of SR 181 and Strander Boulevard and the I -405 corridor will be needed to help mitigate this increased traffic. The Department has a project under considera't'ion for an HOV lane on I -405, but this project will take care of an existing problem; it is not meant to be used to promote future growth. The Department has no plans in its Six Year Program to develop these facilities to handle any more traffic. The Department recommends that the City of Tukwila and the developer make appropriate arrangements for funding any improvements that may be needed as a result of traffic generated by this proposal. We do have a problem about the effect this proposal will have on our facility per- taining to air quality. Since this project is in a nonattainment area, any improve- ments to our facilities needs to satisfy the clean air act, and the State Implement- ation Plan. Since this project relies on our facilities, we feel the document should address what the effects this project will have on our facility pertaining to air quality. If you have any questions, please call me at 753 -3811. RSN:fih WPA /WBH cc: J. D. Zirkle /T. R. Burke Russell Albert Environmental Section Sincerely, ROBERT S. NIELSEN Assistant Secretary for Public Transportation and Planning By: WILLIAM P. ALBOHN Environmental Planner ONCE MEMO CITY of TUKWILA TO: �J E. L L FROM: DATE: SUBJECT: /z -ZS- 79 10 RAW I. v Z1 fo /74v Tzqiv5 P. IEs rTor2 er.sic 4W 124./ 1 'ae4•9/,( t, cjEc. oz, Mx.. w/U 6 eg,tjuesov7 SITE 'FA 3, P. 17 r eu VrIM6 4Npt7+ 2. .l ei T Acvraw 0/441c/Far Slat °gear "ePoKT 3. 1 to A/or FREE P)sm ,U44)y Dc-Toe as/c usroavf , '.tc#a+o -Tv Wee Si- jk& gprre.l P4cr�.s 22- 3i . $rrc , 6( iuci LILC To SEE , sa 1 „ri,e .017r.,e ©mvs l%sai ss$o > z Pic, 61 p• 3Z. 5. 116.0 Acs der.vee t AssaRz hvegaRoa 4,7 Cr-e.40.% 4s arr..c.ao ? 4 lZTI , Awses 6. 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A / 0 icoeztof C /°off yo7 X 1 • r January •1979 7 :00 P.M. r -• FLAG SALUTE AND CALL TO ORDER ROLL CALL OF COUNCIL MEMBERS OFFICIALS IN ATTENDANCE MINUTE APPROVAL VOUCHER APPROVAL !xnin1t TUKWILA CITY COUNCIIL • Regular Meeting MINUTES 0;5 66 Tukwila City Hall Council Chambers Mayor Bauch, presiding, led the Pledge of Allegiance and called the Regular Meeting of the Tukwila City Council to order. LIONEL C. BOHRER, MABEL J. HARRIS, GEORGE D. HILL, J. REID JOHANSON, DANIEL J. SAUL, DWAYNE D. TRAYNOR, GARY L. VAN DUSEN, Council President. LAWRENCE E. HARD, City Attorney; KJELL STOKNES, OCD Director; MAXINE ANDERSON, City Clerk; JOHN MCFARLAND, Administrative Assistant; TERENCE MONAGHAN, Public Works Director. MOVED BY VAN DUSEN, SECONDED BY SAUL, THAT THE MINUTES OF THE REGULAR MEETING OF JANUARY 2, 1979, BE APPROVED AS PUBLISHED. MOTION CARRIED. MOVED BY VAN DUSEN, SECONDED BY HARRIS, THAT THE VOUCHERS BE ACCEPTED AND WARRANTS BE DRAWN IN THEIR RESPECTIVE AMOUNTS. MOTION CARRIED. BID OPENINGS AND AWARDS Call for Bids: Street Improvement Project (So. 147th 4 b 56th So.) Agenda Changed Election of Council President ORDINANCES Ordinance 11095 - Add certain sections of Title 9A RCW Final Expenditures for 1978: Claims Fund Vouchers #1547 - #1592 Current Fund Golf Crse.Spec. Rev. Street Fund 'Land Acq,Bldg,Dev. Golf Acq. Water Fund Sewer Fund 1547 - 1577 $ 8.594.62 1578 - 3,300.00 1579 - 1583 1,314.23 1584 - 1585 326.68 1586 - 350.00 1587 - 1588 2.294.75 1589 - 1592 85.97 16,266.25 First 1979 Expenditures: Claims Fund Vouchers #1593 - #1730 Current Fund Street Fund Fed. Shared Rev. Land Acq, Bldg, Dev. Water Fund Sewer Fund 1593 - 1711 $ 35,920.05 1712 - 1720 76,674.00 1721 - 7,023.15 1722 - 23,431.50 1723 - 1726 1,149.24 1727 - 1730 11,547.61 155,745.55 MOVED BY VAN DUSEN, SECONDED BY HILL, THAT COUNCIL CALL FOR BIDS FOR THE STREET IMPROVEMENT PROJECT ON FEBRUARY 13, 1979. Project includes improvements to South 147th Street and 56th Avenue South. MOTION CARRIED. MOVED BY TRAYNOR, SECONDED BY VAN DUSEN, THAT THE AGENDA BE AMENDED TO INCLUDE THE ELECTION OF THE COUNCIL PRESIDENT. MOTION CARRIED. Councilman Van Dusen thanked the Council for cooperating with him as Council President. MOVED BY VAN DUSEN, SECONDED BY TRAYNOR, THAT COUNCILMAN "BUD" BOHRER SERVE AS COUNCIL PRESIDENT FOR 1979. MOTION CARRIED. MOVED BY VAN DUSEN, SECONDED BY SAUL, THAT THE PROPOSED ORDINANCE BE READ BY TITLE ONLY. MOTION CARRIED. City Attorney Hard read an Ordinance amending Ordinance 989 to add certain sections of Title 9A RCN and repealing Ordinance Nos. 727, Sect. 21; 745, Sect. 30; and 828. TUKWILA CITY COUNCIL, REGULAR MEETING January 15, 1979 • Page 2 • CtORDINANCES - Cont. Ordinance 01095 - Add certain sections of Title 9A RCW MPPOINTMENTS Board of Ad- justment: Mrs. Rudolf Regel MOVED BY VAN DUSEN, SECONDED BY HILL, THAT ORDINANCE NO. 1095 BE ADOPTED AS READ.* Councilman 8ohrer asked Attorney Hard to explain the procedure •on how this ordinance works. Attorney Hard said he is satisfied with the ordinance as it is now. It is proper in every respect. Ordinance No. 989 adopted changes in the Criminal Code made by the State Legislature. Section 4 of the ordinance says that these criminal acts will be considered misdemeanors in the City of Tukwila. This ordinance adds additional crimes to the list. It Specifically states that these are all to be considered crimes in the City of Tukwila. The City is only empowered to assess a penalty of $500 or 6 months in jail. It does not have the power to penalize anyone for more than a misdemeanor. Councilman Bohrer said his concern is we are adopting definitions but are - not making them illegal. Attorney Hard quoted from Ordinance 989 which says "Any person violating any of the provisions of this chapter whether defined as a felony, a gross misdemeanor, or a misdemeanor shall be guilty of a misdemeanor." *MOTION CARRIED. Mayor Bauch's letter recommending M'rs. Rudolf Regel, 14201 56th Avenue South, for appointment to the Board of Adjustment . was read for the record. MOVED BY VAN DUSEN, SECONDED BY HILL, THAT COUNCIL CONCUR WITH THE MAYOR'S APPOINTMENT OF MRS. REGEL TO THE BOARD OF ADJUSTMENT. MOTION CARRIED. PETITIONS, COMMUNICATIONS, APPEALS AND SIMILAR, MATTERS Claim for Damages: George Armour Claim for Damages: ,Ms. Marla Beaty Waiver Request by Chartwell Dev. _-• Corp. (Tukwila Pond Site) - • John McFarland, Administrative Assistant, reported that Mr. George Armour has filed a claim for damages against the City in the amount of 55,000.00. The basis of the complaint is a charge of false arrest. Investigations by Mr. Jim Crook of Miller & Morris, Inc., loss assessors for the City's insurance carriers, reveal no liability on the part of the City or Police Officers involved. Mr. McFarland recommended the claim be denied. MOVED BY VAN DUSEN, SECONDED BY HARRIS, THAT COUNCIL DENY THE CLAIM. MOTION CARRIED. Mr. McFarland explained that one of the Police Officers accidentally hit the side mirror of a parked vehicle and it was broken. Ms. Marla D. Beaty has filed a claim for damages in the amount of 57.43. MOVED BY VAN DUSEN, SECONDED BY HARRIS, THAT COUNCIL AWARD THE CLAIM FOR DAMAGES IN THE AMOUNT OF $7.43. MOTION CARRIED. Mayor Bauch reminded the Council that the request for a waiver and the requirements of Ordinances 1035 and 1053 only involve the treatment of the pond which is the environmentally sensitive area. Resolution 0656 provided the guidelines for the development of the pond. This was passed before the purchase of the property so the purchasers were aware of the guidelines. The interpretation of 656 becomes a staff function. If there is a difference of opinion, the developer can go before the Board of Adjustment. If this is not satisfactory they have the option of going to Court. When the final waiver comes back to Council, they will then determine If the development is essentially the same as that which was in the preliminary plat. TUKWILA'C COUNCIL, REGULAR MEETING .January 1 979 Page 3 • °ETITIONS, COMMUNICATIONS, APPEALS AND SIMILAR MATTERS - Cont. C 'Waiver Request by Chartwell Dev. Corp. (Tukwila. Pond Site) Criteria #1 Criteria #2 Council is not here this evening to review the details of the buildings or whether they are allowable within the zoning and building codes of the City. The discussion should be held to the treatment of the environmentally sensitive area. Councilman Bohrer expressed concern over three items: 1 - Resolution 656 says the development should provide visual access from Strander Blvd. and Andover Park West and there is not direct visual access provided. He suggested moving the hotel currently planned for the southeast corner of the site to the southwest corner. 2 - The contour of the pond gets nearly totally reconstructed and there is the creation of an island. He suggested that maybe the island should not be created and leave the nesting ground essentially in its current location. 3 - The proposal does not leave quite 1/3 of the area in natural form. It appears to be . more like 1/4 (9 acres) of the site. Councilman Van Dusen reminded Council that any type of construction is going to interrupt the wildlife for a period of time. He also agreed that the 1/3 natural area should be retained. The proposal, as it is now, has 7.25 acres for the surface area of the pond. .75 acres for the island, 4 acres designated as wetlands and 4 acres of landscaping for a total of 16 acres. Mayor Bauch noted that the resolution says to "encourage" visual access from the street. He called attention to Section 7 which says the southeast corner of the site will be retained. The proposal will have to be changed to meet this requirement. Attorney Hard said that Council does have to go through all five of the criteria on the waiver checklist the same as for any other property in the City. Fred Satterstrom, Planning Associate, indicated the area to be voted on is the pond and wetlands -- excluding the fill area. MOVED BY VAN DUSEN, SECONDED BY SAUL, THAT COUNCIL VOTE YES ON CRITERIA #1. Does the proposed action represent a unique condition which is not significant in scale? ROLL CALL VOTE: BOHRER - NO, the project is significant in scale. HARRIS - YES, the pond area should be 1/3 of the development and this is not a significant difference. HILL - NO, a development of this magnitude has to have an impact. JOHANSON - NO, there is a significant impact on the wildlife in the area. SAUL - YES, the development of the pond and wetland will enhance the whole project. TRAYNOR - NO, it is significant. VAN DUSEN - NO, definitely significant. 5 - NO; 2 - YES. MOTION FAILED. MOVED BY VAN DUSEN, SECONDED BY HARRIS, THAT COUNCIL VOTE YES ON CRITERIA #2. Has the applicant investigated reasonable alternatives available which would not require a waiver?* Mayor Bauch noted that previous discussion showed there were no situations that would not require a waiver, therefore, this one is not applicable. • • ,TUKWILA CITY COUNCIL, REGULAR MEETING January 15, 1979 Page 4 ',fTITIONS, COMMUNICATIONS, APPEALS AND SIMILAR MATTERS - Cont. Waiver Request by *ROLL CALL VOTE: Chartwell Dev. BOHRER - NA Corp. (Tukwila HARRIS - NA Pond Site) HILL - NA JOHANSON - NA Criteria #2 SAUL - NA TRAYNOR - NA VAN DUSEN - NA Criteria #3 Criteria *4 Criteria #5 MOVED BY VAN DUSEN, SECONDED BY SAUL, THAT COUNCIL VOTE YES ON CRITERIA #3. If the request for waiver involves building, grading, clearing, excavation, or filling in a geographical area generally identified by the Environmental Basemap as an area of high natural amenity or development constraint, are mitigating measures provided ?* Councilman Johanson asked if Chartwell has agreed to move the building from the southeast corner. Mayor Bauch said they have to comply with Resolution 656 and it says they will have to move it. *ROLL CALL VOTE: BOHRER - NO, mitigating measures are provided but the wording should read "are sufficient mitigating measures provided." HARRIS - YES, mitigating measures are provided and it does not ask if they are sufficient. HILL - YES, mitigating measures are provided - -if they move the hotel. - JOHANSON - N0, question the amount of water and wetland area. SAUL - NA TRAYNOR - YES VAN DUSEN - YES 4 -YES; 2 -N0; 1 -NA MOTION CARRIED. MOVED BY VAN DUSEN, SECONDED BY SAUL, THAT COUNCIL VOTE YES ON CRITERIA *4. Is the request for waiver consistent with the goals and policies of the Comprehensive Land Use Policy Plan? ROLL CALL VOTE: BOHRER - YES HARRIS - YES HILL - YES JOHANSON - YES SAUL - YES TRAYNOR - YES VAN DUSEN - YES MOTION CARRIED. MOVED BY VAN DUSEN, SECONDED BY SAUL, THAT COUNCIL VOTE YES ON CRITERIA #5. Do the requirements of this ordinance impose a special hardship to a site for which a waiver of the provisions would not necessitate a major policy commitment prior to the adoption of the Zoning Ordinance and Map? ROLL CALL VOTE: BOHRER - YES MILL - YES JOHANSON - YES SAUL - YES TRAYNOR - YES VAN DUSEN - YES HARRIS - YES MOTION CARRIED. TU OLA.CITTCOUNCIL, REGULAR MEETING ..January 15, 1979 Page 5 PETITIONS, COMMUNICATIONS, APPEALS AND SIMILAR MATTERS - Cont. (aiver Request by MOVED BY VAN DUSEN, SECONDED BY SAUL, THAT THE PRELIMINARY Chartwell Dev. WAIVER BE APPROVED ON THE BASIS THAT ALL THE CONDITIONS Corp. (Tukwila OF RESOLUTION NO. 656 ARE COMPLIED WITH:* Pond Site) Councilman Saul asked why the southeast corner was determined to be environmentally sensitive. Councilman Johanson said that during the discussion periods it was determined that this area is used significantly by all the wildlife in the area. This area is still the natural valley floor. Councilman Saul said it is the southwest corner where he has always noticed the activity. Councilman Harris agreed with him. When they took the walking tour she said it appeared to be the southwest corner where the wildlife activity was. Councilman Johanson said he noticed that the southwest corner floods and a lot of the vegetation is dead. Mr. Satterstrom said the southeast corner has the advantages for nesting because most of the year it is surrounded on three sides by water so it is protected from human approach. It appears to be the major area where nesting occurs. The location is not exactly along Andover Park West but off of the road several hundred feet. Waiver Approved . `- RECESS: 8:25 pm - 8:30 pm ORDINANCES Ordinance •1096 - Recognizing the position classi- fications of the commissioned members of the Tukwila Police Department RESOLUTIONS Resolution f669- Authorizing the Mayor to negotiate & execute an ' ;intertie agreement with the City of Kent *MOTION CARRIED WITH JOHANSON VOTING NO. MOVED BY VAN DUSEN, SECONDED BY HILL, THAT COUNCIL RECESS FOR'FIVE MINUTES. MOTION CARRIED. Mayor Bauch called the regular meeting back to order with all Council Members present as previously reported. MOVED BY VAN DUSEN, SECONDED BY SAUL, THAT THE PROPOSED ORDINANCE BE READ BY TITLE ONLY. MOTION CARRIED. City Attorney Hard read an Ordinance amending Section 2 of Ordinance 639 and recognizing the position classifications of the commissioned members of the Tukwila Police Department. MOVED BY VAN DUSEN, SECONDED BY TRAYNOR, THAT ORDINANCE NO. 1096 BE ADOPTED AS READ. MOTION CARRIED. MOVED BY VAN DUSEN, SECONDED BY SAUL, THAT THE PROPOSED RESOLUTION BE READ BY TITLE ONLY.* MOVED BY HARRIS, SECONDED BY HILL, THAT THE MOTION BE AMENDED TO READ THE RESOLUTION IN ITS ENTIRETY. MOTION CARRIED. •MOTION CARRIED AS AMENDED. City Attorney Hard read a Resolution authorizing the Mayor to negotiate and execute an intertie agreement with the City of Kent. MOVED BY VAN DUSEN, SECONDED BY SAUL, THAT RESOLUTION NO. 669 BE ADOPTED AS READ." Councilman Hill asked If this has been approved by the Seattle Water Department.' Terry Monaghan, Public Works Director, . explained that this is one of the criteria before final approval - -to be sure Kent has documented clearance from the City of Seattle. However, Seattle does encourage interties. TUKWILA CITI OUNCIL, REGULAR MEETING 'January 15, 1979 Page 6 (" SOLUTIONS - Cont. Resolution #669 - Authorizing the Mayor to negotiate & execute an intertie agreeemnt with the City of Kent DEPARTMENT REPORTS .'ayor's Report Finance Director's Investment Report MISCELLANEOUS AND Introduction, Carl Carlson, Deputy City Attorney 1 - 'ADJOURNMENT 8:59 P.M. Councilman Harris asked what the rate will be. Mr. Monaghan said it has to be negotiated but will be no less than $.33 per 100 cubic feet charge for water used. The long term use of this intertie is for emergencies.- Mr. Monaghan explained that this intertie is in the same location as the one used this summer to serve Southcenter South. MOVED BY JOHANSON, SECONDED BY. TRAYNOR, THAT ITEM 1 BE 'AMENDED TO READ: "A RECIPROCAL RATE OF NOT LESS THAN $.33 PER 100 CUBIC FEET CHARGE FOR WATER USED." MOTION CARRIED. Councilman Bohrer said he does not feel.the WHEREASES give the background to really reflect what Is happening. MOVED BY BOHRER, SECONDED BY TRAYNOR, THAT.THE FIRST WHEREAS BE AMENDED BY ADDING "TO PROVIDE SUPPLEMENTAL WATER SUPPLY FOR THE CITY OF KENT" AFTER THE WORD 1NTERTIE. THE SECOND WHEREAS BE AMENDED BY STRIKING THE WORD "AN" AND REPLACING IT WITH.. "A LONG TERM ". MOTION CARRIED. *MOTION CARRIED AS AMENDED. Mayor Bauch announced that Pat Lowrey has been elected Chairman of the King County Law and Justice Planning Committee. The Senior Program conducted at Southgate is very successful. He urged Council to visit the meetings and observe the activities. The representative of our Sister City in Japan will be arriving for a visit to Tukwila sometime the first of February. We hope to have him attend a Council meeting. Councilman Harris read the December report of investments submitted by Ron Swanson, Finance Director. Interest Income amounted to $22,239.88. This resulted from interest rates ranging from 9% to 11%. Total Interest Income for 1978 amounted to over $262,000. FURTHER AUDIENCE COMMENTS Attorney Hard introduced Mr. Carl Carlson of the same firm, who represents the City of Tukwila on Municipal Court Business. Council commended Councilman Van Dusen on the fine job he has done as Council President. MOVED BY SAUL, SECONDED BY VAN DUSEN, THAT THE REGULAR MEETING OF THE TUKWILA CITY COUNCIL ADJOURN. MOTION CARRIED. P1 d 641 Mayor y erc •■••ten. ■61 111 , 17 fw$137., Po/ s N›, 1 11,it•—/1•1:1- 1 • :92 Cf. T:111°' —.'"1 • • — "N•seAVq. X.fiv..1.4i,;./ • . •Oki ci• sl as .1 : 1.1 • - • w..• ,,,s 91 1 i;$;4'1// .711t.01060440 ,70 . 11,1*•?'.- 1141 12-24-79 exginir AEROLIST Inc. SEATTLE, WA 98168 /12061 106.5900 58624-6 Ci of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 Edgar D. Bauch, Mayor Gila - caukP. . MEMORANDUM TO: City Council FROM: Nell Stoknes DATE: 19 December 1979 SUBJECT: DRAFT ENVIRONMENTAL IMPACT STATEMENT - CHARTWELL DEVELOPMENT Please find attached the preliminary draft of the Environmental Impact Statement for Chartwell complex proposed for the former City Light properly. As you will recall, this project has received a preliminary waiver application from the City Council. At this point they intend to pursue a conditional use permit for a motel. Due to the complexity of this project and the impracticality of developing construction drawings for all the buildings at the same time, some thought should be given to how they should proceed with applying for a final waiver. Alternatives are: 1. Apply for a final waiver on a building by building basis. 2. Council grants a final waiver on a conceptual plan and defers building by building review authority as to its consistency. The final waiver . to the Planning Commission. 3. Others -- as may be discussed. This memo is for information purposes only. A meeting should be established in the near future to discuss the details of how best to process the project while staying within the guidelines of the waiver process and the resolution guiding the development of the land. KS /mkb Attachment cc: Mayor Cit of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 MEMORANDUM TO: Planning Commissioners FROM: Kjell Stoknes, 0. C. D. Director DATE: 19 December 1979 SUBJECT: PRELIMINARY ENVIRONMENTAL IMPACT STATEMENT - Former City Light Property Please find attached a draft E.I.S. on a major proposed development on the'property south of Southcenter. It proposes 800,000 sq. ft. of retail, 600,000 sq. ft. of office and 600,000 sq. ft. of hotel/ motel. This document will be of value to you since some time in the future you will be sitting in a decision role on some type of permit. This is being submitted to you for information only. No action is requested. When the final E.I.S. is prepared I will make sure you get a copy. KS /mkb Attachment cc: Mayor • WILSEY&HAM Inc. Central Park Building 1980 112th Ave. N.E. Bellevue, WA 98004 Telephone (206)454 -3250 December 17, 1979 File No. 3- 317 - 0102 -39 Mr. Kjell Stoknes Director of Planning City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 O.C.D. CITY OF TUd :tiillA Inc 2 0 sa'(' Earl P. Wilsey (1892 -1957) Toll Free Numbers Everett 353 -8837 Tacoma 572 -9982 Dear Mr. Stoknes: This letter shall serve as an official affidavit that copies of the Draft Environmental Impact Statement for the proposed Tukwila City Center were mailed to the list of recipients attached on December 17, 1979. As requested, copies of the Draft EIS were hand delivered to be distributed to Tukwila's Mayor, City Council and Planning Commission. In addition, fifty (50) copies have been delivered to your office for distribution to other City personnel and for over - the - counter sales. Sincerely, WILSEY & HAM, INC. Ron Ubaghs Associate RAU/p Encl. On this 17th day of December, 1979, Ronald A. Ubaghs personally appeared before me, known'to be the individual described in and who executed the foregoing instrument, and acknowledged that he signed the same as his free and voluntary and deed, for .•- uses and purposes therein mentioned. a ela J Br-d.uw, Notary Public in .and for the State of Washingto, _ residing at Seattle, in King County, Washington: engineering / planning / surveying / environmental analysis / landscape design Offices located in: Bellevue Washington • Tacoma Washington • Portland, Oregon • Foster City, California • Recipients of the Draft EIS Federal Environmental Protection Agency Department of Energy U.S. Army Corps of Engineers U.S. Soil Conservation Service U.S. Forest Service State Office of the Governor Office of Program Planning and Fiscal Management Department of Ecology Department of Fisheries Department of Game Department of Transportation Department of Social and Health Services Department of Commerce and Economic Development Office of Planning and Community Affairs Institute for Environmental Studies Regional Puget Sound Council of Governments Puget Sound Air Pollution Control Agency Seattle -King County Economic Development Council METRO Environmental Planning County Department of Budget and Program Development County Council: District 6, Bruce Laing District 8, Bob Grieve Division of Hydraulics of Tukwila Mayo Cit su . '1 arming Co ion Cities Auburn (Planning Department) Bellevue (Planning Department) Issaquah (Planning Department) Kent (Planning Department) Kirkland (Department of Community Development) Mercer Island (Department of Community Development) Redmond (Planning Department) Renton (Planning Department) Seattle (EIS Review Committee) Utilities /Services Pacific Northwest Bell Puget Sound Power and Light Teleprompter Cable T.V. Tukwila School District Washington Natural Gas Company Libraries Bellevue Library King County Library System Kirkland Library Mercer Island Library Redmond Library Seattle Public Library (Main Branch). Tukwila Library University of Washington Library, College of Architecture & Urban Planning Branch Newspapers Auburn Globe News Daily Journal American Daily Journal of Commerce Des Moines News Highline Times Issaquah Press Kent News Journal Renton Record - Chronicle Seattle Post- Intel1igencer Seattle Times Private Organizations and Others Bellevue Chamber of Commerce Burien Chamber of Commerce Doubletree Inn Greater Renton Chamber of Commerce Kent Chamber of Commerce Olympic Pipeline Company Rainier Audubon Society Mr. Scott Salzer Seattle Audubon Society Seattle Chamber of Commerce M.A. Segale Southcenter Shopping Center Tukwila Chamber of Commerce Tukwila Industrial Council Valley General Hospital Washington Environmental Council • WILSEY&HAM INC. Earl P. Wilsey (1892 -1957) Central Park Building 1980 112th Ave. N.E. Bellevue, WA 98004 Telephone (206)454 -3250 August 21, 1979 File No. 3- 317 - 0101 -39 Mr. Kjell Stoknes Planning Director City of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Dear Kjell: 9glit... 0.C.D. C)TI OF TUK�iitA AUG 2 2 1979 In starting preparation of the Draft EIS for the Chartwell project, we keep the City informed of progress and take the opportunity to receive much as possible. A preliminary list of "Recipients of the Draft EIS" prepared, and I would like to get your initial response to it. If the a standard mailing list for EIS's, we would like to include it at this any interested private individuals or organizations you feel should be the Draft,and the proposal. Thanks for your help. Sincerely, WILSEY & HAM, INC. Pamela Bredouw Planning Research Coordinator Toll Free Numbers Everett 353 -8837 Tacoma 572 -9982 wanted to input as has been City has time, or aware of /P encl. d( engineering / planning / surveying / environmental analysis / landscape design Offices located in: Bellevue Washington • Tacoma Washington • Portland, Oregon • Foster City, California � "wwW " � \- -�` w'F .I.:..s..vf.:vT : r'.fti',ea: i 'Y .• Recipients of the Draft EIS Federal Environmental Protection Agency Department. of Energy U.S. Army Corps of Engineers U.S. Soil Conservation Service. U.S. Forest Service State Office of the Governor Office of Program Planning and Fiscal Management Department of Ecology Department of Fisheries Department of Game Department of Transportation Department of Social and Health Services Department of Commerce and Economic Development Office of Planning and Community Affairs Institute for Environmental Studies Regional Puget Sound Council of Governments Puget Sound Air. Pollution Control Agency Seattle -King County Economic Development Council METRO Environmental Planning County Department of Budget and Program Development County Council: District 6, Patricia Thorpe District 8, Bob Grieve Division of Hydraulics City of Tukwila Mayor Edgar D. Bauch City Council: George D. Hill Mabel Harris L.C. Bohrer J. Reid Johanson Dan Saul Gary L. Van Dusen Planning Commission: John Richards Joseph Orrico Eileen Avery Gerald James Leo Sowinski Richard Kirsop Steve Welsh 171X216 PN�.t,ps Cities Auburn (Planning Department) Bellevue (Planning Department) Bothell (Department of Community Development) Clyde Hill (Planning Commission) Hunts Point (Planning Commission) Kent (Planning Department) Medina (Planning Commission) Mercer Island (Department of Community Development) Redmond (Planning Department) Renton (Planning Department) Seattle (EIS Review Committee) Yarrow Point (Planning Commission) Utility /Services Pacific Northwest Bell Puget Sound Power and Light Teleprompter Cable T.V. Tukwila School District Washington Natural Gas Company Libraries Bellevue Library King County Library System Kirkland Library Mercer Island Library Redmond Library Seattle Public Library (Main Branch) Tukwila Library University of Washington Library, College of Architecture & Urban Planning Branch Newspapers Daily Journal American Daily Journal of Commerce Renton Record - Chronicle Seattle Post - Intelligencer Seeattle Times Pri1va'ue0O gani zaatt�isons and Others Bellevue Chamber of Commerce Burien Chamber of Commerce Greater Renton Chamber of Commerce Kent Chamber of Commerce Seattle Audubon Society Seattle Chamber of Commerce Washington Environmental Council RablicrAdAb$4410 60uacuwkratopplikg 5eri,c POOL WILSEY&HAM • INC. • Central Park Building 1980 112th Ave. N.E. Bellevue, WA 98004 Telephone (206)/154-3250 August 10, 1979. File No. 3- 317 - 0101 -30 TO: Kjell.Stoknes FROM: Mike Ferris RE: Chartwell Tukwila City Center EIS Pre -Draft Meeting O:C.D. CITY OF TUKWILA AUG i 3 1979 Earl P. Wilsey (1892 -1967) Toll Free Numbers Everett 353 -8837 Tacoma 572 -9982 At our pre -Draft meeting with you and Graham Brawn on July 25th, several points of agreement were reached regarding the scope of the EIS and what data is cur- rently available. To confirm our understanding of the scope to be covered, these points are presented below. o This should be a new EIS, not an updated version of the City Light. EIS although some data from that document can certainly be used. Geology: Just one paragraph needed; use existing data. Soils: Data is available . for adjacent sites. Topography: Existing conditions available in City Light EIS; state filling requirements to desired elevations. Unique physical features: The pond most significant, and City is not satisfied with City Light's discussions. Need additional research on the unique areas' of the pond. Jones & Jones may have looked at ponds in the Green River study, through the King County planning department. Erosion: Needs low coverage, mostly construction impacts (temporary). Accretion /Avulsion: Not applicable. Air Quality: Needs high coverage; tie to PSAPCA standards and how project would comply. First, address the additional traffic expected and resultant pollu- tion, then the heating /cooling systems of the buildings. :.Also address the temporary construction (dust, trucks, etc) impacts to air quality. Odor: Low coverage; just traffic needs to be assessed. Climate: Use a reduced version of available data. Surface water movement: probably none engineering / planning / surveying / environmental analysis / landscape design • Offices located in: Bellevue Washington • Tacoma Washington • Portland, Oregon • Foster City, California August 10, 1979 • File No. 3- 317 - 0101 -30 Page Two Runoff /Absorption: Some retention required underground with a filtration system to take out heavy metals as well as oil and silt (no Tukwila retention Ord.) Floods: There is probably no outlet for the pond, and it's being utilized as a natural detention system for storm water for the area. If the streets flood and drainage backs up, is it possible to connect with the P -17? If the pond floods, what effect will it have upon wildlife? Surface water quantity: What is the relationship between this and groundwater quantity? Surface water quality: Needs water quality measurements before and estimated after development (w /mitigating measures). City Light may have "before" information. Ground water movement: EIS should look at the relationship of ground water to surface water: is it a source of the pond ? ?. Dames & Moore will produce profiles based on their adjacent studies, and may have ground water stratum. Ground water quantity: Probably no wells in the area. Ground water quality: No testing is necessary. Public water supplies: Will be covered in UTILITIES. Flora: Explore the impacts of taking out the trees underwater and making a trail around the pond, like at Green Lake, as opposed to keeping all the vegetation as a wildlife habitat. Flora mostly significant as it relates to wildlife habitat; flora, fauna and recreation of the proposal are all directly tied. Fauna: To what extent will the habitat be retained? Noise: City Light EIS. should have enough data (mostly freeway and airport noise) Light and Glare: Light coverage; mostly due to operation of the buildings. Land Use: Needs high coverage, but difficult to determine the exact uses since tenants are not yet committed. The action proposed is probably a "worst case" situation and will assess those impacts...a proposal any more dense prob- ably.isn't feasible. The EIS should be written to the existing zoning ordi- nance, not the one currently under consideration. Natural Resources: Light coverage. Risk of Explosion: Light coverage. Population and Housing: Light coverage. Transportation /Circulation: Needs high coverage; a key issue. Determine the .traffic volumes generated by each possible land use (by square feet). Coor- dinate w /Terry Monaghan; ENTRANCO study may be considering the Chartwell proposal in their calculations. Discuss transit and possible people mover system. Discuss the type of clientele expected for. hotels (how many bused from airport, using rental cars, or tourist ?). August 10, 1979 0 File No. 3- 317 - 0101 -30 Page Three Economic: A goal of the City's is to avoid having vacant floor space in case of a recession; make this section a macro -level assessment of market demand. Also estimate full demand employment and an estimate of sales per square foot and amount of taxes generated per square foot. Public Services: Low coverage. Discuss the type of construction proposed, and proposed fire prevention system.. Discuss whether facilities will have any private security provision.. For schools, estimate the number of school - aged children living in,the residential units. Energy: Discuss only the amount of energy required by the facility itself, and the proximity of the office uses to retail as an energy saving device. Utilities: The key areas are water, sewer and storm water. Water comes from the Seattle system, and if peak requirements exceed allotment, a fine is paid. Sewer and storm water need some analysis; high coverage. Solid waste would be with a dumpster screened from the public. Also cover Cable Television. Human Health: Low coverage. Aesthetics: High coverage; will be a beneficial impact to the site and community. Recreation: A key issue (pond, trail, etc.); needs high coverage. Arch. /Hist.: A letter needs to be sent to the State for data. Alternatives: Leave it to W &H (perhaps with legal counsel) as to the type of alternatives to be considered. Is "no- action" interpreted as no development at all, or development under existing zoning? Kjell's feeling at this time . is that "no- action" is preservation as is, and "less intensive" would be development under the existing zoning, but W &H should make this determina- tion and address appropriate alternatives. (all office or all retail ?). Other elements: Tukwila's environmental ordinance -has additional elements such as Quality of Life and Neighborhood Cohesion which could be added as an opportunity to promote the proposal. If your understanding of these agreements differs, please contact us as soon as possible. We are currently targeting for a mid - September submittal date of the Preliminary Draft EIS for City review and hope that the City would complete the review within about two weeks. Let me know if you have any additional comments or questions about the EIS. xc: /p , 0 No/ oq.,.‘ .z/do c7,-).z1") 0 7 7 / AL -z+vc/oeid X c • .42 • CO o 0% O .1 .1F0 0 O - _s a_ 0 8 3t 2 J2 C%.1 ro CO t'.. nd pond enwisuonea P,tora Gy►rowid.- 1 -P-8Z. )1veloper lays out plans for Tukwila Pond EIL Frter Active buyer of the_Chart- lopment site in Tukwila's area envisions draining of Tukwila Pond to form a hd on the, property. keloper, however, would (reduce the size of ,the nd to fit: into its tentative :nt 'of four office build- area 'and a. hotel. The plan shows a buffer , of ig between a parking lot Io main streets that border Strander Boulevard and Park West. Construction ver about $1.5 million it. ' Mason Frank, representing the developer, Birtcher, McDonald and Frank Properties of Bellevue, ap- peared before the Tukwila City Council, Tuesday night, to unveil 1a tentative layout for the' site:.Also representing the developer was . Gerald J. Gerron of McKinley Ar- chitects, Seattle. The four office buildings, one perhaps as high as 16 stories, would be built in phases in a diagonal ' running roughly from the northwest corner of the property to the south- • east-. corner. Tukwila Pond would remain in the southwest corner, with an area filled in on the west side,' possibly to accomodate the construc- tion of a hotel. A smaller pond would be dug near the northeast corner of the retail area would be bu:existing pond by• a small. channel. The plan calls for jogging trails throughout the site. A retail area would be built bet- ween the parking lot and the office buildings. Gerron said that the businesses would not compete with Southcenter; located directly north of the site, but instead offer public facilities, and stores to complement. the office buildings. The. developer is considering the. possibility of a skating rink, restaurants' or a movie theater. Councilman George Hill jokingly 'made an apparent reference to Rog- er Forbes, adult movie theater own- er, when questioning Gerron.. "I realize it's a little early in the,. development, but who•do you intend to lease,the theater to ?" Hill asked. Chartwell Development purch- ased the 39-acre site from the City of Seattle in •1979. Chartwell's proposal to develop a $170 million hotel- retail- office' complex on the property met stiff opposition from environmental- ists and members of the council who wanted to protect the pond. The Bellevue firm has obtained an option' to purchase the site from Chartwell Which has been experiencing finan- cial difficulties. Council members appeared to be more receptive to the Birtcher McDonald and Frank proposal which' is smaller in scope than the plan proposed by Chartwell. Developers . have new plans for Tukwila Pond By GREG ANDERSON City Editor The long and stormy history of Tukwila Pond may be about to add yet another chapter. .SS A Bellevue development firm plans to make a presentation to .: Tukwila City Council Tuesday night, outlining plans the . firm has for the pond. Those plans, according -to a partner in the firin,'include a hotel, commercial- retail area and possibly an ice skating rink. The development firm of Birtcher- McDonald-Frank Properties has an * . option to . buy the 39 -acre site from the owner, Chartwell Development Co., according to Bob McDonald. He said his firm has a "long option" on the property to get ques- -' tions about the site answered before a final commitment to buy is made. Financially troubled Chartwell has been trying to sell the property for a year. Chartwell, which' had planned• to build a $170 million hotel- retail- - office complex on the environmen- t tally sensitive site, found itself lost in a maze of municipal regulations regarding development of the site. Smaller scale But McDonald said his firm's plans are on a smaller scale, with emphasis on office space rather than • retail like Chartlwell's concept. He said • office space generates much less traffic than retail - commercial, a W key issue in the Chartwell plans. "Hopefully, our plan will be better. p than the last one from Chartwell," r McDonald joked Friday. "Generally, • F we want to do an office -hotel com- plex with some support commercial. "We want to have our commercial - retail area complimentary to South -, center shopping center, and not compete. We might want to put some restaurants in around an. ice skating. rink, and have a corporate user for . the office space. It's all pretty pre- liminary right now," McDonald said. Pond preserved McDonald said Tukwila Pond would be preserved, "but we don't see it as significant as the last environmental impact statement showed it was." Chartwell Development, whose parent firm is Springridge Invest- ment Co. of Victoria, B. C., 'purch- ased the site from the City of Seattle in 1979 for about $4.8 million. Runoff water from the Southcent- er plain drained into a portion of the 39 -acre site more than 'a decade ago as construction mounted. Eventual- ly, a wetlands habitat was created which covers 14 acres and includes the pond, located just south of -the shopping center. The City of Tukwila, seeking to protect the habitat, placed special development restrictions on the site. But Seattle City Light, which owned the land, claimed the restrictions decreased the market value of the land. In March 1978, Seattle City Light sued Tukwila for $3 million. That suit still is unsettled. Tukwila City Council members will hear proposals from the Bel- levue firm during a meeting at 7 p.m. Tuesday in the council chambers of Tukwila. City Hall. • 1.Secoli4,00:enifisiptied Yd Gio►w iaL- 2.-87. Developer lays out plans for Tukwila Pond By BILL SEIL Staff Reporter A prospective buyer of the Chart- well Development site in Tukwila's industrial area envisions draining water off of Tukwila Pond to, form a • 'second!'pon'd on the; property. 'The rdeveloper,I however, .would probably reduce 'the size of s.the orignal pond to fit: into its tentative arrangement of four office' build= ings, a retailrarea and a hotel' The tentative, .planshowa buffer ,of landscaping between a'parking lot and thetwo main'7streets„that border the. site Strander "Boulevard and ,Adover Park West.. Construction *mild ',cover about $1.5 million square :feet. Mason Frank, representing. the developer, Birtcher, McDonald and 'Frank Properties of Bellevue, ap- peared before the Tukwila. City Council.: Tuesday night to unveil la tentative layout for 'the' site: Also representing the developer was Gerald J. Gerron of McKinley Ar- ,chitects, , Seattle. The four office buildings, one' •perhaps as high as .15 stories, would be built in phases in '4 diagonal running roughly. from th'e"":northwest corner of the property to, the - south- east- ..corner. Tukwila Pond would remain in the southwest corner, with an area., filled -.in on the -west side, possibly to accomodate the construc- tion :of .a hotel. A smaller pond would be dug near the northeast corner of the retail: area would' be bu.existing- pond by • a small. channel. The plan calls' for jogging trails throughout the site: • , A retail area • would be built'-bet= . ween the•>parking..lot and the office buildings. Gerron said • that the busine's'ses would.not compete with Southhenter; located directly north of the site, but instead ,offer public . facilities, and stores to complement . the "office buildings. The. developer is considering the possibility of, a skating rink; restaurants or a movie theater. Councilman George Hill jokingly made an apparent reference to Rog- er Forbes, adult movie theater own- er, when questioning Gerron.. " "I realize it's a little early in the, . development, but who•do you intend to lease the theater. to?" Hill asked. Chartwell Development purch- ased the'39 =acre site from the City of Seattle in :1979: Chartwell's proposal to develop a $170 million hotel- retail- . office complex on the property met stiff opposition from environmental -;• ists- and;members of the council who wanted- to • protect the • pond. The Bellevue firm has obtained an option to purchase the site from Chartwell, Which has been experiencing. finan- cial difficulties: • Council members appeared to be- more. receptive to the , Birtcher; McDonald and Frank 'proposal; which' is smaller in :scope 'than. the plan proposed by Chartwell. • • id LId 1 -1-1 -H—f-- .;1.41 .:1 1 1 1 1 1 11 1 1 1 111 11 1 1 1 1 I.1, Jul �1V dVld ,, 801 H1tiON 1mfM4Artllg. r@YJ4C1 ami.'n -assX M.N..A'.Y- �� {��.'vYt4i.11a'CA I.:'.MWA'•.:/a..i.'VI NS■.•Y•'' 1.4a.“: .r.mM ILet..1aaT IC-at-4W .M.`NG.n..V'•1 j:Jf 'V a �.S l.1rtV. ...^n..�. a. 1.a•: !?..i.J;i..�J+: °• UP STATES DEPARTMENT OF AGRICULTI FOREST SERVICE Mt. Baker - Snoqualmie National Forest 1601 Second Avenue Building Seattle, Washington 98101 REPLY TO: 1950 Review of Other Agencies EIS SUBJECT: Draft EIS Tukwila City Center TO: Kjell Stoknes Director of Planning Office of Community Development 6200 South Center Blvd. Tukwila, WA 98188 DEC 2 6 1979 We have reviewed the Draft Environmental Impact Statement for the Tukwila City Center complex and have no comments. The project is located well away from the National Forest boundary and will have no effect on National Forest Lands. Thank you for the opportunity to comment. 110/frpti-A, JAMIA R. MURRAY Writer - Editor Enclosure • • CITY CENTER D.E.I.S. -- DECEMBER 17, 1979 Subject Areas Requiring More Intensive Analysis The following is a generalized analysis of perceived deficiencies in the content or extent of discussion of various aspects of the City Center DEIS. This analysis is based upon the responsible official's own study of the document and upon the public comments received during the 35 -day circulation period for the draft. These comments reflect generalized areas of concern and are intended to facilitate preparation of a new DEIS for this project based on design guidelines contained in Resolution #736. We have attempted to provide as much specific guidance as possible. However, this document does not preclude the possibility of discovering other potential defects in the December 17 draft nor a subsequent draft or final EIS for this project. This material should serve as reference only, and should not substitute in any way for close intercoordination between the project proponent's EIS consultant(s) and those city of- ficials having professional expertise in a given field of inquiry. 1. PUBLIC SAFETY ISSUES A. Police Services - Expand upon crime potential and its control relative to underground parking facilities. - Justify conclusion that one - -two new officers only will be needed to serve city center complex. Discuss indirect police service demand generated by the project (i.e. due to increased traffic on city streets generally). B. Fire Suppression Services - Provide sufficient information on adequacy of project water supply for fire suppression purposes. - Provide expanded discussion of increased city costs for fire service personnel and equipment both directly and indirectly associated with project (including aid car service). - Discuss steps to be .taken, if any, as part of the project design to enhance fire safety; especially discuss such matters as evac- uation of occupants from "high rise" and underground portions of the project and methods of eliminating smoke from the complex. - List in detail hazardous materials to be stored or utilized on project site. • • CITY CENTER DEIS -- December 17, 1979 Subject Areas Requiring More Intensive Analysis Page 2 2. ENERGY CONSUMPTION - Quantify motor vehicle fuel consumption requirements associated with vehicle trips generated by the project. Quantify the estimated off- setting savings in fuel consumption resulting from proposed mitigating measures. - Discuss /directional building orientation and proposed use of construction materials as they relate to the project's solar energy usage efficiency. 3 TRANSPORTATION IMPACTS A. State - Controlled Facilities - Provide detailed discussion of project related traffic on I -405 and I -5 corridor in terms of land demand, adequacy of existing or future proposed access /exit ramps, intersection controls, etc. - Quantify and discuss project's impact on air quality relative to existing conditions on State highway facilities and relative to any project related changes to State highway facilities (i.e., widening, H.O.V. lanes, new ramps). B. Locally - Controlled Facilities - Justify the apparent assumption of 35 % -40% daily modal split between vehicle transit and transit ridership for office oc- cupancy. - Justify reduced trip generation rate from ITE standard for retail portion of site; discuss the assumptions which justify anticipated heavy usage of transit. - Provide discussion of traffic accident and hazard potential associated with the project in terms of reducing level of . service for roadways /intersections within the cordon area. - Justify suggested peak hour volumes within cordon area; provide 1985 level of service /volume indications with and without project. - Expand discussion of responsibility for implementing and funding all traffic related mitigation measures. 4. HOUSING /POPULATION - Resolve apparent discrepancy in population /employment forecasts in EIS and figures generated by PSCOG. - Justify conclusion that project will not affect local housing demand. Estimate number of employees (by income range) wishing to live in City as a result of employment within the project and then state the amount • • CITY CENTER DEIS -- December 17, 1979 Subject Areas Requiring More Intensive Analysis Page 3 of housing available within city and immediate region to satisfy that demand. Relate this discussion to vehicle traffic and energy con- sumption impacts of the project. 5. FLOOD CONTROL - Preliminary hydraulic calculations should be prepared to provide quantitative justification for the theoretical flood water run off control discussion contained on pages 92 -95. - Resolve objections of the King County Public Works Department to diversion of project related storm waters into the P -17 drainage system. 6. SANITARY SEWER - Quantify sewage disposal requirements of the project. - Evaluate and quantify the impacts of additional project related sewage upon the Metro sewage treatment plant at Renton. 7. AIR QUALITY - Discuss the air quality impacts and mitigation measures proposed for the project in relation to regional and statewide policy plans administered by PSAPCA and DOE. - Vehicle traffic related air quality impacts should be analyzed in terms of idling time and anticipated peak hour congestion resulting from the project. 8. LAND USE - Justify elimination of easement parking area from building to land area ratio computation. - Provide construction phasing /timing program. - Explain apparent conflict between building setback requirements and proposed widening of arterial streets adjacent to the project. - Provide diagrams illustrating project alternatives discussed. - Clarify underground parking plan to illustrate location of parking stalls in relation to support columns, elevator shafts, access ramps, footings, loading areas. CITY CENTER DEIS -- December 17, 1979 Subject Areas Requiring More Intensive Analysis Page 4 9. SOILS ANALYSIS - Append preliminary engineering soils investigation to DEIS. - Discuss potential for and protection of subsidence of project construction due to presence of underground waters on site. - Discuss project's impact on existing underground utility lines in project construction area. 10. WILDLIFE Substatial criticism of the DEIS was received during the public comment period; However, since Resolution 736 has now supplanted Resolution 656 and in essence allows total destruction of the existing wetlands and re- placement thereof with a man-made water environment, we have not attempted herein to respond to specific concerns. In any subsequent EIS for the City Center project, we would expect a complete description of the exist- ing wetland environment and an analysis of the design objectives and employed technology intended for use in the man-made water environment to be incorporated into the overall project design. In the abscence of a specific redesigned site plan, it is difficult for us to give you spe- cific guidance in tis area.Certainly the revised DEIS should include all background technical research generated by the wetlands design ad- visory committee mandated by condition 8 of Resolution 736. CHARIT` ELLS D LEVELc- >> MEHT CORPORAT0 M H� i] 4 fn1 L]11 • 4r. vc met, 1 MY OF TLMWOL/3_\ PLL,AMOM DCEPARTME T DDCC EMoEN91919 DRAFT ENVIRONMENTAL IMPACT STATEMENT for the TUKWILA CITY CENTER Prepared by CITY OF TUKWILA PLANNING DIVISION of the OFFICE OF COMMUNITY DEVELOPMENT For the Review and Comment of Citizens, Citizen. Groups, and Governmental Agencies In Compliance With: The State Environmental Policy Act of 1971 Chapter 43.21c, Revised Code of Washington Revised SEPA Guidelines, Effective January 21, 1978 Chapter 197 -10, Washington Administrative Code City of Tukwila Ordinance #759 DATE OF ISSUE: December 17, 1979 DATE COMMENTS DUE: January 21, 1980 COST PER COPY: $4.00 kell,(04 K - 1 Sto nes Dig ctor of Planning Introduction ACTION SPONSOR Chartwell Development Corporation Suite 2800, 555 West Hastings Street Vancouver, British Columbia V6B 4N6 (604) 669 -1112 PROPOSED ACTION The sponsor is requesting the necessary approvals to develop a retail shop- ping, office and hotel complex focusing on a wildlife pond and natural area. The shopping center will be "L- shaped ", and include three 3- to 4 -story department stores and a 2 -level mall which connects to the rest of the site development. The hotel development would consist of two towers, seven and ten stories high, containing 400 hotel rooms and 375 suites. The office buildings will range from three to ten stories, designed to accommodate a variety of offices and businesses. The focus of the development will be the existing pond, modified to maximize the effectiveness of the wildlife habi- tat and to provide a visual amenity. PROJECT LOCATION The site is located in Tukwila, Washington, in the southwest quadrant of the intersection of Strander Boulevard and Andover Park West. LEAD AGENCY City of Tukwila Planning Division, Office of Community Development RESPONSIBLE OFFICIAL /CONTACT PERSON Kjell Stoknes 6200 Southcenter Boulevard Director of Planning Tukwila, Washington 98188 Office of Community Development (206) 433 -1848 City of Tukwila PRINCIPAL CONTRIBUTORS /LOCATION OF BACKGROUND DATA Environmental Analysis and Document Preparation: Wilsey & Ham, Inc. Central Park Building, Suite 200 1980 - 112th Avenue N.E. Bellevue, Washington 98004 (206) 454 -3250 Contact Person: Ron Ubaghs Transportation and Circulation Analysis: The TRANSPO Group 23 -148th Avenue S.E. Bellevue, Washington 98007 (206) 641 -3881 Contact Person: Jim Maclsaac i r., Economic /Market Analysis: Shorett & Riely 1040 Washington Building Seattle, Washington 98101 (206) 682 -0630 Contact Person: Cornelius T. Beemster REQUIRED APPROVALS Draft and Final EIS Approval Final waiver under Section 3, Item 2 of Ordinance No. 1035 (Area of Con- straint) Conditional Use Permit for Hotel Height Exception Approval Architectural Control Review Binding Site Improvement Plan Flood Control Zone Permit City of Tukwila Grading and Building Permits Utility hookup permits COST OF COPIES: $4.00 DATE OF ISSUE OF DRAFT EIS: December 17, 1979 RETURN COMMENTS TO RESPONSIBLE OFFICIAL BY: January 21, 1980 ii "Table of Contents Page INTRODUCTION i TABLE OF CONTENTS RECIPIENTS OF THE DRAFT EIS 1 SUMMARY OF THE DRAFT EIS 3 DESCRIPTION OF THE PROPOSAL Name of Proposal and Sponsor 13 Location of Project 13 Other Agency File Numbers 13 Physical and Engineering Aspects 13 Existing Plans and Regulations 13 EXISTING CONDITIONS, ENVIRONMENTAL IMPACTS AND MITIGATION Elements of the Physical Environment Topography 31 Geology and Soils 31 Air 34 Water 41 Vegetation 46 Wildlife 46 Noise 53 Natural Resources 56 Light and Glare 57 Risk of Explosion 57 Land Use 57 Elements of the Human Environment Population and Housing 63 Transportation and Circulation 67 Public Services 85 Energy 88 Utilities 90 Health 95 Aesthetics 95 Recreation 96 Archaeology /History 97 Economics 97 IRREVERSIBLE OR IRRETRIEVABLE COMMITMENTS OF RESOURCES and the Relationship Between Local Short -Term Uses of Man's Environment and Maintenance and Enhancement of Long -Term Productivity 109 ALTERNATIVES TO THE PROPOSAL 111 UNAVOIDABLE ADVERSE IMPACTS 117 REFERENCES 119 INDEX OF ELEMENTS OF THE ENVIRONMENT 121 APPENDIX A:. General Description of Noise 123 iii LIST OF FIGURES Figure 1: Figure 2: Figure 3: Figure 4: Figure 5: Figure 6: Figure 7: Figure 8: Figure 9: Figure 10: Figure 11: Figure 12: Figure 13: Figure 14: Figure 15: Figure 16: Figure 17: Page Regional Location 14 Site Vicinity 15 Site Plan 16 Lower Level Parking Plan 17 Sections 18 Existing Site Conditions 32 Wildlife Habitat 48 Generalized Land Use 59 Zoning 61 Census Tracts 64 Existing Arterial System 68 Traffic Distribution 74 1985 Traffic Volumes 75 Recommended Traffic Improvements 77 Recommended Site Traffic Improvements 78 Transit Routes 83 Retail Demand Sectors 102 LIST OF TABLES Table I: Table II: Table III: Table IV: Table V: Table VI: Table VII: Table VIII: Table IX: Table X: Table XI: Table XII: Table XIII: Table XIV: Table XV: Table XVI: Table XVII: Table XVIII: Project Statistics 20 Air Quality Data 36 Carbon Monoxide Emission Factors for Various Vehicle Speeds 40 Predicted Decline in Carbon Monoxide Concentrations in 1985 - 40 Analysis of Water and Soil Samples 43 Existing Noise Levels 53 Predicted Ldn Noise Levels 55 Population Characteristics 63 Housing Characteristics 66 Vehicle Trip Generation Estimates 71 Anticipated Peak Hour L.O.S. For Various Lane Configurations 76 Heating and Cooling Degree Days for Seattle 88 Real Estate & Sales Tax Revenue 98 1980 -1990 King County Employment Growth & Demand for Office Space 100 King County Population by Major Sectors 100 King County DSTM Expenditures by Major Sectors 103 King County DSTM Expenditures and Sales Comparison 1978 -1990 105 Impact on King County DSTM Sales 1980 -1990 107 iv 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Recipients of the Draft EIS Federal Environmental Protection Agency Department of Energy U.S. Army Corps of Engineers U.S. Soil Conservation Service U.S. Forest Service State Office of the Governor Office of Program Planning and Fiscal Management Department of Ecology Department of Fisheries Department of Game Department of Transportation Department of Social and Health Services Department of Commerce and Economic Development Office of Planning and Community Affairs Institute for Environmental Studies Regional Puget Sound. Council of Governments Puget Sound Air Pollution Control Agency Seattle -King County Economic Development Council METRO Environmental Planning County Department of Budget and Program Development County Council: District 6, Bruce Laing District 8, Bob Grieve Division of Hydraulics City of Tukwila Mayor City Council Planning Commission Cities Auburn (Planning Department) Bellevue (Planning Department) Issaquah (Planning Department) Kent (Planning Department) Kirkland (Department of Community Development) Mercer Island (Department of Community Development) Redmond (Planning Department) Renton (Planning Department) Seattle (EIS Review Committee) 1 Utilities /Services Pacific Northwest Bell Puget Sound Power and Light Teleprompter Cable T.V. Tukwila School District Washington Natural Gas Company Libraries Bellevue Library King County Library System Kirkland Library Mercer Island Library Redmond Library Seattle Public Library (Main Branch) Tukwila Library University of Washington Library, College of Architecture & Urban Planning Branch Newspapers Auburn Globe News Daily Journal American Daily Journal of Commerce Des Moines News Highline Times Issaquah Press Kent News Journal Renton Record - Chronicle Seattle Post - Intelligencer Seattle Times Private Organizations and Others Bellevue Chamber of Commerce Burien Chamber of Commerce Doubletree Inn Greater Renton Chamber of Commerce Kent Chamber of Commerce , Olympic Pipeline Company Rainier Audubon Society Mr. Scott Salzer Seattle Audubon Society Seattle Chamber of Commerce M.A. Segale Southcenter Shopping Center Tukwila Chamber of Commerce Tukwila Industrial Council Valley General Hospital Washington Environmental Council Summary of Contents of Draft EIS THE PROPOSAL The sponsor, Chartwell Development Corporation, is requesting approval to develop a retail /office /hotel complex on a 38.9 -acre site in Tukwila. The site is at the southwest corner of the intersection of Strander Boulevard and Andover Park West, just south of the Southcenter shopping center. The proposal includes 800,000 square feet of retail space, 600,000 square feet of office space and approximately 600,000 square feet of hotel space (400 rooms and 375 suites). The shopping center would be a two -level enclosed . mall with three major department stores. The office space and hotel would be in build- ings up to ten stories in height. The complex would provide approximately 6,300 parking spaces (mostly underground), an integrated, enclosed pedestrian system, and eleven acres of pond and natural open space designed to enhance and protect existing wildlife habitat. SUMMARY OF ENVIRONMENTAL IMPACTS AND MITIGATION Elements of the Physical Environment Topography About two - thirds of the site would be excavated, filled or recontoured, and covered with buildings, parking structures and landscaping. Much of the re- mainder would be modified slightly, primarily to improve wildlife habitat in the pond area. Geology and Soils Soils on the site are expected to compact and settle from filling and from the extraction of water during construction of below -grade parking. There may also be slight and localized settling of soils in roadway areas and adjacent par- cels. Settling occurring as a result of building loads will be more minor since structures will be founded on piles. Approximately 200,000 to 220,000 cubic yards of soil materials, primarily previously placed fill, would be exported to other construction sites in the valley, in 15,000 to 20,000 truck- loads, in phases over the five -year construction period. Mitigation - Trucks can be scheduled to avoid traffic peak hours and avoid residential areas. 3 Air Vehicular activity would create the majority of pollutants resulting from the proposal. Future pollutant concentration levels are not expected to exceed existing levels, but should continue to decline as vehicle - related emissions are reduced by federal programs. Short -term increases in local dust levels are anticipated during construction. Mitigation - Roadway improvements are suggested to improve traffic flow in the vicinity. Proper construction procedures can reduce dust levels. Water The existing pond would be reduced to approximately half its present size. Potential changes to surface water quality could result from increased runoff, pollutants from impermeable surfaces and changes in groundwater or pond levels. Increased summertime water temperatures and concentrated nutrients may result from reducing the volume of the pond, which may, in turn, reduce oxygen levels. Mitigation - Measures proposed include storm water collection, silt traps, oil /water separators, a controlled pond level to recreate existing seasonal fluctuations, and prevention of backf l ow into the pond from the local storm sewer system. These measures would be effective in maintaining water quality in all but extreme circumstances. Other factors which could be employed in cases of unanticipated circumstances (e.g., excessive nutrients due to ferti- lizers or larger numbers of domestic ducks) include: • increasing pond depth; • use of circulating and aeration devices; and • frequent sweeping and washing of parking areas and streets. Vegetation Most of the existing vegetation would be removed from the site in phases. Vegetation along the southern shoreline and flooded brush area of the pond would be preserved, and the remainder of the eleven -acre open space area would be planted with food - producing plants immediately after recontouring. Several acres of landscaping would be provided in conjunction with building and parking area construction. 4 '' Wildlife Much of the dry grassland habitat area, which has developed on previous fill, would be replaced by buildings and parking areas, and therefore use of the site by species such as cottontail rabbits, savannagh sparrow, pheasant and quail would be substantially reduced or eliminated. This habitat type is found frequently throughout the region and the loss of this isolated site is of minor overall impact. The more uncommon habitats located in the southwestern portion of the site and around the edges of the pond would be retained, recreated or enhanced in a smaller area. Most of the eighty or more species identified on the site would continue to use the area, but probably in reduced numbers. No rare or en- dangered species are known to inhabit the site. Mitigation - The pond and several important habitat types associated with it would be preserved and enhanced in a smaller area. An eleven -acre parcel is set aside for exclusive wildlife use and would be designed under consultation from a wildlife biologist. The edge of the pond would be modified to incor- porate water channels, peninsulas and cover areas and the flooded brush habi- tat, seasonal mudflat and brushy areas at the south and west edges of the pond would be retained. Islands would be created and other measures instituted to buffer wildlife from predators and human activity. Food grains, grasses, shrubs and trees would be planted immediately after any grading and recon- touring. The larger islands would include low areas which would flood in the winter, replicating the wintering and nesting duck habitat which would be displaced from the southeast corner of the site. Interpretive displays would be provided at places where the public can view the pond and natural area, to explain the sensitivity of the habitat and identify species which may be observed during the different seasons. Water quality and seasonal fluctuations in pond level would be monitored and controlled to pro- tect the productivity of the site. Noise There would be a slight long -term increase in noise levels from additional traffic and a short -term increase from construction activity. 5 Natural Resources Construction and operation of the proposed complex would consume typical amounts of natural resources in the form of land, construction materials and fossil fuels. Light and Glare No light- sensitive facilities would be affected by the proposal, which would emit light at approximately the same intensity as other commercial structures in the area. Risk of Explosion and Hazardous Emission Other than the temporary risks associated with construction, any risk of explo- sion or hazardous emission would be no greater than at any comparable type of development. Land Use The use of about two - thirds of the site would be changed from vacant land to retail, office and hotel uses. The proposed floor -area ratio of approximately 1.2 square square feet of building for each square foot of land would represent a more intensive land utilization than now exists on any parcel of this size in the region outside of a few major downtown areas. The eleven acres of pond and wildlife habitat, along with additional adjacent park -like landscaping, would provide a unique open space amenity. The proposed project should have no adverse impact on any existing or potential use of adjacent lands or other land in the vicinity. Future use of surrounding land could indirectly be affected due to the concentration of retail and office square footage in the area. The regional retail drawing power of the proposal combined with Southcenter may encourage additional intensification of retail development in the vicinity. Additional mid -rise office construction may also be stimulated in response to possible improved transit service to the area which the proposal may facilitate. Elements of the Human Environment Population and Housing Little effect on population or housing in the area is expected as a result of the proposal. The proposed hotel /suites could provide temporary housing for 6 employees being relocated by nearby businesses. Some additional pressure for higher density residential development in and near Tukwila may result from the proposal's employment of up to 4,500 persons. Transportation /Circulation The proposal would generate about 27,500 vehicle trips on an average weekday; about 10% of which would occur during the afternoon peak hour. The traffic volumes on streets in the immediate area of the proposal are expected to increase about 20% to 40% as a result of the development. Traffic into the project vicinity would increase by up to 20 %, and the freeway systems in the Tukwila area would experience 3% to 5% increases in volume. The proposed employment density, particularly in the proposed office complex, may provide justification for improvements in transit service to the area. Such service expansion, which METRO has been studying, would benefit the greater Tukwila area. Pedestrian circulation would be improved by the interior mall system and con- struction of sidewalks in adjacent streets. Carpooling opportunities would be increased due to the employment density. Mitigation - A number of street improvements are recommended to ease existing congestion and to accommodate the traffic growth generated by the proposal and other area growth. Improvements generally involve additional traffic or turn- ing lanes, signalization, two -way left turn lanes and lane widening. Most suggested improvements are on Andover Park West, Strander Boulevard, and a short segment of Southcenter Parkway. An east -west extension of Minkler Boule- vard and improvements to the I -405 corridor are recommended to improve the general area traffic flow, with or without the proposal.. Public Services There would be a proportional increase in demand for services such as police and fire protection, but taxes generated would offset any additional costs. The proposal would be designed to minimize the need for additional city pro- tection as much as possible. No significant impact to schools, parks or other services is expected, but additional tax revenues would benefit these opera- tions. 7 Energy Gas and electricity requirements for lighting, heating and cooling of the proposed development would be commensurate with other new commercial construc- tion. The additional concentration of retail, office and hotel uses in an existing commercial activity center would tend to increase the overall tran- sportation energy efficiency of the proposal. Utilities Electricity The existing electrical system in the site vicinity, and substation expansion already proposed, will adequately serve the proposal. Natural Gas Adequate gas lines and supply exist to serve the proposal. Telephone Existing systems can be expanded to supply the demand with no major altera- tions. Water The local system of 8" to 12" mains, served by a 60" main in the vicinity, will provide adequate fire flow and domestic water service. Sanitary. Sewer Existing 12" and 27" sewer lines border the site and drain to a 36" METRO line along the Green River. Adequate capacity exists for the proposal and other area growth. Storm Drainage The modified pond would provide adequate storage for all on -site runoff during times when the river level is high and the local drainage system backs up. The floodwater storage capacity currently provided on the site would be removed from the City's drainage system, possibly raising local off -site ponding levels somewhat, and /or causing additional overflow into the adjacent P -17 drainage system to the. south. Mitigation - Additional study is required to define the actual storage needs of the local drainage system and the measures necessary to compensate for the lost storage capacity. Potential solutions include providing additional storage elsewhere, intercepting runoff from the higher elevations of the watershed with direct pressurized piping to the river, and increasing the design capacity of the adjacent P -17 system to handle the overflow. 8 Solid Waste A private company provides disposal service to the county transfer station and can expand as necessary to accommodate the proposal. Health No conditions would be created that would become health hazards. Aesthetics The proposal would be visually compatible with surrounding uses, although it would be more intensive in character and appearance than most existing develop- ment in the vicinity. The ten -story buildings would provide a strong visual focus which does not now exist in the commercial industrial district of Tukwila. The pond and natural area would provide a visual amenity for users of the site and adjacent development. No significant views would be obstructed and no offensive views would be created. Recreation No significant recreation is provided on the existing site. Recreation facili- ties would be added in conjunction with the office and hotel development, and interpretive displays would increase public visual use of the pond and habitat areas for observation and understanding of wildlife. Archaeology /History No architectural or historical resources would be affected by the proposal. Economics Tax Revenue The completed proposal would generate approximately $8.64 million in taxes annually - $2.25 million from property taxes, $6.2 million from sales tax and $190 thousand from the 2% hotel room tax. Tukwila's direct portion of these revenues would be about $1.1 million annually. Employment Total site employment would be approximately 4,500 - 1,700 at the shopping center, 2,400 in office space, 300 at the hotel and about 100 in general operations and maintenance. Market Factors Office: The 600,000 square feet of office space represents about 7% of the projected ten -year growth in the county and 25% of the growth projected for the Tukwila/ Sea -Tac Airport area. 9 Hotel: The 775 rooms and suites would supply approximately 20% of the county's ten - year projected growth. This is a relatively high share. Phase I is justified now, but the market potential should be reassessed prior to a go -ahead on Phase II of the hotel development. Shopping Center: During the ten years from 1980 to 1990, King County sales in department store type merchandise (DSTM) are expected to increase from $1.8 billion to $2.45 billion, an increase of $650 million. The DSTM sales projected for the pro- posal are approximately $80 million, or 12% of the total county growth. The major impact of the proposal would be to shift the growth in new shopping center space between the various quarters of the county. The following chart summarizes the growth in sales that would occur over the ten year period with and without the proposal. 1980 -1990 GROWTH IN DSTM SALES WITHIN KING COUNTY (millions of dollars) SUB AREA W/0 PROPOSAL WITH PROPOSAL 1. Northwest (Seattle, Shoreline) $ 155 2. East side (east of Lk. Wash., north of Renton) 220 3. Southwest (includes proposal) (Tukwila to Federal Way) 105 4. Southeast (Renton, Kent, Auburn & east) 170 $ 650. $ 105 210 230 105 $ 650. The southwest area (Sub -area 3), including Tukwila, would experience a substan- tially increased growth rate in DSTM sales with the proposal. Tukwila and Federal Way would both increase their sales growth rates, while Midway and Burien would grow more slowly. The east side (Sub -area 2) would continue to experience a substantial sales growth, with only a slight retarding effect due to the proposal. Seattle /Shoreline area (Sub -area 1) sales would grow about two - thirds as fast with the proposal, primarily due to the proximity of Tukwila to the southern portions of Seattle. • 10 The southeast area (Sub -area 4) currently has a shortage of DSTM sales facili- ties and many shoppers now travel to Tukwila or Federal Way shopping centers for much of their comparison shopping. Without the proposal, substantial growth in shopping center construction and sales could be expected in the southeast part of the county. With the proposal, this trend would not develop to the same degree, and Tukwila and Federal Way would remain as major shopping locations serving the southeast area. SUMMARY OF ALTERNATIVES CONSIDERED The No- Action Alternative Denial of the final waiver or other necessary approvals would leave the site in its present condition for an undetermined length of time, eliminating or delay- ing the impacts described in this report. The options available to the sponsor include: • Subdivide the site for sale or for other types of development. • Resubmit a substantially different proposal (alternatives discussed below). • Institute appeal procedure or legal action to overturn the denial. Alternative Sites The sponsor does not own or control other sites in Tukwila or in the nearby area suitable for the proposed development. Varying the Mix or Size of Uses Proposed Any of the three major uses; retail, office and hotel, could be varied somewhat in size. The overall scope of the proposal could be adjusted upward or . downward by such changes or rebalanced to retain the approximate overall pro- posed size. The most direct impacts of such changes would be in the areas of air quality, traffic generation, tax revenue generation and employment. A change of 200,000 square feet in the retail portion would change average daily traffic by about 12 percent. A similar change in office or hotel wuold modify traffic by about 7 percent. Other changes may occur in abundance of wildlife on the site, an indirect affect on future intensity of adjacent land uses, and in the aesthetic quality of the development. 11 Reduced Scale Project Based on Surface Parking Only A similar mix of uses built without structured parking would be limited to 700,000 to 800,000 square feet. About half of the site would be in surface parking, one quarter in buildings and one quarter in pond and open space. Maximum building heights would be four to five stories. Fewer financial resources would be available to preserve the pond and wildlife habitat. Major changes to impacts would include: import of a greater amount of fill than would be exported under the proposal, faster rate of local air quality improvement, somewhat greater loss in abundance of wildlife, lower intensity of land use in the vicinity, approximately a 50 percent reduction in traffic generation, loss of potential transit focus, absence of the creation of a visual focus and "downtown" scale activity center, reduced tax generation and employment. Fill Entire Site and Develop a Mix of Commercial Uses This alternative would be essentially the same as the earlier proposal by the former site owner, Seattle City Light, which is described in a final environ- mental impact statement dated May, 1976. It is likely that the site would be subdivided and sold to a number of developers and that a mix of office, distribution and some one -story retail would occur. The actual impacts from development could not be determined until specific proposals were made. Since a proposal to fill the entire site was previously denied by the city, 'and since elimination of the pond would violate many of the guidelines established by Resolution 656 regarding the site, it is unlikely that this alternative would be considered viable. SUMMARY OF REMAINING ADVERSE IMPACTS • Minor compaction and settling of soils on and immediately adjacent to the site; • Exportation of 200,000 to 220,000 cubic yards of mainly previously - placed fill, requiring about 15,000 to 20,000 truck trips to other construction sites in the valley; • Loss of grassland vegetation and some wildlife species from about two - thirds of the site; • Reduction in the size of the existing pond; • Reduction in numbers of wildlife using the pond area; • Minor reduction in diversity of wildlife species on the site; • Increase in traffic of 20% to 40% on the local arterial system; • Increase of 3% to 5% on nearby freeway traffic volumes; • Reduction in floodwater storage capacity of the local storm drainage system. 12 1 1 Description of the Proposal NAME OF PROPOSAL AND SPONSOR The proposed commercial development is to be known as the Tukwila City Center. 11 The sponsor is the Chartwell Development Corporation. ' LOCATION OF PROJECT The 38.9 acre site is located in the southwest quadrant of the intersection of IStrander Boulevard and Andover Park West, immediately south of the Southcenter shopping center in Tukwila, Washington. The regional location is shown on Figure 1, and the site vicinity is shown on Figure 2. The parcel constitutes the southwest quarter of the northeast quarter of section 26, Township 23 North, Range 4 East, W.M., King County, except the north 30 feet and the east 30 feet thereof. 11 OTHER AGENCY FILE NUMBERS None known. • PHYSICAL AND ENGINEERING ASPECTS The proposed complex includes an 800,000 square foot shopping center, 600,000 square .feet of office buildings, approximately 600,000 square feet of hotel space including 400 rooms and 375 suites, 6,300+ parking stalls (mostly in two ' below- grade, covered levels), and an integrated, enclosed pedestrian system, all clustered around eleven acres of pond and natural open space area. The ' physical configuration is shown in the schematic site plans (Figures 3 and 4), and the elevation and sections (Figure 5). The main floor and surface parking would be at a level approximately three to eight feet above the adjacent streets. The entire building complex, including tsurface parking and adjacent landscaping, would be supported on piles over two levels of covered parking. The pond would remain at approximately its existing ' level, about 15 feet below the main floor level. Table I gives the project 1 1 1 13 7°%► ,44 llll fr 1-11 ill, ACIIr•1■■IPi::■ I (•r. n uIl•1I1u it \ I1It IaaaCll J111 II uIIIIIIIPI . 1.-t'ti •_ . 111111111::111` III1,,4 thionlaunn 11111111111U-A�e -�II II 111 IIIn11 omr.' 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"; • i 1 1 ; t • . • 7, ; i 1 ' Liter. ; 1 "." t i , SOUTHCENTER / ...77 (1 1 ■ 1 i V: '; ; ! f ; 1 • I i . . ; ' • i 1 \ f 7 7 • ; ; . 7,°.4.7.75,„7 ,t„,,.< i 1 ..a. , ,-- •••••• ; I 7/f . 1 1 TUKWILA I s i CITY ▪ CENTER • SITE i 7 2300 i • Fv- 4 7,77' • `*--->T7-; ••• 3' • tukwila city center Site Vicinity FIG. 2. 15 Al existhg road STRANDER BLVD. 411- SOUTHCENTER rolastdx ing access 4kt. ,x celerat ion Ask -deceleration Crf2f77 I -• •• existing row. 1LJ 1— 0 1 SHOPPING 800,00.0 sq water to be continued Into existing fill ..,--cipprox ot existing eget ation A 0 50 100 200 300 feet line of 11 acres of pond and wetland LEGEND C9 pI HOTEL RETAIL _ DEPT. &ORES & MALL OFFICE ROOF LEVEL RAMP UP RAMP MN oo■ tukwila city center Site Plan FIG. 3. 16 TA STRANDER BLVD. • • T • • • dlomEMM • • • Asa • • • q; i .I 1. 1. 1 F IN III MUM . L B N tUiSW1�C1 Lower Level city center Parking Plan FIG. 4,r 17 �� •�L_����...��ir•��aar•����T•,�� ��:r��.► •�i_�. t WA 4.0a!•3�;Jls!s •.t - .3±....r • ... major major ELEVATION FROM STRANDER BLVD. hotel OFFICES 11 ACRE POND & WETLAND <-5.1 x CARPARKING STRUCTURE SECTION A•A ELEV 25 5 '^` MALL MALL -X —X X X <9t x CARPARKING STRUCTURE SECTION 13.13 K N X„ X DEPT STORE X MALL • I I:!II!i.. IA�� AVERAGE ELEV. OF WATER SURFACE 15 11 ACRE PONO & WETLAND AVERAGE ELEV OF WATER SURFACE 15-0 X N 11 ACRE POND & WETLAND X STRUCTURE STRUCTURE !E" SECTION C-C f 2 K a X setback _XAPTS.X landscaping X HOTEL I ELEV i 26� <17,. x CARPARKING STRUCTURE SECTION D•D iJi011IIG ;un, ,,4nwa;Ip X setback n!f J S AVERAGE ELEV OF WATER SURFACE 15.0 AVERAGE ELEV_OFWATER SURFACE 15-0 X 11 ACRE POND & WETLAND >t< 0 50 1G0 Z00 3W feet tykwilci Elevation City center and Sections FIG. 5 . 18 'statistics and the following text generally describes the major char- acteristics of the proposal.* Construction and Phasing Schedule - The sponsor intends to begin construc- tion in 1980 and to construct the complex in stages over a five -year period with occupancy of the final buildings occurring during 1985. The detailed staging has not been determined, but it is anticipated-that the portions of the shopping center, hotel and office buildings closest to the adjacent streets would be built first and that redevelopment of the pond would accom- pany construction of the inner buildings during the last half of the project. Design and Materials - Specific architectural designs have not been com- pleted. The overall concept is a cluster of separate buildings unified by lower -level mall connections, compatible exterior design and materials, and a coordinated site landscaping scheme. Predominant exterior materials would be precast concrete, wood and glass. Shopping Center - The fully enclosed two -level shopping mall would occupy approximately 13.7 acres at the northeast corner of the site. Three 3- to 4- story structures would form anchors on the northwest, northeast and south- east corners of the retail complex (see Figure 3). Two of these anchor structures would be major department stores and the third would be either a major department store or a combination of a junior deparment store, a large specialty fashion store, a food center and a restaurant complex. The anchors would contain approximately 150,000 square feet each. The balance of the center would include about 325,000 square feet of shops constructed on two floors along a series of sky -lit, two -level malls. A complex of six theaters would complete the 800,000 square foot shopping center. *At the time of this publication, preliminary negotiations are being con- ducted with a number of potential primary tenants for the Tukwila City Center. The exact configuration and size of the various portions of the proposal are . subject to minor modifications as financial arrangements are completed and detailed architectural plans are drawn. The project sta- tistics presented herein, and utilized in the environmental analysis, are based on studies which approximate the maximum anticipated size for each element and use, and cumulatively represent the best available data regard- ing the potential maximum scope of the proposal. 19 TABLE I PROJECT STATISTICS* Stage I: 1981 -1983 Completion; Total 1,177,000 Sq. Ft. Shopping Center Office Hotel Anchor 1 150,000 Sq. Ft. Major Dept. Store Anchor 2 150,000 Sq. Ft. Major Dept. or Junior Dept. Food Center Specialty Restaurants ' Tenant Shops 217,000 Sq. Ft. 600,000 Sq. Ft. 400 Rooms Restaurant Coffee Shop Meeting Rooms Lobby Service Retail Total Stage I: 517,000 Sq. Ft. 360,000 Sq. Ft. 300,000 Sq. Ft. ** Stage II: 1984 -1985 Completion; Total 823,000 Sq. Ft. Shopping Center Office Hotel Anchor 3 150,000 Sq. Ft. Major Dept. Store Theaters 26,000 Sq. Ft. Tenant Shops 107,000 Sq. Ft. 600,000 Sq. Ft. 375 Suites Restaurant Rec. Area Meeting Rooms Lobby Service Total Stage II: 283,000 Sq. Ft. 240,000 Sq. Ft. 300,000 Sq. Ft. ** Total Proposal; 2,000,000 Sq. Ft. Shopping Center Office Hotel 800,000 Sq. Ft. 600,000 Sq. Ft. 600,000 Sq. Ft. ** FINAL SITE AREAS: Buildings Parking Landscaping Pond /Open Total Site 14.2 acres 6.0 acres 7.6 acres 11.1 acres 38.9 acres 20 *A11 areas are 'preliminary * *Square footage for hotel facilities is a rough approximation. I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Office Complex - Office space would be contained in a cluster of buildings on 7.1 acres at the southeast corner of the site. The group of towers, 3 to 10 stories in height, would include approximately 600,000 square feet of gross floor area. Assuming ten percent for corridors, service and common areas, the net leasable space would be around 540,000 square feet. The design would provide a variety of floor sizes and could accommodate large corporate offices as well as small businesses. The 10 -story building would be approxi- mately 135 feet tall. Hotel Complex - Hotel accommodations would be provided in two buildings on seven acres at the northwest corner of the site. The northern 10 -story tower would be approximately 108 feet high, and the southern 7 -story tower approxi- mately 78 feet. The hotel complex would include 400 standard hotel rooms and 375 two -room suites. The suites would provide deluxe accommodations for business travelers with a separate meeting /social room and sleeping quarters. They would also be suitable for tourist families or for short- or long -term lease to area businesses to house relocating families and groups of employees in training. The two towers would share common parking, lobby and service facilities as well as meeting rooms, . restaurant /lounge, recreation facilities and small retail shops. Parking - The bulk of the on -site parking would be provided in two below grade levels extending under the entire building complex. Surface parking would be limited to small areas adjacent to the office clusters, the hotel complex, and the shopping mall. Approximately 6,300 parking stalls are proposed. This number exceeds the cumulative requirements in the Zoning Ordinance for the uses proposed. During the detailed design stage, further study will be conducted to assess the viability of shared -use parking or other factors which may modify the final parking plans prior to building permit approval. Circulation - Most of the vehicle traffic would enter directly into the below -grade parking levels from three points along Strander Boulevard and three along Andover Park West. One of the ramps from Strander Boulevard near the west end of the site would also bring traffic past a surface parking area 21 and the hotel entrance before descending to the below -grade parking levels. An additional small ramp along Andover Park West would access the surface parking by the office buildings. Acceleration and deceleration lanes have been allowed for within the building setbacks along the two arterials. A separate truck ramp and loading dock would be provided for each major anchor of the shopping center, with additional loading areas and service parking on the upper below -grade parking level. Horizontal pedestrian circulation would be provided by the two -level en- closed mall system which would extend throughout the complex, beyond the shopping center into the lobby areas of the hotel and office structures. Vertical circulation would include stairs, ramps, escalators and elevators from the parking levels to the malls and the hotel and office towers. Pro- vision would be made for development of a people mover system to transport people from transit stops and parking areas to the malls and lobbies, with the potential to link with other nearby commercial facilities in the future. Pedestrian walks would lead to the city sidewalks on the north and east, and barrier -free access for the handicapped would be provided at several points. Provision would be made for accommodating METRO transit service to serve the on -site development and other major employers in the vicinity. The Pond -.The proposal dedicates 11 acres of the site for pond and natural wildlife use. This area includes much of the existing pond and adjacent wetland and upland habitat areas. Additional land near the hotel, shopping center, office complex and parking areas would be landscaped to provide a park -like transition from human use to wildlife use areas. Portions of this transition area would allow some controlled passive human activity, but the more sensitive habitat areas would be protected from incompatible human activity. The north and east edges of the pond would be reconfigured to provide an attractive visual amenity for employees, shoppers, hotel guests and other visitors to the site, as well as to enhance the area for wildlife use. The southwestern portion of the pond would be maintained as wildlife habitat. The existing habitat would be enhanced by including peninsular forms, small islands, additional water channels and supplemental vegetation, designed 22 under the direction of a wildlife biologist. The use of the pond for detention of on -site stormwater would provide natural and seasonal water level fluctations approximating those which currently exist. Interpretive displays would be provided at key viewing locations to inform the public about the habitat characteristics of the pond and natural area and to identify the wildlife species which may be observed in the area throughout the various seasons. EXISTING PLANS AND REGULATIONS Zoning The site is currently zoned C -M (Industrial Park), which is intended to allow all uses permitted in the C -1, C -2 and M -1 districts of the Tukwila Zoning Ordinance. Two of the proposed uses (retail and office) are permitted outright in C -M, and the third major use, hotel, is permitted with the approval of a conditional use permit. The C -M zone provides for parcels greater than five acres in size to exceed the 35 -foot (or three stories) height limitation. The height can be increased by one additional story for each additional two - and - one -half acres of site area. This criteria would allow development on the site to build to a height of 16 stories, if approved by the City Council. A height exception to 300 feet can also be given by the Planning Commission, provided certain setback and design conditions are met. The maximum height proposed for the project is 10 stories, or approximately 135 feet. Off- street parking spaces are required on the following basis: For retail business - one space for each 400 square feet; for office buildings -3.1 spaces for each 1,000 gross square feet; for hotel - one space per room; plus additional parking for restaurants and public assembly areas. Certain allowances for shared use parking areas are provided for, and the require- ments can be changed or reduced by the City Council. Based on the above factors, approximately 4,400 parking spaces would be required. Due to the special requirements of many major shopping center tenants, however, the sponsor is proposing to provide approximately 6,300 spaces. The exact number will be determined during detailed design and permit stages. 23 Comprehensive Land Use Policy Plan The proposal is consistent with the designations on the Comprehensive Land Use Plan Map. The site and adjacent land to the north, west and southwest is designated "commercial ". Land to the east and southeast is "light industry ". A "special development considerations" designation is overlaid on the pond portion of the site. The proposal appears to be consistent with the intent of the goals, objec- tives and policies of the plan in the areas of Natural Environment, Open Space, Commerce /Industry and Transportation /Utilities. The following poli- cies are pertinent in consideration of the proposal: Natural Environment Discourage disturbance of vegetation when not in conjunction with the actual development of the property. Strive to retain viable areas of wooded hillsides, agricultural lands, wetlands, streams and the Green River for wildlife habitat. Discourage filling, grading, or excavations of land when not in con- junction with actual development of the land. Encourage the preservation of marshes and ponds for the retention of storm water runoff. Open Space Encourage the preservation of marshes, ponds, and watercourses for open space purposes and include them in the open space system. Provide for passive recreational areas (parks, natural resources, picnic grounds) consistent with the needs of the community. Commerce /Industry Encourage the grouping of uses which will mutually and economically benefit each other or provide necessary services. Allow for the location of new commercial and industrial areas and the expansion of existing ones when this expansion is compatible with sur- rounding land use and not detrimental to the public welfare. Encourage aesthetic building and site design in working and trading. areas. Promote adequate provisions for parking for all land uses. Encourage a diversity of business uses to promote maximum occupancy. Encourage and promote the location of labor- intensive industries in the City. Encourage uses which are supportive to retail areas to strategically locate in or near those areas. 24 Commercial uses should be located functionally convenient to major trafficways. A pedestrian circulation system should be developed in commercial use districts. Recognize the benefits of retail activities and promote them. Commercial office developments should consider the adjacent use dis- tricts in the design process. Encourage the location of commercial offices in areas of high natural amenities. Encourage the grouping of land uses which vary in business hours to maximize the usage of parking spaces. Transportation /Utilities Minimize conflict between moving traffic and parked vehicles. Discourage the maneuvering of automobiles or trucks on public rights -of- way. Promote the consolidation of access points to frontage properties along major arterials. Encourage the construction of safe internal access roads in developments and other private easement roads. Support efforts to increase transit use. Create a sidewalk or pathway system where every link is a part of an integrated network. Integrate bicycle, pedestrian, bus and street systems and develop accom- modating and safe mechanisms of transferring from one mode of tran- sportation to another. Provide for pedestrian overpasses over other transportation routes which otherwise restrict safe pedestrian movement across them. Encourage a part structural (pipe), part non - structural (detention pond) storm sewer system. Where beneficial to downstream properties, control peak flow runoff from the source at a rate similar to natural conditions. Where possible, make provisions for local storm water which cannot enter the Green River during periods of high flow. Encourage control of peak runoff at the source. Consider nonstructural as well as structural solutions to storm water control.. City Ordinance No. 1035 When the new Comprehensive Plan was adopted on September 19, 1977, the City recognized that the existing zoning code no longer reflected current plan 25 policies and therefore also adopted an interim ordinance to provide for City Council review of certain development proposals. Under Section 3, Item No. 2 of Ordinance No. 1035, a waiver by the City Council is required prior to processing "proposals for building, grading, clearing, excavation or filling which are located in a geographical area generally identified by the Environmental Base Map of the Comprehensive Land Use Policy Plan as an area of constraint." The Environmental Base Map designates the existing pond on the proposal site as such an "area of constraint" due to the presence of a significant area of surface water. A waiver is therefore required before approval of any devel- opment of the site. A preliminary waiver was granted in January, 1979, after review of the conceptual development plans. This preliminary action was declared exempt under provisions of Tukwila's environmental ordinance, Ordinance No. 986. A final waiver requires SEPA compliance, and the final waiver request will be considered following finalization of the SEPA EIS process. City Resolution No. 656 When the subject property was offered for sale by sealed bid by the previous owner, Seattle City Light, the City of Tukwila established a set of guide- lines to assure that any future development of the site would be consistent with the new Comprehensive Plan. Resolution No. 656, passed by the City Council on October 16, 1978, adopts general guidelines for the development of this specific parcel (identified as the "City Light Site ") which is "...depicted on the Comprehensive Land Use Plan Map as an area requiring special development considerations." A proposal which responds sensitively to the adopted general guidelines of Resolution No. 656 would therefore also satisfy the criteria in Section 5 of Ordinance No. 1035 regarding "The Merits of a Waiver Request ". The following discussion presents the guidelines adopted by Ordinance No. 656 and the manner in which the proposed development responds to these guidelines. Guideline 1. Surface runoff from paved areas on the site should not be channeled into the pond unless approved water filter devices and other measures are implemented in order to maintain suitable water quality for wildlife. 26 1 1 1 1 t 1 1 t 1 1 1 1 1 i 1 Response: Guideline 2. Response: Response: Response: Response: Response: Detailed drainage system designs for the site are not com- pleted. Preliminary studies indicate that the use of the pond for detention of drainage from the site and limited external areas is desirable both from the standpoint of relieving potential flooding problems in the vicinity and to provide seasonal fluctuations in the level of the pond to enhance the rich and diverse habitat that the pond pre- sently provides for numerous species of migrating birds. Final drainage system designs will be carefully developed to control silt, oils, nutrients and toxicants to the degree necessary to maintain the long -term viability of the pond as a wildlife habitat. Encourage the pond environment to be used by wildlife, par- ticularly waterfowl. In order to accomplish this objec- tive, the following policies should be implemented. a. Separate human access areas from prime feeding and nesting areas. Human access will be limited to the areas near the proposed buildings. During the current environmental analysis, a detailed biological study was conducted to further define the most, sensitive and unique habitat areas in and asso- ciated with the pond. Final development proposals for both human and wildlife uses of the pond environment will be carefully reviewed. b. Separate the nesting area from the mainland (possibly create an island for nesting purposes). Development of refuge islands, peninsula habitat areas and other wildlife enchancement measures is proposed and will be developed with consultation from a recognized wildlife biologist. c. Future development should setback from the edge of the pond. Access roads and parking areas should be setback also. All buildings, parking areas and human use areas are pro- posed to be set back from the pond and natural areas. d. Sufficient "cover" habitat should be retained in order to provide the waterfowl with escape or hiding places (retain tree cover in southwest corner of site). The proposal retains much of the existing "cover area ", and provides additional protected areas on islands and penin- sulas. e. Encourage visual access to the pond. The proposed shopping center, restaurants, office struc- tures, hotels and associated human -use areas are designed to take advantage of the visual amenity provided by the pond. 27 f. Monitoring of water quality should be done on a continual basis. Measures must be taken to prevent eutrophication. The pond must be maintained. Response: Proposals will be made to the City on how to achieve this during the planning and design stages. Management would include recommending measures necessary to protect and en- hance the pond, wetlands and other associated habitat areas in keeping with overall long -range goals for the site. Guideline 3. Discourage the use of trucks as a means of filling the site. Encourage fill to be brought by rail. A large amount of trucks delivering fill may cause damage to road surfaces and add to traffic congestion and hazard during peak volume periods. Response: It is anticipated that development of the site as proposed will result in an excess of material to be disposed of. Arrangements are being pursued to move the excess material to nearby sites as fill. Scheduling can be controlled to avoid peak hours. Guideline 4. Encourage the coordinated development of building sites on the City Light property. To accomplish this, implement the following: a. Promote shared access points and internal circulation roads, possibly built to city standards and dedicated to the City. b. Encourage a. compatible mix of office and retail land uses on the site. c. Review all building and site development plans for compat- ibility with surrounding developed areas, as well as for compatibility with the objectives of wildlife and waterfowl enhancement. Response: The proposal appears consistent with these guidelines. Additional design review and approval is required prior to issuance of permits. Guideline 5. Concentrate grading and fill activities and site develop- ment activities which occur on or near the pond during the non - winter months of April - October, so as to minimize the adverse effects of contruction activities on the use of the pond by waterfowl. Preference will be given to con - struction on piling. Response: Construction schedules would be prepared with consultation from the biologist involved in pond design to minimize tem- porary adverse impacts to seasonal habitat use. Guideline 6. Approximately one -third of the total area of the site should be retained in its natural state. 28 • Response: The proposal establishes a 11 -acre parcel for pond and natural area. An additional one to two acres of adjacent . landscaped buffer would result in 31 to 33 percent of the total site being retained in a natural or near natural condition. Guideline 7. That area retained in its natural condition is to be located on the southeast portion of the site, generally between the southeast corner of the property and extending west to the southwest corner of the pond. Response: The biological survey conducted indicates that the southwest corner of the site is more valuable, sensitive, unique and irreplaceable as a wildlife habitat than the southeast corner. In response to these findings, the pro- posal is designed to retain and enhance the natural fea- tures of approximately four acres of upland, thicket, wet- land and shore environments including the southwest and south edges of the pond, in order to maximize the long -term wildlife productivity of the site. Controls will be in- cluded to prevent access from adjacent properties to the sensitive habitat areas. This proposal appears to meet the spirit and intent of guideline 7. Guideline 8. A major portion of the pond should be retained; the wild- life nesting and refuge areas on the southern portion of the site should be retained as well. Response: Approximately one -half of the present surface area of the pond will be retained, along with the adjacent habitat areas at the southwest and southern edges of the pond. The length of the critical pond -edge habitat will be increased by one -third with the addition of peninsulas, bays and islands. Modifications for other than wildlife enhancement will be restricted generally to the northern portions of the pond. Guideline 9. Visual and public access to the pond and natural areas from Strander Boulevard and Andover Park West should be en- couraged. Response: Only very restricted or distant elevated views of the pond are now available from the adjacent streets. Location and design of numerous public areas such as restaurants, malls, promenades, et cetera, will provide the public with broader and closer views of the pond and adjacent natural areas as well as convenient access to a variety of controlled, view - oriented pedestrian activities. Guideline 10: Development plans, depicting the future utilization of the entire site, should be submitted at the time of waiver application review. Any proposal indicating less than full development of the entire site should contain, at a minimum, complete plans indicating treatment of the pond and adjoining wetland /wildlife areas. 29 Response: The development proposal submitted, as described in this document, covers the entire site area and includes complete plans for retaining, protecting and enhancing the pond and its most significant associated wildlife habitat areas. KING SUBREGIONAL PLAN - Puget Sound Council of Governments The proposal is consistent with subregional objectives and policies adopted by the C.O.G. on December 14, 1978. The Tukwila /Southcenter area has a preliminary designation as a "suburban center ". The following policies are applicable in consideration of the regional- planning implications of the proposal: Phased Growth Policies Policy 1 - New commercial and other intensive activities should locate in existing urban and suburban centers.... Activity Center Policies Policy 1 - Concentrations of jobs, shopping, government, busi- ness, service and commercial activities should locate in designated activity centers. Policy 4 - Retail, office, government and employment growth should locate in existing urban and suburban centers. Policy 6 - Circulation system investments relating to activity centers should give priority to pedestrian, non - motorized and public transit access. Policy 7 - Centers should be planned and designed to consoli- date transit destinations and promote pedetrian and local transit connect ions within them. 30 1 1 1 1 1 1 1 1 i A 1 f 1 l� 1 1 1 1 1 1 1 1 1 1' 1 1 1 1 1 Existing Conditions, Environmental Impacts and Mitigation Elements of the Physical Environment TOPOGRAPHY Existing Conditions The site lies in a broad, very flat alluvial floodplain formed over thousands of years by deposition of sediments during flooding of the Green River. The site itself contains a natural depression originally about five feet deep, with a minimum elevation of twelve feet above mean sea level. Partial filling of the "L- shaped" portion (see Figure 6) has increased the depth of the depression to approximately twelve feet and increased the site's maximum elevation to approximately twenty -four feet. Additional fill of about one foot occurred on a small portion of the site during construction of Andover Park West. Environmental Impact Approximately two - thirds of the site would be excavated and covered by parking structures and buildings. Some fill would be placed for landscaping adjacent to the structures. Much of the remaining 13 to 14 acres would be recontoured, primarily to improve wildlife habitat associated with the remaining pond area. The primary impacts resulting from the excavation would be associated with the truck traffic removing material from the site (see also GEOLOGY AND SOILS below). GEOLOGY AND SOILS Existing Conditions The proposed project area is located within the alluvial floodplain of the Green River. Man -made dikes now border the river and contain the river flows, and consequently flooding rarely occurs in the project area. In the recent geologic past, however, sediment carried by the ancestral Green River slowly accumulated within a relatively deep postglacial valley and filled the valley to its approximate present level. The general project area is underlain by more than 150 feet of alluvial (water- deposited) sediment, which includes layers of silt, silty sand, sand, clay and peat. These alluvial sediments occur above a "basement" of dense glacial deposits and /or sedimentary bedrock such as sandstone and siltstone. The uppermost natural alluvial soil deposits at the site consist mainly of silt, organic silt and peat. These soils are exposed at the ground surface 31 JL STRANDER BOULEVARD ■ 3 n -2.5 ,-- - - -- - - - -- - - -FENCE - - - -- POND DEAD TREES AND SHRUBS 1 Iz !w —20' -- Noise Measurement Site FORMER STREAM CHANNEL / / 0 100 200' 300 400 iun tUkWlltl Existing city center Site Conditions FIG. 6. 32 t f only in the southeast corner of the property, near the existing pond. Native soils west and north of the pond have been buried in the past by placement of fill materials. The fill consists mainly of sandy silt and silty sand with r gravel. Geologic conditions at the site indicate that development of the planned Tukwila City Center is feasible. However, the alluvial silts, clay, and peat which underlie the site are moderately to highly compressible, and surface loads such as fills or heavy buildings would result in surface settlements. For example, fills placed to raise site grades for the nearby. Southcenter Shopping Center resulted in as much as 3 -1/2 feet of settlement over a period of several years. The extensive filling near the proposed project area, as well as fills placed on the property, have probably already caused a foot or more of settlement over much of the site. The compressibility of the under- lying alluvial materials indicates that pile support will be necessary for the proposed structures. Heavily loaded buildings may require support on rela- tively long piles. Groundwater levels at the site are generally very close to the water level in the pond. Water levels are normally highest during the rainy winter months and lowest during later summer. Wintertime water levels rise to within a few feet of adjacent street grades. The fill and uppermost natural soils at the site are relatively fine - grained and do not transmit groundwater readily. Sand deposits which occur at greater depths, however, are moderately permeable. Environmental Impact The primary impact associated with the geology and soils at the site would be the excavation and removal of 200,000 to 220,000 cubic yards of fill material and soil to allow construction of sub -grade parking and foundations. Between 15,000 and 20,000 truckloads would be exported over the life of the project. It is anticipated that the material would be used as fill or for surcharging other building sites in the local valley area, and that truck movements would be mostly within the commercial /industrial areas of the valley. Construction'of below -grade parking facilities would extend below the ground- water level. Consequently, dewatering (water collection and pumping) would be necessary during construction of these facilities. In order to prevent seepage problems once the below grade parking facilities are in operation, they would 33 either have to be waterproofed and equipped with emergency pumping units, or permanent dewatering pumping systems would have to be employed. Dewatering operations can lead to consolidation of fine - grained alluvial deposits which are located within and below the dewatered areas. Consolidation of the deposits would result in settlements at the ground surface. Settlements resulting from dewatering are expected to be slight and are not expected to significantly impact areas outside the property limits, except on a very local- ized basis. Building loads are expected to result in only minor and localized settlements because structures will be founded on piles. Water level fluctuations in the pond are not expected to result in significant settlements. Mitigating Measures Dewatering- induced settlements can be minimized by limiting excavation depths below the water table. In general, sheet pile or slurry trench cutoffs used in conjunction with a dewatering system would result in less settlement than dewatering from perimeter or deep wells. Further study will be conducted to determine design requirements for grading and dewatering prior to granting of grading and building permits. Trucks carrying fill material from the site should be scheduled, as far as possible, to avoid peak traffic hours and to avoid residential areas. AIR Existing Conditions Meteorology: The closest complete weather station is at Sea -Tac International Airport which has a complete U.S. Weather Bureau station operated by the National Ocean- ographic and Atmospheric Administration (NOAA), and collects the data on tem- perature, precipitation, wind speed and wind direction. The site locality is characterized by a typical Pacific Coast marine type climate with cool, wet winters and warm, dry summers. Precipitation at Sea -Tac Airport averages about 39 inches annually, with annual variations between 24 inches and 50 inches. November through February are traditionally the wettest months with over half the annual precipitation occurring in this period. 34 t 1 i 1 t 1 • Annual average temperature is about 50 °F. Temperatures average about 40 °F in the winter months and about 65 °F during the summer months. Extreme tem- peratures of up to 100 °F in the summer and down to 0 °F in the winter occur rarely. Winter winds on the (Sea -Tac) plateau are predominantly southerly, originating from the south - southwest 30 percent of the time. Summer and fall winds are predominantly northerly with 30 percent originating from the north - northeast. Winds of less than 2 MPH are moderately rare occurring about 10 percent of the time. Wind speeds are generally low, rarely exceeding 20 MPH, but occasional storms may bring gusty winds of up to 50 MPH. Fog occurs occasionally during the fall and winter months. A monitoring station operated by the .Puget Sound Air Pollution Control Agency (PSAPCA) at Southcenter (Andover Park E.) shows that wind patterns in the valley are slightly different. Southerly (S -SW) winds occur 35 -40% of the time and northerly (N -NW) winds occur about 20% of the time. Calm conditions are more common, occurring about 20% of the time at Southcenter. Air Quality: Air quality monitoring has been conducted at several sites in the vicinity of the project. This includes stations operated by the Department of Ecology or PSAPCA: Southcenter at 401 Andover Park East, McMicken Heights at South 176th Street and 42nd Avenue South, and in Kent. These stations have been collecting data for several years. The Washington State Department of Transportation also did some monitoring at Southcenter Blvd. and 57th Avenue South for about three months in 1977. Table II summarizes the data from the four stations. As shown in Table II, pollutant concentrations vary widely in the area. The various pollutants can be summarized as follows: • Suspended Particulate Annual means are within the standards (60 mg /m3) at all sites. There was one violation of the 24 -hour maximum (150 mg /m3) at Southcenter in four years, none at McMicken Heights and 13 at Kent over a five -year period. Kent's location in the central part of the Green River Valley may con- tribute to these violations. 35 1- H 0 1--- 4 >- w J J 00 Q Q 1— O• Cr h-1 STANDARD 0 0 1 t0 U •--1 O O O N d• 14) 1--1 O • • • • O O O O O N t0 LC) d• Lt) r-1 0 •-1 • • • • CO O . N f\ 01 r- 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 co r• 01 ri 1 1 1 '--1 I M 0 'Cr O 0 • • 1 1 1 1 1 1 1 1 1 1 1974 t0 1 1 M N. 1 NO ■1 0 0 M .:1- CV 01 1 N 0 M M .-4 O O N Nt0 •-1 N • L N. 01 .--1 d- t0 0 M 1--1 r-1 CO 1 N 0 •--1 0 0 • • • N 0 0 01 1 Cr) ••1 co 0 N 0 0 r-1 • • • M U) rl r-4 • 1976 Lc) co •--1 d' t0 r-1 t0 - M 0 M .--1 O O • • • • 01 •--11-1 O t0 N O d' r� N r-1 O O •--4 • • • • 00 O O O . 01 .-.4 OOO d- r-1 r-1 •--1 N. 01 .--4 .--1 0 0 0 • • • • ^N- 0 N N 0 U7 00 N .--■ O O r--1 • • • • 01 01 r-4 ••1 N . 1978 ton C d- d- r••1 r- Old•. --1 Mr-1OO d. In to r\•- -1 d'0 t.0• --1 MN00 N d- VI 01 r•iM • LPollutant Units S- a) 4) C W S..) _C 4-' O N M 0 a) ( M Oi =�E� U0 •r• 0 Cr) +) = S_ C V) (0 r0 X 0) CL Cl.) r0 U m Z C -D a) a) r- • S- -0 r0 S.- S. C 02 0 W C 1 U t1 C d U =QcVO N t. E a EE0-a) • • 0- 0- 0. O a) 0- 0. 10 -10 S_ S- •r S- L 0 a) X 0 0 0> 0 0 0 2< •r 2 2 1 0 1 1 d• r• •-1 CO N IV i O 0 X X X C 4- 10 rtS rts C � =M< V) +.) C Y Cr) \ = (1 a) O 1O ) co ..-1 d =��� E = Urnrn EE0-a) •r- 0 0 • • 0. 0- 0. 171 4-) a) 0. 0- 10 S- C X V) O S- S- 10 f0 10 a •r- S- S- 0 Cl..) • 0- a) Z U X 0 0 0> E C 0 0 0 2< -0 S- 0 •r- 2 2 1 0) r- 0 S- O 1 1 d• r- 70 rt 0 Si r•4 M N 10 C 02.0 S- W I O 0 X X X C D. C 'Cr O 4- CO 10 10 C V)QN0 �MMMQ N V) E E C1 tl 00.N -1 E •• •• 0- 0. V) VI S.- O a) 0 U U O C C 2 a) a) 1 S- i •-1 5- S- 0 0 a) X O U C ICS U O ()MOO 0 36 1 r 1 s r t t t 1 1 r 1 1 1 1 1 f 1 t t 37 (ozone) to .12 the EPA changed the photochemical 00 LO Lf) 000N in .-1 O CO O u') C1 M L[)C M CV I I ct I I I I r--I 1- O ri LO I I Lfl I I M 01 1 1. .--1 u) O O CO 0 0 O Lf) •CT I 1 Lc) MO C'0) C1.1 ri C) I •Zr.--I CO CO ONO •1 r4 1 I 1 1 O N O Cr) CO LO I 10 .--I N 00 1 1 1 I 1 1 I CV 4.00 d • M •1 01 4.0d• 1-I CV. -100 • • 1-OO O I I I I OCO0 CI' O ri 001cr1•••I Ch 1.-1 O O • • • • 0 10 0 .--1 .--I • I I CV C1 ri (7 cv") as LC) C M. --100 .N-I CCOOO I I I I cn 1-) t •r 111 = C Cl) . U •r m U x M E ai 10M co Lt) r- E E •-■ O \ \ " Uv)al •r a O 4.4 S_ C X . N 10 10 10 CV O.. CU X O M C •0 S_ a) Cl) I a S_ 1=1 10 0 S. C O = O a1. C I U CL . C U v14cV0 = v) G E IZ. EE 0. a) • • O_ O. 0. al O f2 f1 10 •0 S.. S_ •• S.. L O CU X a O O> 0 0 0 =< .r = = I 0 1 I C1• '- r♦ 41') N 10 S- 0 X X X C 4- 10 10 10 C r-EEXQ = V) E E as co cv 0 ,. • .: E C1 fZ N N S. CU CU a U U O C C = CU CU I S. S. 4--1 5- S_ O O CU X U U C b U U OXOO N O • • E E CU Cl. 0. -0 0. 0. •r X S_ S_ O O O C O O 0 = = E I I ri CO C O X X LI 10 .1d S-Xz 10. U +) • o 'n v) > r m CU > S_ < N +4 .0 C 4) CU N. U LC) .0 as = 0 v) • • E E Cl) O CL CL f1 .r X S_ S- O O a C 0 0 0 = = X 1 1 ri CO C O X X 1] 10 f0 s z 10 U 37 (ozone) to .12 the EPA changed the photochemical • Sulfur Dioxide There were two violations of the one -hour maximum in 1973, at Southcenter and McMicken Heights. The standard was not exceeded for any of the other measurement periods shown. The sulfur dioxide concentrations are attri- buted primarily to the emissions coming from the ASARCO smelter in Tacoma. • Ozone There have been numerous violations of the photochemical oxidant (as ozone) standard at Kent, both the old standard and the one adopted in January of 1979. McMicken Heights was in violation of the old standard on several occasions but has never exceeded the new one. Kent appears to be the recipient of "smog" which occurs in the Seattle area and drifts south under northerly winds during the sunny summer months. The photo- chemical reaction which creates oxidant appears to reach a maximum in the Kent area. • Nitrogen Dioxide Nitrogen dioxide was measured for three years at McMicken Heights and no violations were observed. • Carbon Monoxide Carbon monoxide was measured in 1972 -73 at McMicken Heights and no viola- tions were recorded. In 1977, the Washington State Department of Tran- sportation measured carbon monoxide for three months (Jan -Mar) just north of I -405 on Southcenter Boulevard. The maximum eight -hour con- centration reached but did not exceed the standard. Vehicle activity is the primary source of photochemical oxidant and carbon monoxide. The site is located in a non - attainment area for both carbon mon- oxide and photochemical oxidant. This non - attainment area covers most of the central Puget Sound Basin. A transportation control strategy has been estab- lished by the Department of Ecology and includes a vehicle inspec- tion /maintenance program to reduce vehicle emissions in order to attain the ambient air quality standards by 1987. 38 Environmental Impact Air pollution generated by the completed project will impact the site vicinity and would be carried and dispersed by air currents, diffusing to ambient concentrations within a few hundred feet of the site boundaries. Vehicle emissions from traffic generated by the project would disperse similarly from adjacent traffic routes. The primary area of impact, then, would include the general vicinity of the site, Interstate 5, Strander Boulevard, Southcenter Parkway and Andover Park West, as indicated in the TRANSPORTATION AND CIRCU- LATION section of this report. Existing traffic would still provide the bulk of vehicular pollutants. General pollutants resulting upon completion of a project of this type can originate from three possible sources: 1) pollutants emitted from the heat- ing of buildings, 2) pollutants emitted from solid waste incineration, and 3) pollutants from vehicular activity both in the parking areas and added to existing arterials. There would also be a short -term increase in particulate pollution levels during the construction period. At this time, it is expected that the buildings in the proposal would be heated by electricity or natural gas. The emission of pollutants resulting from heating this project is expected to be negligible. Solid waste would be removed by the local refuse disposal service so there would be no incinera- tion on the site. Vehicular activity would create the majority of pollutants, primarily carbon monoxide. The proposal is estimated to generate a total probable traffic volume of approximately 28,000 additional vehicle trips as shown in Table X and distributed as shown in Figure 12, TRANSPORTATION AND CIRCULATION sec- tion. The current federal standards are becoming more stringent, however, which will cause a decline in vehicle - related emissions. Based on existing data and implementation of federal law, vehicle emissions are expected to decline as shown in Table III for the various vehicle speeds. As shown in Table III, the emissions are expected to decline an average (based on 20 mph) of 55% between 1979 and 1985. Therefore, in order for traffic to offset the predicted 55% decline in emissions, the volumes must increase ap- proximately 120 %, slightly more than double the present levels. 39 TABLE III CARBON MONOXIDE EMISSION FACTORS FOR VARIOUS VEHICLE SPEEDS* (gm /mi) *Assumes an engine condition 40 percent hot stabi- lized, 30 percent hot start and 30 percent cold start. Vehicle distribution is 90 percent autos, 8 percent light trucks and 2 percent heavy trucks. Based on a California Division of Highways' line source diffusion model, the predicted changes in concentrations (in percentages) are shown in Table IV. The model assumes a receptor point under the same wind -road orientation, same wind speed and same atmospheric stability. The only variables are the emission rates and the traffic volumes. TABLE IV PREDICTED DECLINE IN CARBON MONOXIDE CONCENTRATIONS BY 1985 Speed With Proposal 10 20 30 1979 119 66 42 1985 48 29 21 *Assumes an engine condition 40 percent hot stabi- lized, 30 percent hot start and 30 percent cold start. Vehicle distribution is 90 percent autos, 8 percent light trucks and 2 percent heavy trucks. Based on a California Division of Highways' line source diffusion model, the predicted changes in concentrations (in percentages) are shown in Table IV. The model assumes a receptor point under the same wind -road orientation, same wind speed and same atmospheric stability. The only variables are the emission rates and the traffic volumes. TABLE IV PREDICTED DECLINE IN CARBON MONOXIDE CONCENTRATIONS BY 1985 As shown in Table IV, even with the increased traffic created by the project, there is expected to be an overall reduction in carbon monoxide concentrations. Based on existing data (Table II) the maximum recorded carbon monoxide con- centration is 9 ppm (10 mg /m3), equivalent to the eight- hour standard. With- out the project, "worst case" eight -hour concentrations are predicted to be between 5 and 6 mg /m3 in 1985. With the project, the concentrations are predicted to be between 7 and 9 mg /m3 - within the 10 mg /m3 eight -hour stan- dard. 40 s 1 Without Proposal With Proposal SSW Wind - East of Andover Park West -44% -12% South Wind —North of Strander Blvd. -49% -27% As shown in Table IV, even with the increased traffic created by the project, there is expected to be an overall reduction in carbon monoxide concentrations. Based on existing data (Table II) the maximum recorded carbon monoxide con- centration is 9 ppm (10 mg /m3), equivalent to the eight- hour standard. With- out the project, "worst case" eight -hour concentrations are predicted to be between 5 and 6 mg /m3 in 1985. With the project, the concentrations are predicted to be between 7 and 9 mg /m3 - within the 10 mg /m3 eight -hour stan- dard. 40 s 1 Over the same time period, (1979- 1985), hydrocarbon emissions are expected to decline approximately 50% and oxides of nitrogen emissions about 40 %. There- fore, the potential for photochemical oxidant production due to the increased traffic volumes, with the project is expected to remain at the same levels that are presently occurring. There would be a short -term increase in summertime dust levels due to con- struction. However, this would be confined to the area under construction and would cease upon completion of construction and landscaping. Watering pro- cedures and good operational techniques would keep dust levels to a minimum. Mitigating Measures Dust resulting from construction work can be minimized through the use of good operational techniques such as watering of exposed areas. Puget Sound Air Pollution Control Agency regulations require that precautions be taken to minimize the entrainment of dust in the ambient air. Other precautions should include careful design of all street and driveway systems to provide the best circulation patterns designed to reduce traffic congestion and vehicle idling time. The continued enforcement of the federal exhaust emission standards will be a factor in reducing future carbon monoxide, hydrocarbon and oxides of nitrogen emissions from motor vehicles. Presently, proposed state legislation requiring maintenance and inspection of vehicles might further reduce regional and local air pollution problems. See Mitigating Measures in the TRANSPORTATION AND CIRCULATION section for methods to improve traffic flow. WATER Existing Conditions Surface water on the site consists primarily of the pond. The size and shape of the pond varies through the year due to seasonal fluctuations in water level, but it generally covers approximately sixteen to seventeen acres. The land now covered by the pond was dry prior to 1974, except for a few small low spots which held some water only during the rainy season when the local water table rose to near surface. As surrounding land was filled for build- ings, rail lines and roads over the past 20 years, the natural drainage from 41 the pond to the Green River was gradually shut off, and the local water table gradually rose. During the winter of 1974 -75, groundwater seepage, local surface drainage and stormwater backing up in the area drainage system, which was constructed at a higher elevation than the low portion of the site, collected and formed a permanent pond. The major sources of surface water to the pond now result from groundwater seepage and from backups in the area storm sewers in Andover Park West. During periods of high flows in the Green River, the outfall pipe for the storm sewer system serving the general project area is below water, and stormwater from the entire area backs up in the system and flows to the pond. During the December, 1975 and 1977 storms, much of the site was flooded. Thus, the pond is presently serving as a stormwater storage pond for the City of Tukwila's storm sewer system in the Southcenter area. The drainage basin served by this storm sewer system is estimated to comprise approximately 1,700 acres. The pond presently provides approximately 140 acre -feet of storage capacity for on -site as well as general area stormwater (see UTILITIES section for more detail). The natural drainage from the hillside to the west that once passed through the site has previously been intercepted and directed to a separate drainage system south of the site area, and all other adjacent lands now drain to the city's storm sewer. Consequently, the only surface water which drains directly to the pond is from the site itself. During the winter months, the pond water level is very high and portions of the fill areas north and west of the pond have standing puddles. During the summer months, the pond water level drops up to two or three feet below the level of the storm sewer outlet. Observations made during August, 1979, indicate that the minimum depth of the pond is now approximately 3 to 4 feet during the dry season. Water quality within the pond and mud from the bottom of the pond were sampled and analyzed in August, 1979. The results of the analysis are presented in Table V. Sample 1 was a composite sample from the northeast corner of the pond, and Sample 2 was a composite sample from the southwest corner of the pond; the mud sample was taken from the eastern edge of the pond. 42 i a t 1 1 r J 1 r t t TABLE V ANALYSIS OF WATER AND SOIL SAMPLES The analysis yielded fairly typical results for ponds. The total coliform bacteria is very high, presumably due to the substantial quantity of ducks and other birds in the pond. The dissolved oxygen levels are high, probably due to the large surface to volume ratio of the pond allowing for sufficient exchange with the atmosphere. BOD, COD, oil and grease and metal concentrations are typical of levels normally found in urban stormwater runoff. Suspended and 43 #1 Water Sample. #2 Water Sample BOD 14.0 mg /1 10.0 mg /1 COD 263 ppm 343 ppm pH 8.4 8.1 Dissolved Oxygen 9.2 mg /1 8.5 mg /1 Nitrate 0.1 ppm 0.6 ppm Oil & Grease 6.8 ppm 5.8 ppm Phosphate 0.01 ppm 0.01 ppm Suspended Solids 14.7 ppm 41.2 ppm Dissolved Solids 143.7 ppm 141.8 ppm Turbidity 44 FTU 40 FTU Mercury 0.001 ppm 0.001 ppm Copper 0.10 ppm 0.10 ppm Zinc 0.10 ppm 0.10 ppm Lead 0.05 ppm 0.05 ppm Total Coliform 3,500 MPN /100 mis 24,000 MPN /100 mis Fecal Coliform 78 MPN /100 mis 110 MPN /100 mis Mud Sample Mercury 0.24 ppm Copper 18.4 ppm Zinc 30.6 ppm Lead 3.7 ppm The analysis yielded fairly typical results for ponds. The total coliform bacteria is very high, presumably due to the substantial quantity of ducks and other birds in the pond. The dissolved oxygen levels are high, probably due to the large surface to volume ratio of the pond allowing for sufficient exchange with the atmosphere. BOD, COD, oil and grease and metal concentrations are typical of levels normally found in urban stormwater runoff. Suspended and 43 dissolved solid levels are about 10% of the levels normally found in stormwater runoff. The metal concentrations in the mud indicate that there is substantial deposition of solids containing metals in the bottom of the pond. There are no established criteria for evaluating pond water quality, but over- all, the pond's water quality is good. Nutrients, especially phosphates, are very low and may be a limiting factor in algae growth. This suggests that the pond may be particularly sensitive to nutrients and that additions of nutrients from development (lawn fertilizers or detergents) or other sources could cause substantial algae growth, possibly accelerating eutrophication of the pond. This pond is particularly vulnerable since there is no significant through - flow of water to provide flushing. It is expected that, with the current lack of flushing, metal concentrations from runoff will continue to increase in the bottom sediments. The pond will also continue to act as a trap, filtering out up to 90% of the solids found in stormwater runoff. The water elevation of the pond is approximately the same as the elevation of the groundwater table on the site. The bottom of the pond is very slowly permeable, thus the two water levels will slowly equalize after changes occur on the site. Such equalization may take up to a month or more depending on the extent of the differential. Environmental Impact Potential changes to surface water could result from increased runoff, pollu- tants from developed surfaces and changes in groundwater or pond levels. On -site surface water runoff volumes would be increased due to replacement of soil and vegetation with impermeable surfaces, primarily roof areas. The proposal calls for collection of stormwater from the site in a system that would direct runoff to the pond. During much of the year, the pond would remain below the level of the outlet to the storm sewer system and would lose water only by percolation and evapora- tion. The pond would have the capacity to store all runoff from the site during periods of high river levels or whenever backups occur in the area system. A flapgate would be installed to prevent inflow from the outside system. The impact of removing the pond's storage capacity from the areawide drainage system is discussed in the UTILITIES section. 44 l'he on -site stormwater system would incorporate silt traps and oil /water sepa- rators. With proper maintenance, these facilities would prevent significant quantities of silt or petroleum products from entering the pond or the City's storm sewer system. Nutrients and some heavy metals would remain and the metals would continue to build up in the bottom sediments as the pond filters out the suspended solids. The rate of buildup would increase slightly over present rates.` The proposed facilities would protect water quality under most circumstances if properly maintained. Excessive applications of fertilizers to landscaping could increase the nutrient loading of the pond, in turn causing accelerated algae growth and decay, followed by lowered oxygen levels and general deterioration of the pond's water quality. The reduced volume of the pond would tend to concentrate nutrients and increase summertime water tem- peratures; both factors leading to reduced oxygen levels. The level of the pond would be controlled to maintain seasonal fluctuations critical to many species of wildlife that use the pond environs as a habitat. Although the proposal may result in slight localized changes in the groundwater table, the pond level would not be significantly affected. Mitigating Measures Retention of the pond and collection and detention of storm water are mitiga- ting measures incorporated in the proposal. Silt traps and oil /water separa- tors will be used to reduce contaminant levels in stormwater runoff. Control of the pond level outflow to maintain current seasonal fluctuations will be implemented. These factors are expected to maintain the water quality of the pond. Other mitigating measures are available to maintain water quality in the event of unanticipated impacts such as excessive nutrients from fertilizers or large numbers of domestic ducks. These include additional dredging to provide ade- quate depth in the pond, circulating and aerating devices, and frequent sweep- ing of parking areas on the site as well as parking areas and streets adjacent to the site. Provision of adequate water depth increases the volume of water (providing a dilution factor and decreased temperatures), which results in higher oxygen levels if the water is circulated. Circulation exchanges cool bottom water with stagnant, warm surface water. Aeration increases oxygen within the water. Lower temperatures and higher oxygen levels allow the pond 45 to utilize additional nutrients if they are inadvertently introduced to the pond without a reduction of water quality. EPA (U.S. Environmental Protection Agency) studies have identified street sweeping and litter pickup as effective measures to reduce pollutants, primarily suspended solids, in runoff. VEGETATION Existing Conditions The vegetation of the site is primarily grasses with borders of trees and shrubs along the pond edge and the western and southern property boundary (see Figure 8). Along a former stream channel in the southeast corner of the site there is a small area of pond lillies. Very limited cattails occur in the northeast corner of the pond. The vegetation species present on the site are common and are significant primarily for providing wildlife habitat. The vegetation and habitat types are discussed in more detail in the WILDLIFE section following. There are no rare or endangered species and no agricultural crops on the site. Environmental Impact Under the present proposal, most of the vegetation on the site would be elimi- nated in phases by construction. The southern shorelines and the flooded brush area of the pond would be preserved. The remainder of the eleven -acre open - space parcel would be planted with a variety of grasses, shrubs and trees to benefit wildlife. Landscaping would be provided on several other portions of the site: adjacent to the open -space area, around buildings, around the site periphery and within surface parking areas. Mitigating Measures The proposal incorporates preservation of the vegetation along the southern shoreline and the flooded brush area of the pond and on the western upland area. The remainder of the eleven -acre open space parcel would be planted immediately upon completion of construction. WILDLIFE Existing Conditions The collection of data concerning wildlife of the site consisted of several site visits and review of existing documents such as the Seattle City Light EIS 46 for the site prepared in 1976. During site visits (August, 1979), species were observed informally and listed, and habitat types were analyzed. Habitat types were subsequently further analyzed using aerial photographs. Casual observa- tions of species observed on the site at other times of the year were also considered, but no long -term objective studies of wildlife have been conducted on the site. The habitat types identified are illustrated in Figure 7. A brief description of the habitat types and their utilization by wildlife follows. The dry grassland and dry grassland with extensive winter puddles occur along the margins of the site on former fill. They support rather sparse, dry grass vegetation species. During the summer these areas are important nesting habi- tat for species such as cottontail rabbits, savannah sparrow, pheasant and quail. They also provide valuable feeding areas for species such as the goldfinch. In the winter, large areas of this dry grassland have extensive shallow puddles. The puddles transform these areas into valuable feeding areas for duck species such as pintail. These areas, are also lightly utilized by migra- ting shorebirds in March. The tree /shrub border that surrounds part of the site provides a valuable visual screen for the pond and "edge" habitat for species such as the song sparrow, and cover for several species using the adjacent grassland. The brushy pond edge has a similar value in providing edge habitat for the pond. In general, the overall pond edge is the most productive and critical habitat of the site. The edge provides essential cover for species using either the grassland on one side or the pond on the other. Casual observation will indicate that even most duck species prefer the pond edge to the open water in the middle of the pond. The brushy edge provides an important visual buffer for the pond, shelter from wind, cover from predators and nesting habitat for several species such as warblers and song sparrows. The pond edge is also used exclusively by such species as the green heron and the great blue heron. By comparison, the open pond is used relatively lightly by resting and feeding ducks. The fence posts running through pond are used heavily by resting ducks and an occasional gull. 47 No live fish have been seen in the pond to date, although the pond is appa- rently capable of supporting aquatic life. Grebes have been apparently fish- ing, and one fish has been found on the shore. Fish which may be living in the pond include the threespine stickleback, prickly sculpin, longnose and speckled dace and other small freshwater fish. Other aquatic animals, such as snails and frogs currently exist in the pond. The flooded brush area in the southwest corner of the pond is an unusual habitat that provides excellent cover for a distinct group of species such as cedar waxwings, tree swallows and band - tailed pigeons in the summer. In the winter, this area appears to provide the preferred cover of the mallard ducks on the site. This habitat is temporary in that it will change in five to ten years as the dead vegetation decays. It is an unusual habitat that is diffi- cult to duplicate. The seasonal mudflat along the southern shoreline provides the required habi- tat for another distinct wildlife group. A variety of shorebirds such as solitary sandpipers, dowitchers and plovers wander over the mud and in the shallow water feeding on insects. This area stays flooded during the winter and spring, then slowly becomes exposed in August and September as the.migrat- ing shorebirds return from the north. Adjacent to this seasonal mudflat is the wet grassland in the southeast corner of the site. This area is largely flooded in the winter providing excellent feeding and loafing areas for many wintering ducks. Other observers have stated that the area is used by nesting ducks in the spring. The success of the nesting is probably limited due to lowering water levels, increasing predation and nest desertion. The area was totally devoid of any surface water in August of 1979, although a small area of pond lillies indicated that surface water was probably present through much of the summer. Throughout the seasons, the pond site hosts a wide variety of wildlife species. The species occurring on the site change dramatically through the year due to changing site conditions and established migration patterns. In the winter, the site is dominated by ducks that spend the winter at the site before flying north to nest. In spring there are migrating shorebirds, ducks and songbirds in succession. Also in spring, there are nesting birds such as ducks, song- birds, pheasant and quail. In August and September, the shorebirds pass 49 through again followed by the waterfowl. Some species such as the song sparrow, pheasant, quail and several of the duck species are year -round resi- dents. Many species such as the savannah sparrow and the swallows spend the spring and summer at the site then migrate south for the winter. The variety and productivity of the site are unmatched on any comparably sized site in the Green River Valley or the Greater Seattle area. This factor combined with the close proximity to intensively developed adjacent land make this site truly unusual and give it regional significance as wildlife habitat. No rare or endangered species are known to inhabit the site. Environmental Impact In summary, the most productive habitat types currently found on the site would be preserved and supplemented within a smaller open area. Additional food and visual screening would be provided, but the dry grassland habitats would be eliminated. Overall, there would be a substantial reduction in abundance of wildlife, but only a minor reduction in species found on the site. An eleven -acre parcel would be retained (see Site Plan, Figure 3) in open space with the majority of the area developed exclusively for wildlife habitat. Within this area, the flooded brush habitat, the mudflat and brushy pond edge along the southern shoreline, and several acres of open pond would be retained. Much of the eleven -acre open space would be subject to intensive modifications for the sole purpose of improving wildlife habitat diversity and productivity. The proposed modifications would continue to provide the diversity of habitat types presently found on the site, increase the most productive habitat types and provide visual buffers. The present fluctuations in pond water levels would be replicated artificially. Collectively, these modifications should continue to provide suitable habitat for the majority of species presently utilizing the site, although the overall abundance of wildlife would be reduced. Extensive grading would create bays, peninsulas and islands in the pond, resulting in increased shoreline and pond edge habitat (the most productive habitat of the site). While the existing pond has approximately 3,360 feet of shoreline, approximately 4,480 feet of shoreline would be provided by the proposed modifications to the pond (about 1,600 feet of shoreline would be on 50 islands). Approximately' 960 feet of the total shoreline area, along the northern edge of the pond, would be open to controlled seasonal human use and would therefore be used by only the more tolerant species of wildlife. This human -use area would include interpretive displays to increase the public's knowledge of and awareness of the variety, productivity and sensitivity of the habitat and wildlife. In addition to increasing pond edge habitat, the proposed islands would provide buffers from the structures and human activity and would provide loafing, nesting and feeding areas for ducks, secure from predators (e.g., dogs). The large island at the western end of the pond would be graded with gradual slopes and low spots which would flood in the winter, and planted in grass to recreate the existing wet grassland habitat type currently found in the southeast corner of the site. The productivity of this area would be further increased by the planting of more valuable food grains, such as wild rice and wild millet, instead of the existing common grasses. Areas of food grains would also be planted along the exterior shorelines. Shrubs and trees, such as hawthorn, dogwood and snowberry, also provide food for other species of wildlife as well as providing visual buffers. Shrub and tree buffers would be planted along much of the pond edge and along all but the northeastern border of the open space'parcel. Although visual buffers would be provided by shrub and tree borders, the existing level of separation of human activity from wildlife by buffering and open space would be revised. Human activity would be confined to the north- eastern corner of the pond, but would increase substantially within that area. Much of the existing seasonally flooded grasslands along the northern and western portions of the property would be lost. These areas provide winter feeding for such species as pintail and widgeons. They also provide the habitat required for pheasants, cottontail rabbits, mice, savannah sparrows and, to some extent, quail. Therefore, these animals and a few others may be significantly reduced or eliminated from the breeding populations. The closeness of buildings, as a factor by itself, is not expected to have a major impact on wildlife as demonstrated by the existing Bon Marche warehouse located near the southern shore. Modern hotels and office buildings provide 51 people inside with little opportunity to interact with or disturb wildlife. The tall buildings proposed are designed to be located far enough apart that they should not significantly disrupt flight patterns into and away from the pond. The substantial construction activity required for the development of the proposal (buildings and habitat modification) would result in significant tem- porary disturbance to all wildlife. The magnitude and duration of the disturb - ance would be controlled by the staging of construction. Upon completion of construction within the open space, approximately one to two years would be required for vegetation to become re- established and suitable for intense wildlife use. The success of the proposed habitat preservation and modification is dependent upon diligent design, careful construction practices, maintenance and perma- nent protection from further encroachment of human activity. Mitigating Measures Subsequent to submission of the conceptual development proposal and approval of the preliminary waiver, the detailed wildlife study was conducted in con- junction with the preparation of this EIS. A number of recommendations were made by the wildlife biologist and were incorporated, through design modifi- cations, into the current proposal. These include: 1. protection of the productive southern shoreline; 2. protection of the unusual flooded brush habitat; 3. retention of eleven acres of open space and pond; 4. reconstruction of wet grassland habitat;. 5. reconstruction of approximately the same length of pond edge habitat as the existing pond, with additional shoreline length; 6. provision of shrub /tree visual screen along the boundary of the open space parcel and the edge of the pond; 7. creation of islands to provide visual buffers and secure nesting, feeding and loafing areas for waterfowl; 8. control of the water level to replicate natural seasonal fluctua- tions; 9. elimination of human access to the southern and western "natural" areas; 52 t r i 1 i 1 t t r t t t t t 10. addition of interpretive displays at the controlled viewing loca- tions; 11. elimination of an internal boulevard street adjacent to the pond; 12. increased setback of buildings from the pond and "natural" area. NOISE Existing Conditions A general description of noise and pertinent regulations are found in Appendix A. To determine the existing noise levels on the site, measurements were taken at three locations at three different times of the day. The measurement locations are shown on Figure 6. A summary of the noise readings is shown in Table VI. TABLE VI EXISTING NOISE LEVELS (dBA) Time Site 1 Northwest Corner of the Pond Site 2 50 Ft. South of Strander Blvd. Site 3 50 Ft. West of Andover Park West Midday (1 -3 PM) L10 60 60 64 L50 58 55 59 L90 55 52 , 54 Peak Hour (5 -6 PM) L10 56 65 63 L50 54 60 58 L90 52 58 53 Night (12 -1 AM) L10 54 58 54 L50 52 54 50 L90 51 52 48 Ldn 60 62 59 53 Noise measurements were taken on Tuesday, August 20, 1979, with a Bruel and Kjaer 2209 Type I Sound Level Meter with a 4165 microphone and wind screen attached. The meter was calibrated with a 4230 calibrator. The weather was overcast and temperature was about 70 °F, cooling to 50° at night. Winds were northerly in the daytime at 3 -5 MPH, gusting to 7 -10 MPH, and were calm during the night readings. The principal source of midday noise at Site 1 included construction work (hammering, sawing, etc.) on a building under construction immediately west of th'e project site. Traffic on Interstate 5 was audible in the background and jet take -offs from Sea -Tac Airport could be heard in the distance. During the peak hour and night readings, the traffic on I -5 was the dominant noise source. At Site 2, the source of the noise during the midday measurements was traffic on Strander Boulevard. Peak hour sounds were due to traffic on Strander Boulevard, several plane flyovers and a train whistle. Interstate 5 was the predominant noise source during the night readings, augmented by a jet take -off from Sea -Tac Airport. Site 3 noise sources included traffic on Andover Park West, a train and a plane flyover during the midday measurements. Peak hour noise sources were traffic on Andover Park West, I -5, several chirping birds, plane flyovers, a jet take- off from Sea -Tac Airport and a singing UPS truck driver. Nighttime sources were due to occasional local traffic with I -5 and I -405 traffic clearly audible in the background. Based on EPA criteria and State regulations, adverse noise levels currently exist on the entire site. The principal noise source is traffic on adjacent streets and I -5 and I -405. Environmental Impact The two principal noise impacts created by the proposal will be the long -term increase in noise levels created by additional traffic in the vicinity of the site and a short -term increase in noise during construction of the new facili- ties. Table VII shows the predicted Ldn levels with and without the proposal. 54 1 r 1 t t 1 1 t t 1 1 t t t TABLE VII PREDICTED Ldn NOISE LEVELS (dBA) Noise Measurement Existing Level Predicted Level Without Proposal Predicted Level With Proposal Site (1979) (1985) (Change) (1985) (Change) 1 60 61 +1 61 +1 2 62 63 +1 64 +2 3 59 61 +2 63 +3 As shown in Table VII, the noise levels will increase 1 -3 dBA on all sides of the project. Noise levels will increase at least 1 dBA without the project being constructed and occupied. The project is predicted to add one additional dBA to the noise level on each measurement site. According to EPA criteria, there will be a slight increase in noise levels. A three dBA change is the minimumc"necessary for people to normally be able to detect a difference in noise levels. Adverse noise impacts currently exist on the site and will be''maintained with or without the project. Since the increase in traffic will be confined principally to daytime hours (9 AM -9 PM), the late night noise levels will remain essentially unchanged from existing conditions (shown in Table VI). There will also be a short -term increase in' daytime noise levels due to con- struction activity. The chart on the following page lists typical noise levels which can be expected from the types of equipment used in construction. Noise from construction activities would generally range from 69 to 95 dBA, with some higher peaks if impact equipment were used. Pile driving may produce peak noises in the range of 110 to 130 dBA, and average 100 dBA during opera- tion. Approximately 70 to 80 days of pile driving are required, in phases. Mitigating Measures Long -term mitigating measures are difficult to implement because the principal noise increase is due to traffic generated by and adjacent to the proposed development. The predicted noise levels address the "worst case" traffic generation. Measures to mitigate traffic impacts are found in the TRAFFIC AND CIRCULATION section.- Auger drilling as an alternative to pile driving could significantly reduce construction noise levels. 55 Noise Level (dBA at 50 feet) Earth - Moving Equipment Tractors 70 - 95 Trucks 82 - 94 Backhoes 71 - 93 Graders 80 - 94 Compactors (rollers) 73 - 74 Materials - Handling Equipment Concrete Mixers 75 - 88 Concrete Pumps 81 - 84 Impact Equipment Pneumatic Wrenches 82 - 88 Jack Hammers (and rock drills) 81 - 98 Other Vibrators 69 - 82 Saws 72 - 82 Noise abatement procedures during construction could include: • The use and maintenance of properly operating mufflers and quieting devices; • The use of the quietest available machinery and equipment; • The use of electric equipment in preference to gas, diesel or pneumatic machinery; • Locating construction equipment as far from nearby noise sensitive pro- perties as possible; • Shutting -off idling equipment; and • Limitation of construction hours to coincide with the normal workday period (between 8:00 AM and 6:00 PM). NATURAL RESOURCES Existing Conditions The primary natural resources of the site are open space, undeveloped land and wildlife habitat. The site originally contained prime agricultural soils but previous filling and-flooding of the site and off -site improvements (utili- ties, roads, railroads, adjacent commercial land use) have combined to make any kind of agricultural use of the site infeasible. Environmental Impact Approximately 70 percent of the open space would be converted to developed human use. The wildlife habitat area would be reduced, but the most unique and 56 productive habitats would be preserved and enhanced. Options for alternative site uses would be foreclosed for the foreseeable future.. Fossil fuels would be used during construction and by vehicles travelling to and from the site after completion. Sand, cement, steel, aluminum, lumber and other resources would be used in quantities typical for commercial building construction. Electrical energy and natural gas would be consumed by operation of the facility. LIGHT AND GLARE The proposed structure would emit light at approximately the same intensity as the nearly Southcenter complex and the other commercial structures in the area. No light- sensitive facilities would be adversely affected by the light from the proposed development. RISK OF EXPLOSION OR HAZARDOUS EMISSION A temporary risk of equipment accidents would occur during construction. How- ever, safety requirements are quite stringent and largely compensate for any potential hazards. Safety precautions would be observed during construction and the risk of explosion or emission would be no greater than at any other comparable facility. All safety requirements will be met. No offices or stores carrying hazardous materials are expected to locate on the site. Any voids below the structural parking deck would be vented to eliminate the possibility of a buildup of methane gas from decaying organic matter in the alluvial soils. LAND USE Existing Conditions In the 1950's, Tukwila was primarily a semi -rural residential community with virtually no commercial /industrial development. The last two decades of intense development have changed Tukwila into a city with about one third of the total land base (2,500 acres) developed in industrial and commercial land use, and only about one fifth of the land left undeveloped. 57 The chart below shows a percentage distribution of land uses within the City of Tukwila. As shown, the percentage of land used for residential purposes is only about 6% and about 12% is in freeway use, both figures uncommon for municipalities. TUKWILA'S LAND USES BY PERCENTAGE OF LAND BASE USE CODE 5% 10% 15% 20% 93 - UNDER CONSTRUCTION !UNDEVELOPEDI 81+ III MULTI- FAMILY RESIDENTIAL 20 -39® PROCESSING 10,11 _ AGRICULTURE 40,45 -49 COMMUNICATIONS 7D -79 PUBLIC SERVICES 80 ® SINGLE FAMILY RESIDENTIAL 60-69 COMMERCIAL SERVICES 92 WATER AREAS IUNDEVELOPEDI 43 HIGHWAYS 91 NON- COMMERCIAL FOREST IUNDEVELOPEDI 52-59 RETAILING 42,50,51 DISTRIBUTION 44 ` ' - FREEWAYS 90 UNDEVELOPEDIVACANTI The land use in the vicinity of the proposed development is shown in Figure 8. This area is strongly defined on the north by I -405 and on the west by I -5. To the east, the area is more loosely defined by the Green River and to the south by South 180th Street. The two predominant land uses in the vicinity are commercial and industrial. The commercial land begins at Southcenter, a 1,200,000 square foot shopping center just north of the proposal site, and continues south with a mixture of wholesale and retail commercial outlets, restaurants, a hotel and offices. The eastern portion of the vicinity is predominantly light industrial and includes warehousing, light manufacturing, offices and scattered commercial outlets that cater primarily to the employment base of the area. 58 ;JJjjJJffJJ: i • •• •i • • ..r..L ::::.:Jl •i! ir;. ,, ' .c ::: The proposal site is in the most intensive commercial land use area in Tukwila. Directly west of the site, a new five -story office building and an eight -story hotel are presently under construction, further intensifying the commercial land use trend of the area. The 38.9 -acre site itself is currently undeveloped and not used for human activity. It includes a pond of approximately 16 acres which provides habitat for various wildlife species. The dry portion of the parcel is also a produc- tive wildlife area (see the VEGETATION and WILDLIFE sections of this report). The current zoning on the site is C -M (Industrial Park). Land to the east and south of the site is also zoned C -M. To the north, the Southcenter site is zoned C -PR (Regional Planned Business Center) and to the west, there is a mixture of zones including primarily C -M, and also some commercial and resi- dential zones (see Figure 9). The C -M zone is intended to allow all uses permitted in the C -1, C -2, and M -1 districts of the Tukwila Zoning Code or, in other words, all commercial, business and light industrial uses. Two of the proposed uses (retail and offices) are permitted outright in this zone and the third major use, hotel, is permitted with an approved conditional use permit. The C -M zone provides for parcels greater than five acres in size to exceed thirty -five feet or three stories in height by one additional story for each additional two and one -half acres within the site boundaries. This criteria would allow development on the site to build to a height of 16 stories, if approved by the City Council. The Comprehensive Land Use Plan for the City of Tukwila designates the subject site and land to the north, west and south for commercial use. Land to the east is designated for light industrial use. The pond on the site is additionally designated as requiring special development considerations. Specific guide- lines for developing the site and preserving the pond have been adopted by the council and are detailed in Resolution 656 (see DESCRIPTION OF THE PROPOSAL). Environmental Impact The proposed development would convert about 70 percent of the . site from its present undeveloped state to retail shopping, office and hotel use. The proposed floor -area ratio of approximately 1.2 square feet of building for each square foot of land would represent a more intensive land utilization than now 60 tykwilci city center Zoning 61 exists on any parcel of this size in the region outside of a few major downtown areas. The eleven acres of pond and wildlife habitat,.along with additional adjacent park -like landscaping, would provide a unique open space amenity. The proposed project should have no adverse impact on any existing or potential use of adjacent lands or other land in the vicinity. However, the intensity of the proposal may have the indirect effect of encouraging further intensi- fication of development on other nearby properties over the long range due to two significant aspects. First, the regional drawing power of the proposed shopping center in combination with Southcenter and the "home furnishings center" along Southcenter Parkway may encourage additional or more intensive retail development on vacant or under - utilized parcels. This would not be a major change in existing trends, but the proposal may stimulate somewhat more retail footage than would otherwise be built over the next decade or so. The second significant aspect is the large concentration of office space pro- posed on the site. METRO has been exploring ways to increase transit service in the area, particularly in the I -405 corridor, and the proposed 600,000 square feet of office space may provide sufficient employment density to jus- tify significantly service expansion. With better transit service, the Tukwila area may become more attractive as an office location, and additional mid -rise office development or redevelopment,, perhaps including structured parking, may occur over the long -range on parcels along future transit routes in the area. Again, this would not be a major new trend, but a possible ampli- fication of existing trends. In summary, the proposal would solidify and further the developing trend toward creation of a central business district (CBD) in this part of Tukwila. Since very little vacant land remains in the commercial- industrial district, much of any future intensification would have to occur mainly through privately spon- sored redevelopment. Future proposals for intensifying or altering existing land uses in the area should be monitored and assessed regarding their effect on the overall development of the area. It may be appropriate in the future to augment or revise land use regulations to control the locational distribution and /or densities of various commercial uses to focus development for maximiza- tion of transit and pedestrian circulation. 62 t 1 1 t t 1 1 1 t ® Elements of the Human Environment POPULATION AND HOUSING Existing Conditions The proposal site is located within Census Tract 262 (see Figure 10), but for purposes of this study Census Tracts 263, 272, 282, 283, 284 and 288 will be considered for analysis (see Table VIII). These seven Census Tracts include the entire City of Tukwila and the surrounding area immediately to the west, which is the population and housing group potentially impacted by the proposal; King County is also included in the table for comparison purposes. TABLE VIII POPULATION CHARACTERISTICS (1970 Census Data) Census Tract: 262 263 272 282 283 284 288 King County 1970 Population 3,177 2,083 2,362 2,068 3,454 8,267 8,752 1,159,230 1978 Population* 3,458 1,764 2,159 1,922 3,026 8,172 8,517 1,186,903 '70 -'78 Change +8.8% -15.3% -8.6% -7.1% -12.4% -1.2% 2.7% +2.4% AGE ( %): Under 10 15.3 16.4 21.7 17.1 20.1 17.9 20.6 17.6 10 - 19 17.8 14.4 17.8 19.2 24.9 19.2 21.1 18.7 20 - 34 35.5 24.6 24.9 26.2 19.1 27.3 25.6 23.1 35 - 64 27.4 36.3 28.2 32.1 32.5 31.1 29.1 31.9 Over 65 4.0 8.3 7.4 5.4 3.4 4.5 3.6 8.8 SEX: % Male 51.6 52.5 49.7 50.5 50.8 48.9 50.3 48.9 RACE: % Black 1.4 1.7 0.7 0.4 0.3 0.2 0.4 3.5 *PSCOG 1978 Estimate 63 tukwilci City center Census Tracts 64 The 1970 population of the City of Tukwila was approximately 3,500, although current estimates show a drop to about 3,400 persons. This reflects a region - wide population decrease since 1970, generally attributed to the economic decline of the aerospace and housing industries at that time. Residential population of Tukwila is expected to reach 4,000 by 1980, however, exclusive of annexation. .These figures refer to actual residents, but in addition, Tukwila has an average "daily" population of approximately 50,000 to 70,000 persons. Most of these are made up of transient population (primarily shoppers), but approximately 15,000. are daytime employees within the city limits (not includ- ing seasonal additions to the retail employment force). Of the 15,000, about 3,300 are in commercial /service type of employment (2,000 of which are at Southcenter), 6,500 in warehousing /industrial employment, and the remainder in office, miscellaneous or public employment. Housing characteristics for the Tukwila area are shown in Table IX. The data shows that Census Tract 262, which makes up most of the City, has a much lower percentage of owner - occupied homes than the surrounding Census Tracts or the County as a whole (although this data is ten years out of date, especially the dollar figures). As these figures suggest, there are more multi - family dwell - ing units than single - family in Census Tract 262 (and the City of Tukwila): 56% multi - family and 38% single - family, which is unusual for the area. Many of the more recently built multi - family dwelling units are owner - occupied, and ,this trend is expected to increase in the future. Environmental Impact The proposal would have no significant adverse impact on existing housing or population. No residential units would be lost, and traffic increases would occur primarily on the existing heavily travelled freeways and arterials serv- ing the commercial - industrial district. As a secondary effect, the addition of up to 4,500 employees on the site may add to existing pressures for more multi - family housing units in the area. The proposed hotel suites could provide some temporary housing for relocating employees of businesses in the greater Tukwila area. 65 HOUSING CHARACTERISTICS King County 1 Cr) CO r1 w M N d- ae tD • 0 LC) O O r- r-1 N 69 d' .-1 r-4 Fff N N Tukwila 01 1.0 tD w r-1 Cr) • N co O O 0 w N N 69 N M r1 !,A I I 000 co 01 CV aR tD r--I O r w O CV 69 O 0-.4 69 C--• tD (V CO CV CO LO .--1 •• M IA 0• • ^ L() O w 011 1-4 69 r- I 69 CVCV N M CO CV N CO 01 C- • c CO O O M N 69 CO .--1 69 011 01 N N 00 N n ^ • tD LC) 0 O d' w O N 69 CO N r 1 69 CV CV N n N CO 01 • N d' O O w LO r-I 64 O 0-1 69 CO CV M 1.D N CO Cr) 01 0 • t0 LC) O O N •' LC) r-1 69 Cr) 01 69 LC) 01 r-1 N N LC) w r-I CV• ^ CV O 01 w CO '-I 69 M -4 69 01 r.1 Census Tracts: Total Year -round Housing Units: % Owner - Occupied: Median Value: Median Rent: Persons per dwelling unit *: 66 *PSCOG 1978 Estimate f 1 1 t t t 1 t 1 t 1 TRANSPORTATION AND CIRCULATION Arterial Streets and Traffic Volumes Existing Conditions The City of Tukwila recently engaged the consulting services of ENTRANCO Engi- neers (Bellevue, Washington) to conduct a transportation study for the city. A draft report entitled Transportation Improvement Plan was completed for city review on August 22, 1979. Since that report contains a comprehensive review of current transportation conditions in the Tukwila City Center project vicin- ity, only a brief summary of current conditions is included here. The more comprehensive review in the "ENTRANCO Report" is incorporated by reference. The existing arterial system serving the project vicinity, together with current (April, 1979) average weekday traffic volumes, is illustrated on Figure 11. The area is located southeast of the confluence point of Interstate Routes 5 and 405 -- a major "crossroads" of regional and interstate traffic. West of this interchange, the SR 518 freeway extends west to Burien, the Sea - Tac International Airport, and an interconnection with the major SR 509 north - south freeway corridor. This four and five -lane freeway is currently carrying about 50,000 vehicles per day (vpd), and it operates at level of service (LOS) "C" to "D" during commuter peak periods. Level of Service (LOS) describes the capacity condition of urban streets, usually tested at intersection approaches, on a scale of LOS "A" being free flow and LOS "F" being severe congestion. LOS "E" represents a "capacity" condition during peak hours for a given street or intersection where congestion and delay may be anticipated. LOS "D" represents a condition of relatively unstable flow where conditions can deteriorate to LOS "E" at critical points in the system. LOS "C" represents fairly stable traffic flow conditions with little delay encountered by motorists. LOS "C" is generally accepted as a design criteria for midday and evening traffic flow quality in urban areas. Eastward bound, Interstate 405 leads to Renton and the east side of Lake Washington, connecting with the SR 167 Valley Freeway at Renton, and Interstate 90 in Bellevue. This four -lane freeway currently carries up to 76,000 vehicles per day. As a result, it operates at LOS "E" to "F" (forced flow "stop and go ") conditions in both directions during commuter peak periods, and at LOS "C" to "D" during most other hours of the day. 67 \ \\\\ \\__\\\ qb' los A LEGEND: '6)c)<' .-. d i B 0., - 6,000 .. I 1 - \Average Weekday 1 i i ii• 1.% 24-hour Vol umes. , • = I ,. ,, ,. ""1:-.2z"-- :15 000 LI ,t off, NCurrent Level •I I itio•-i I i , iti.s., , ! ! i ib 9, of Service =. , =o . --- E loto ic). Level of Service ii 12•-••-to% I with Short-rangell ii6- :7— ----i Improvements* II lid. ----'. /1 /IP_ 1/ po (17 L......._ ..1._ cTiii;04. fah t_411. nfir 4,000) A SOUTHCENTER *Recommended by En tranco TUKWILA CITY CENTER SITE 1 710 . / !O 1'110 40. I ii °O - 11,/:°23 bq Q 1! /roe!, o o . 0 /1/10 o 0 0 h I / 0. fill °0L TTT �. oo, k cp /0 0 e: 4.,4,0400:241 kAltftwititrz. 2000 \ °00 l/11 B s o 0,0,1 oo 1-0,000 0 0 0 7' 4 I co j a 9,000 • I. • —• 0 0 0 0 0 0 0 0 0 0 0 0 I • B B 00 11,000 tykwila Existing city center Arterial System 4 A irtte 4*, 40 fict. • • 16,000 • 2,000* Source: The TRANSPO Group FIG. 11 . 68 Interstate 5 is an eight to ten -lane freeway, and is the primary traffic carrier in the Pacific Northwest. It currently carries up to 120,000 vpd in the Tukwila area, and it operates at LOS "D" to "E" southbound during the afternoon commuter traffic peak period. Southcenter Boulevard, Tukwila Parkway, Strander Boulevard, Minkler Boulevard, and South 180th Street form the major east -west arterial system serving the project vicinity. All are four -lane streets with additional center left -turn lanes at major intersections. Southcenter Parkway, Andover Park West, Andover Park East and West Valley Road (SR 181) provide the major north -south arterial system. All are four -lane streets with the first and last having additional center left -turn lanes. For purposes of discussing the proposed project's impacts on areawide traffic accessibility, a "cordon area" was defined, as illustrated on Figure 11. Seven major arterial streets and three freeway access ramps currently carry about 93,000 vehicle trips per day into and out of this cordon area. The current "level of service" within the cordon area and around its periphery is also illustrated on Figure 11. Freeway ramp terminii and arterial street intersections usually present the limiting points to arterial street capacity. In urban areas, LOS "0" or better flow conditions are desirable to maintain during peak periods, and LOS "C" or better is desirable during midday and evenings. (During the pre- Christmas seasonal shopping peak, the cordon area traffic count increases by up to 20 percent over the annual average weekday conditions.) Four intersections in the project vicinity are currently operating at LOS "E" to "F" conditions during peak periods: (1) Southcenter Parkway /Strander Boule- vard; (2) Strander Boulevard /SR 181, (3) SR 181 /South 180th Street, and (4) SR 181 /Grady Way. Signalization improvements and /or addition of turning lanes have been recommended in the "ENTRANCO Report" as short -range improvements to mitigate current problems at these intersections. These improvements can bring three of the four troubled intersections up to LOS "C" or better operat- ing conditions, as illustrated on Figure 11. All other intersections in the project vicinity are currently operating at LOS "C" or better conditions during all hours of the day. 69 Environmental. Impact Vehicle Trip Generation Estimates: Retail Facilities - According to studies by the Institute of Transportation Engineers (ITE), a retail center of 800,000 square feet will generate an average of 34.5 Vehicle Trip Ends (VTE's) per day per 1000 square feet of Gross Leasable Floor Area (GLFA). Southcenter at about 1.2 million square feet of GLFA is estimated to generate 31.1 VTE's /day /1000 square feet of GLFA, or 37,000 VTE's /day. The combined retail square footage of Southcenter and the proposed Tukwila City Center should average 26.5.VTE's /1000 square feet, or 53,000 VTE's /day, at full market potential - a maximum areawide increase of 16,000 VTE's per average weekday. It is estimated that. "on- site" office - employee consumers and improved transit service brought about by the Tukwila City Center project will reduce the combined center traffic volumes by 5 to 10 percent -- or by 4,000 VTE's per day at 7.5 percent. About 9 to 10 percent of the total daily shopping center traffic occurs during the afternoon commuter peak hour. Office Facilities - The ITE studies indicate that multi- tenanted suburban general office buildings with minimal transit service average 12 vehicle trip ends /day /1000 square feet of Gross Floor Area (GFA). Large tenants and /or administrative headquarters operations with low visitor activity can average considerably lower trip generation rates. These characteristics combined with improved transit service and vastly improved carpooling potential for large - office tenants make a trip rate of 8 VTE's /day /1000 square feet of GFA more probable for Tukwila City Center. Hence, the office - related traffic for 600,000 square feet is estimated at 4,800 to 7,200 vehicle trip ends per day on weekdays. Peak hour traffic can range from 18 percent of total daily traffic, the maximum, to 14 percent with improved transit and carpooling. Saturday activity will be less than half the weekday activity, and Sunday activity will be minimal. Hotel /Suite Facilities - Tukwila City Center will provide 400 hotel rooms and 375 hotel suites, plus restaurant and meeting facilities. The Institute of Traffic Engineers and other sources indicate that these types of facilities, as a separate "freestanding" development, generate up to 10.5 VTE's per day per occupied room, or about 8.1 VTE's per day per total room. In combination with the other retail and business activities contained within the proposal and the 70 1 1 1 1 1 1 s 1 1 proximity to the airport, a more probable rate for these activities is 6 VTE's /day /room -- a 25 percent reduction from a "freestanding" hotel facility. This results in an estimate of 4,700 to 6,300 VTE's per day for the proposed hotel facility. Afternoon peak hour traffic activity will be about 8 to 9 percent of the daily total. Total Tukwila City Center Proposal - Average weekday daily and afternoon peak hour vehicle trip generation estimates are summarized in Table X. TABLE X VEHICLE TRIP GENERATION ESTIMATES FOR TUKWILA CITY CENTER PROJECT1 Bldg. Use /GFA (sq. ft.) Avg. Weekday Veh. Trips2 PM Peak Hr/Trips (In /Out) Probable Maximum Probable ' Maximum Retail Shopping /800,000 sq.ft. +18,000 +21,000 +800/900 +1000 /1100 General Office /600,000 sq.ft. + 4,800 + 7,200 +100/600 + 200/1050 Hotel & Meeting /775 Rooms + 4,700 + 6,300 +200/200 + 300/250 TOTAL PROJECT VEH. TRIPS +27,500 +34,500 +1100/1700 +1500/2400 Less "Impulse" & Local Trips3 - 4,100 - 5,200 - 150/250 - 250/350 Reduction in Southcenter Trips4 - 6,000 — 5,000 - 300/300 - 250/250 NET INCR. IN CORDON TRAFFIC +17,400 +24,300 +650/1150 +1000/1800 1 Estimates do not reflect vehicular traffic reductions that may occur in the surrounding area as a result of increased transit service and carpooling opportunities that may be catalyzed by Tukwila City Center. 2 Vehicle trips to and from project or cordon area. 3 "Impulse trips" are trips passing by or near the site for other purposes (e.g., work to home) which make an intermediate stop for shopping. 4 Reflects traffic- reducing effect of an expanded super - regional retail center; does not reflect any reduction in the sales per unit of floor area. Seasonal Variation: Comparison retail shopping facilities experience a considerable range of weekly and seasonal variation in activity. Friday traffic can exceed average 71 weekday daily traffic (AWDT) levels by 10 percent, and Saturday traffic exceeds AWDT by 15 -20 percent. Pre - Christmas weekday traffic levels exceed AWDT by as much as 50 percent. On the other hand, office activities react almost conversely to retail activi- ties. Holidays, vacations and four -day work weeks tend to reduce Friday and pre /post - holiday work activities to below average weekday levels. Weekend office activity is low to minimal. The business - dominated hotel activity at Tukwila City Center will tend to follow the weekly and seasonal office activity patterns. The net result on traffic activity will be self- compensating for the proposal. The AWDT volumes in Table X will vary little during most of the year. Pre - Christmas shopping peaks, however, could surcharge the AWDT estimates by as much as 25 percent. Summary - Tukwila City Center at mature operation will result in a "probable" generation of 27,500 vehicle trips into and out of its entrances on an average weekday, with about 10 percent occurring during the afternoon work - commuter peak hour. During pre- Christmas shopping periods, total weekday trips may increase to 36,000, and the afternoon peak hour volumes may reach 1,400 trips entering plus 2,000 trips exiting. As noted previously under "Existing Conditions ", there are an estimated 93,000 vehicle trips currently into and out of the greater vicinity "cordon area" on an average weekday. The Tukwila City. Center project at full development and maturity will result in a "probable" net increase of 17,400 vehicle trips entering and leaving the cordon area on an average weekday, or about a 20 percent increase. Travel Distribution Patterns: The distribution of trips attracted to regional shopping facilities and office buildings is largely a function of population distribution around these activ- ity centers and the degree of accessibility of the facilities via the regional transportation system. Travel to and from hotels is more closely related to the location of major transportation terminals (i.e., Sea -Tac Airport) and regional activity centers (downtown Seattle, Southcenter, etc.). The .trip distribution pattern for the proposed project was developed from two sources 72 1 1 1 1 1 which include the effects of the above factors: (1) a 1976 survey of 1,000 shoppers at the adjacent Southcenter shopping mall, and (2) a 1990 forecast of regional travel of persons to and from the Southcenter vicinity prepared by the Puget Sound Council of Governments. The resulting trip distribution patterns estimated for Tukwila City Center are illustrated on Figure 12. Traffic Impact Analysis: The traffic impact of the proposal is estimated by calculating the net traffic contribution at mature development, on the local arterial system, and by adding this contribution to cumulative traffic volumes at a future year. The "ENTRANCO Report" projected an average 5 percent per year traffic increase rate in the project vicinity from now to 1990. This could result in a 25 -30 percent traffic increase throughout the area by 1985--the earliest year by which the proposed project could reach full development. The low end of this range was used for expanding current non - project traffic volumes in the immediate vicin- ity of the project site, and the higher end was applied elsewhere. Figure 13 shows the estimated 1985 average weekday daily traffic (AWDT) on the arterial system without and with the contribution of the proposal, and also shows the estimated traffic volumes attributable to the proposal. This is a likely overestimate of 1985 traffic levels since improved public transit facilities and carpooling were not taken into account in the "non- project" traffic forecasts. The greatest traffic impact would occur on Strander Boulevard near the site where traffic would be increased by 8,500 trips, or 40 -45 percent, and on the short section of Southcenter Parkway north of Strander.to Klickitat Drive (the heaviest travelled arterial link in the area), where the additional 7,000 trips would represent a 26 percent increase. Increases of 30 -40 percent would be experienced along the length of Andover Park West and on Klickitat Drive. Increases of 20 -30 percent would occur in the vicinity of the Strander Boule- vard bridge over the Green River and along a short segment of Tukwila Parkway west of Andover Park West. Figure 13 also indicates the proposal's additions to traffic volumes on freeway and arterial links leading to the project vicinity from other parts of the region. Increases on Interstate 5 and 405 would be about three percent and SR 518 traffic would increase by about five percent. The freeway ramp systems 73 .,„....,, i,.......,.. r workit.max IltGll � •��• i • Ua '��IIIIIIIIIIIIIIl�.i1�►' �S� � �-�( .. Fr 11 y, ilk �. nil 1 1 u.�s.m�uu..�� 1�t1 �.. - w .. 1 �����►�11111� � ''717 �� •4.0 1�. �1lll�,.�l. -7ii�1� � � S IIIllICIlI X{�111 11111 �N;%:•v�' 111 111h��llii .E..4= 7 = -7,4L 11 ���: -,, - 1,�.. \ \I�� \�'►R�`s � i��� l I �■Ylv /lllllll►�1 � !j (`j ►li111 riNE �_�_�' Iti'f "•- OA�tiR! %1i FLOATING 6x/06 eo I ■mn ii luii Ii nuIil == pulping uu pul in •- IlUllI, ,1111IIIunl � — �� =lInI1/� euuuca,lal �� Ill fir, n1111I1'1l1► U. • 03 - • t ° 'l_ u nU119n1 raimun canal I;earul_ cal ilenab- ^�!�r.. iiiii. ii unn11•IU►17111i1 �anuu►ur f �� �n6 iia aultl nia..�ume -tuni �ni11Rl K1 9 1 "Mi(,ulu M11I1s!, �1 1w1I► nln � ? Zeilralti 1111 TAM ��wll..- lilt //11'1113`_ 51=111.111111 AIi -� �1�� -' • l'3111i /AN • ii41 niy /� Source: The TRANSPO Group 74 24,00o + 1,acb 6,500 +1,000 7,50o 3000 2500 /7,500 +4,000 21,500 11,500 +4,500 14,000 27,500 t 3,000 ,5o0 LEGEND: 1985 AWDT w/o project Project addition 1,985\AWD T with project' 11,000 +4.500 15, 500 S0UTHCENTER 27,000 +7,000 34,000 20,000 -t 8, 500 28,5C0 47.500 25.000 11,000 +4,500 15,500 23,000 .tt 24,too j TUKWILA CITY CENTER SITE 12,000 +4,000 16,000 14,000 +4,000 18,000 23,700 4,1,000 24,700 10,000 +4,000 14,00o 17,500 + 500 lt3,aoo 23,700 + 1,000 24,700 11,400 �- 6,00 12,000 500 3000 1000 + 500 14,000 17, 000 +3•000 20,000 20,000 + 3,0c0 23,000 15,000 +1,500 14,500 *4e7t'44 1500 tykwilci city center 1985 Source: The TRANSPO Group Traffic Volumes FIG. 13. 75 would experience volume increases of approximately 20 percent. West Valley' Road (SR 518) south of South 180th Street would increase approximately 16 percent, and South 180th Street east of SR 181 would experience a ten percent increase. Increases in congestion as a result of the proposal would occur at inter- sections along Strander Boulevard, Andover Park West and Southcenter Parkway. Other intersections within or near the "cordon area" shown on Figure 11 would not experience a significant decrease in level of service, assuming that the short -range improvements recommended in the "ENTRANCO Report" are implemented to improve existing levels of service. The intersection of Interurban Avenue (SR 181), Grady Way and the I -405 ramps will continue to experience congestion with or without the proposal. Mitigating Measures Mitigation of traffic impacts for Tukwila City Center should primarily focus on Southcenter Parkway, Strander Boulevard, and Andover Park West as illustrated on Figures 14 and 15. Longer range mitigation to accommodate this project and other developments in the vicinity should include an east -west link from South - center Parkway to SR 181 between Strander Boulevard and South 180th Street. Such a connection would reduce traffic loads on the latter two streets. The following table shows the anticipated peak hour LOS for various land configurations. TABLE XI ANTICIPATED PEAK HOUR LEVEL OF SERVICE FOR VARIOUS LANE CONFIGURATIONS AT A.W.D.T. VOLUMES SHOWN • Total Lane Configuration Maximum A.W.D.T. for Peak Hour LOS of: LOS "C" LOS "D" LOS "E" 2 lanes (one each way) 8,500 10,200 11,300 2 lanes + left -turn lane 12,100 14,600 16,000 4 lanes (two each way) 19,400 21,500 23,900 4 lanes + left -turn lane 23,400 26,000 28,900 6 lanes (three each way) 24,600 29,300 32,600 6 lanes + left -turn lane 28,500 33,800 37,600 Source: Crossroads Study and Subarea Plan, City of Bellevue Planning Department, June 1979. 76 1 LEGEND New or ,,l,�Pry s;34 lnntzAtiax Desie:- Artc.rio1 Strest A E /Ansi". De. siraJh. to 2L2 v 213 2 L 2 New Aete R04) Des<rdat- (Cool Atone.) } w J -J 3 NV'Id NOI,LVOQ'I. s hS tukwilci city center Recommended Traffic Improvements FIG. 14. Source: The TRANSPO Group 77 iu50)1L Zoo 8001± 1100 AIcvvEIZ Po--e n t o.Q /dew Si9n•�s jISk l .F- isoZ �_ mew sow CITV CENTER uKWILA ---� �s ROW AccEss 04 II' 6. W LT as Ng n 541 c - -c M%n loa pfAJOR 4121) SSd co s ?- ANDOVER PARK WEST Reco►kMendJ Obis -Sect o& s ECTr o a A -A ,tso- bi aloe. Row= 8o'M ;� �,g I ►r• _ H' I!' 11 %:' G' L w cs w ¢ LT :f L =G �� �-- s ioo too _:A _STRANDtR 130ULEVARA _ : Ref-4)m m ended. Cross- Seclia., - : :: : _ S ECT 10N 8 -. G IrT • , MA.roQ }.:._.. .. „ �1 _ u _ rrt� : - - by - w6..ALT - _Es -Ee. RoW= 63' AVM e1 = • -1�0 --•-r : —; r_,_., : -... - -- o - . GCFSS .. ._ SrRAaVOER C3oucEve►aD :. ,7._..._ -f - --=Rer..40.- p,er+ale.d Goss - Se a1 'Ioto ..x f • .. t::..... • ' SECTI oA C- C ` • • f -` ---7 ' '.1 T - s s T -- Ip trig I - -+--- --# Ri kT.111.115 .In af. 0iLT D, , I tukwila city center _ -TNA- Volumes t larbt;n3 flouertedt. yr_- Recommended Site SCALE Source: The TRANSPO Group Traffic Improvements FIG. 15. 78 Based on these criteria, immediate improvements which should be accomplished prior to completion of the proposal have been developed and are illustrated on Figure 15. Strander Boulevard should be expanded to six lanes plus sidewalks on both sides from a transition point west of the west property line to Andover Park West. This improvement would provide a center left -turn lane with storage areas feeding the major access drives into the project as well as the existing entrance drives to the Doubletree Inn and Southcenter. It would also provide an eastbound auxiliary lane to service high volumes of right- turning traffic into and out of all access drives for Tukwila City Center. The two major full access entrance /exit drives should be aligned opposite to the existing South - center drives, and signalization provided at both intersections as shown on Figure 15. These signals will also provide additional crossing control and safety for pedestrian flow across Strander Boulevard between the proposal and Southcenter. Whether or not the eastbound auxiliary lane should extend west to Southcenter Parkway is a determination the city should make by assessment of the volumes of right turn maneuvers into and out of the Parkway Place office building. A similar westbound auxiliary lane on the north side of Strander Boulevard does not appear to be necessary since access drives to the north do not appear to be high volume in use. However, a westbound auxiliary right -turn lane of 100 to 200 feet in length should be considered for addition on the Strander Boulevard aproach to Southcenter Parkway. Desirable improvements would include extension of the five -lane expansion of Strander Boulevard east to the Green River Bridge. Andover Park West should be expanded to accommodate a center left -turn lane along . the project periphery to increase lane widths to eleven feet, and to add sidewalks on . both sides. By comparing the 1985 traffic forecasts with Table XI, a five -lane cross section for Andover Park West appears more than adequate to accommodate the 1985 traffic demands, including Tukwila City Center. Suffi- cient right -of -way along the project periphery should be provided to enable the addition of a southbound auxiliary lane in the more distant future should it ever be necessary. New signalization should be provided at the middle access drive to /from the project site to control vehicle turning movements and to provide a controlled pedestrian crossing of Andover Park West. Desirable improvements would include extension of the five -lane expansion of Andover Park West north and south from Tukwila Parkway to South 180th Street. 79 Signal improvements and the addition of another northbound lane are also desir- able on Southcenter Parkway from Strander Boulevard to the I -5 off- ramp /South- center access junction. Tukwila Parkway and Southcenter Parkway north of the northerly I -5 off -ramp and south of Strander will be adequate as they presently exist to accommodate the 1985 level traffic impact condition. With the other street improvements dis- cussed above, they should in fact be adequate to accommodate traffic demands to 1990 and beyond. The need for six lanes on Tukwila Parkway by 1990, as recommended in the "ENTRANCO Report ", should be held in abeyance until such time as the recommended I -405 corridor improvements are studied in more detail. The new access roads suggested in the "ENTRANCO Report" for development on the south and west property boundaries of the proposal site were given careful consideration. Their need and prospective use were compared against traffic access /egress patterns for Tukwila City Center, and speculation was given to other non - project travel patterns that they may serve. By weighing the needs assessment against the environmental sensitivity of the pond perimeter, a recommendation to pursue these new road improvements could not be reached. The very limited benefits to traffic flow would be gained only at the expense of filling and constructing the roads on the most sensitive wildlife habitat areas around the pond, thereby largely negating the habitat preservation and en- hancement measures included in the proposal. There could be more significant advantages for non - project traffic resulting from a new east -west road along the south periphery of the project site and westward to Southcenter Parkway. Traffic from the northeast approaching Park- way Square and other activities along Southcenter Parkway further south could be diverted off of Strander Boulevard by this improvement. Likewise, traffic from Southcenter Parkway north of Strander Boulevard destined to areas south of Strander along the Andover. Park West and East corridors could also be diverted away from Stander Boulevard. Most of these traffic patterns, however, could be equally well served by a westward extension of Minkler Boulevard from Andover Park West to Southcenter Parkway. Coupled with an easterly extension of Minkler Boulevard across the Green River to West Valley Road, the extension and improvement of Minkler would be a much more desirable improvement alternative. In addition, the Minkler Boulevard corridor does not have the environmental constraints which are present along the south edge of the proposal site, as discussed in the previous paragraph. 80 As noted previously, Tukwila City Center will increase traffic volumes on the Interstate 5 and 405 freeway ramps by an average of about 20 %. The ramp systems themselves have adequate capacity to accommodate these increases, how- ever improvements are desirable at the ramp intersections with arterial streets to improve the processing of freeway traffic. The most specific concerns focus on the I -5 /Southcenter Parkway ramp intersections and on the I- 405/SR 181 interchange location. Short -range improvement of the I -5 /Southcenter Parkway traffic processing will be accomplished by the addition of a seventh northbound lane on Southcenter Parkway north of Strander Boulevard, as discussed above. Interim -range im- provement of I -405 access can be accomplished by an expansion of SR 181. to six or seven lanes between Strander Boulevard and I -405, together with associated improvements at the ramp junctions to increase traffic flow capacity. Such improvements could adequately accommodate traffic demands to 1985 and beyond. Longer -range planning should pursue studies and designs for the I -405 corridor access improvements described on pages 60 -68 of the draft "ENTRANCO Report ". Also, investigations should be initiated to study the feasibility of providing - a new arterial connection from the I -5 /South 188th Street interchange north- easterly into South 180th Street at Southcenter Parkway, as illustrated on Figure 14. These improvements, however, are not considered as critical needs during the early years of operation of the proposed Tukwila City Center. General Note: LOS "C" to "D" was sought as a design criteria for commuter peak periods during the 1960's and early 1970's. Considering the dwindling public funding resources for road construction and the growing desire to encourage the use of transit and carpool travel modes during peak periods (which restricted freedom encourages), many public agencies are accepting lower service levels during peak periods as they look toward roadway capacity needs in the 1980's. Pedestrian and Bicycle Circulation Existing Conditions Most of the project vicinity lacks sidewalks, and together with widely- spaced traffic signals, this presents safety and comfort problems for pedestrian travel. This particularly discourages noon -time walking trips to nearby res- taurants by employees, who instead add their vehicles to the heavy traffic in the area. 81 Environmental Impact Traffic increases associated with the proposal will cause proportional in- creases in the likelihood of traffic accidents in the project vicinity. The project access drives will create additional locations for traffic conflicts to occur; and the project will generate increased pedestrian activity along- side and crossing Strander Boulevard and Andover Park West. Little to no bicycle traffic has been observed in the project vicinity; no increase is anticipated as a result of the project. Mitigating Measures The sidewalks and pedestrian crossing controls at the signalized intersections as recommended previously should provide adequate external facilities for pedestrian traffic. Extensive pedestrian facilities will be provided within the project. No special bicycle facilities are recommended. Bicycle riders can use the proposed sidewalks, and curb ramps should be provided at all intersections and driveways to facilitate wheelchair as well as bicycle travel. Public Transit Service Existing Conditions METRO Transit's weekday routes serving Tukwila are indicated in Figure 16. There are several deterrents to effective use of public transit in the Tukwila area. Steep hillsides make walking to routes on Interurban Avenue and South - center Boulevard difficult. Also, weekend bus service on Interurban Avenue is shifted to another collector, which makes transit travel from the resi- dential area north of I -405 to Southcenter more difficult. Transit use in the commercial /office area of Tukwila is also difficult due to transfer problems or extended walking distances from bus stops. The lack of sidewalks in the area near Southcenter is another deterrent to current and potential future transit use. Environmental Impacts The project impact on transit will be a positive one from a public standpoint. It will provide an employment, shopping and recreational facility concen- tration which will be a positive influence for improvement of transit routes and schedules serving the vicinity. Some service improvements are suggested 82 0 500 1000 • 1111 tykwilci city center Transit Routes FIG. 16. 83 under "Mitigating Measures" below. However, more specific proposals will have to come from METRO Transit after considering equipment availability, capital and operating budgets, and capital improvement program goals and priorities. Mitigating Measures The "ENTRANCO Report" provided a number of recommendations for the improvement of local area transit service (pages 77 -81 of "ENTRANCO Report "). These should be considered by the city and METRO for implementation. Bus stops and shelters should be provided on Strander Boulevard and Andover Park West to serve the proposed project. Consideration should be given to rerouting regional Routes 123, 150 and 240 to Strander Boulevard to service the project site. Routes 155 and 340 will provide direct service to the site on their current routings. METRO Transit should be encouraged to investigate the need and opportunity to focus addi -. tional regional service on the strength of the increased employment density which the proposed project will bring about. High Occupancy Vehicles (HOV's) The large concentration of employment that the project will add to the vicinity will vastly improve carpooling and vanpooling opportunities -- not only for project employees, but for employees of surrounding businesses of lower em- ployment densities. It is recognized that the project Applicant may have little control over the transportation policies of future project tenants and owners. However, to whatever extent is practical or . feasible, the Applicant and the city should encourage the large tenants to develop carpool and vanpool programs. Assist- ance will be gladly extended by the region's Commuter Pool service located in Seattle. A new feature of Commuter Pool's assistance is making nine - passenger commuter vans available to subscribing agents, complete with operating guide- lines, at low costs to the users. The design of parking facilities should consider the reservation of prime parking areas, clearly marked for carpools and vanpools. 84 'PUBLIC SERVICES Fire Protection Existing Conditions The City of Tukwila currently has two fire stations, one at 59th Avenue South and South 147th Street and one on Andover Park East near Industry Drive, about one -half mile from the site. There are a total of 24 paid personnel (8 per shift), 7 volunteers and 4 support personnel serving the Fire Department. Equipment currently owned by the Department includes three pumpers •(two 1,500 gallons per minute, and one 1,250 gallons per minute), one pumper with an aerial ladder (1,500 g.p.m.), one aid car, and a mini - pumper which is also utilized as an aid car when needed. The Tukwila Fire Department has mutual aid agreements with King County Fire Districts #1, #23, #24 and #40, and with the cities of Renton and Kent. The city -wide insurance rating is 4 on a scale of 1 (best) to 10 (unprotected). The Department reports no problems with water pressure or availability. Environmental Impact The proposed development would create slight additional demand for fire pro - tection due to the increase of people and automobiles on the site. The frequency of alarms is expected to increase somewhat, especially aid calls, car fires and false alarms. Since the site is currently undeveloped, any con- struction and occupancy would increase demand for fire protection services. The hotel development will add 24 -hour occupancy to that portion of the site. The Fire Department expects that the proposal, at full occupancy, may require a staff increase of about three persons (one per shift) to maintain the existing level of protection. Mitigating Measures The proposed Tukwila City Center will be constructed to city standards. The Fire Department will be consulted during detailed design phases regarding recommendations to reduce the incidence and severity of potential fires and to assure quick access of fire equipment and personnel responding to all types of calls. Hydrant locations and fire flow design must be approved by the Depart- ment. A fire sprinkler system will be installed throughout the complex to reduce additional Fire Department personnel needs to a minimum. Tax revenue generated by the proposal would offset additional costs. 85 Police Protection Existing Conditions Police services are provided by the City of Tukwila Police Department, located in City Hall. The current staff of 24 commissioned officers includes five detectives, the Chief of Police and one Lieutenant, with six clerical per- sonnel. There are usually four officers per shift serving the city., In addition, the Department also employs one civilian crime prevention person. Although the residential population of Tukwila is only about 3,400, the day- time, or transient, population is estimated at 50,000 to 70,000 with about 15,000 area employees (see POPULATION AND HOUSING section). The ratio of commissioned officers to transient population would be approximately 0.2 per 1,000, while the ratio to residential population is about 6 per 1,000 (the national average ratio of uniformed officers to population is 2.3 per 1,000). The overall crime rate in Tukwila is high in the . commercial areas and low in residential neighborhoods. The highest incidences of crime are petty and rand larceny (shoplifting), the largest offenders of which ar teena ed girls at Southcenter. Fraud and forgery associated with the retail outlets are also commonly reported crimes. Most of the calls, that the Police Department responds to for domestic violence, occur in offices in Tukwila, not in private homes. Traffic citations are on an upswing in Tukwila, currently averaging about 300 tickets and 40 accidents per month. Southcenter has uniformed maintenance /security personnel, and the major retail stores have their own security forces to help respond to the demand for police protection. The Police Department also has one officer on foot at the mall during shopping hours to assist the store security forces. The Boeing Company, one of the largest tenants of office space in Tukwila, also provides its own security system and personnel, as does the Doubletree Inn. Environmental Impact The proposed development would create a demand for some additional police protection services. The hotel and major department stores would provide their own security personnel, but based on the Department's experience at South - center, one or two additional officers would be required to adequately serve the development. The enclosed parking garages could also create a potential security problem, especially for personal crimes. 86 Mitigating Measures The security provided by the major retail stores, mall tenants and hotel will help to mitigate the demand for police protection for the complex. Additional security for the mall itself and the office and garage areas is also recom- mended. The parking garages will be lit to accepted standards with both artificial and natural. light. Tax revenues generated by the development would offset the additional costs of this and other required public services. Schools The only school located within the city limits is Tukwila Elementary School, on South 149th Street near 59th Avenue South. This, and other surrounding schools, have recently been experiencing a decline in school enrollment, and have ample capacity. Enrollment would not be significantly impacted, since the proposed project is not expected to result in any shift in population. How- ever, the school district would receive additional tax revenue generated by improvements on the site. Parks & Recreation City parks located within the city limits include Riverton Park, Joseph Foster Memorial Park, Tukwila Park, McMicken Heights Park, Bicentennial Park, Christensen Greenbelt Park and the Fire Station Park on Andover Park East. Fort Dent, a county park, is also within the city limits and provides recrea- tion and athletic facilities for organized and informal programs. The proposed development would be expected to have little, if any, significant impact to the surrounding park facilities (see also RECREATION section). Other Services The closest hospital to Tukwila is Valley General in Renton, a 250 -bed facility with expansion planned to begin early next year. A Medic One unit is based at Valley General, and has an estimated response time of five to ten minutes to Tukwila. Other nearby hospitals include Highline Community (104 beds) and Riverton General (109 beds) in Burien. A county library is planned for Tukwila in the Old City Hall facility on 59th Avenue South to begin occupancy this fall. Until this new 10,000 - volume facility is in service, Tukwila residents have use of nearby county libraries in McMicken Heights, Foster, Valley Ridge or Kent. 87 Although the proposal will have little or no significant impact on libraries, the demand on hospitals may be slightly increased as a result of additional population using the .site. The hotel facilities will have medical staff available on an on -call basis for emergencies. Maintenance Some additional maintenance of public roads would be required due to the additional traffic demand. ENERGY Existing Conditions The proposal would consume energy for construction and for operation, and energy would be used for travel to and from the facility. Estimates, based on other projects of a similar nature, indicate that the proposal will consume 0.4 x 1012 (trillion) BTU during sitework, and 4.4 x 1012 BTU during construc- tion. TABLE XII HEATING AND COOLING DEGREE* DAYS FOR SEATTLE Month J F M A M J J A S 0 N• D Annual eating Degree Days 738 599 577 396 242 117 50 47 129 329 543 657 5524 (65°F Base) tooling Degree Days - - 3 28 68 164 158 65 8 - 494 (60'F Base) *Heating degree days are largely used for determining the heating require- ments and size of heating equipment that will be needed for a particular location. Heating degree days are determined by subtracting the mean tem- perature of the day from 65. For example, if the maximum temperature for a particular day was 60° and the minimum was 34', the mean would be one -half their sum or 47. Subtracting this from 65 we obtain 18 degree days for that day. If the daily mean is greater than 65, the number of degree days is 0 - there are no negative degree days. Cooling degree days are computed in exactly the same manner. In computing cooling degree days the base being considered is subtracted from the mean temperature. When the mean temperature for a day is less than the base, the cooling degree days is 0. There are no negative values. 88 An indication of the heating and cooling needs for the project is shown in Table XII. The heating requirements are much greater than the cooling require- ments. The average temperature must be increased 25 °F per day during January to maintain 65 °F. The average summer temperature must be reduced about 5° daily to attain the 60 °F cooling requirements. The completed project will use an estimated 334 x 109 (billion) BTU annually for heating, lighting, and equipment operation. These impacts are commensurate with commercial develop- ment of this size and scope. The rate of use of motor fuel for transportation to and from the site would be affected by numerous factors, many of which are beyond the scope of this analysis. Factors specific to the proposal and its location include the following. Hotel: The location of the site near the regional airport and the primary interstate freeways would tend to minimize travel associated with hotel busi- ness. High occupancy shuttle vehicles to the airport can replace a significant percentage of private auto travel, and the proximity of a large amount of office development in the Tukwila area would further reduce travel demand. Shopping Center: The combination of the proposal and other nearby regional shopping facilities would have significant regional drawing power, and may generate a higher number of longer trips than would many other shopping centers. The combined size of the local shopping facilities, however, will generate fewer trips per sales dollar (see TRANSPORTATION section) than most centers. This, with the proximity of thousands of workers in the area, would tend to reduce fuel consumption, offsetting the longer trips. Office: The concentration of approximately 2,500 office workers on the site would provide substantial opportunities for carpooling and may also lead to expansion of transit service to the area. These factors, along with the proximity of shopping and entertainment facilities on the site and nearby, would tend to reduce fuel expenditures by site employees and other employees in the vicinity. Mitigating Measures The proposal will incorporate the most current design and materials to make it energy efficient. 89 To optimize thermal efficiency, the building heating and cooling requirements will be analyzed by computer modeling techniques. The building configuration, insulation thickness and use of skylights which achieve the lowest practical energy consumption will be selected. Some of the energy savings measures proposed include the following: 1. The proposed complex is to be compact in area presenting an efficient wall to floor ratio. Shop fronts will face an enclosed mall inside the build- ing rather than each having glass and entrance doors in exterior walls. 2. Roof heights will be kept to a minimum necessary for installation of mechanical and electrical systems above the required ceiling height. This is to keep building volume to a minimum. 3. Roof, wall and floor construction will include insulation to reduce heat loss and solar heat gain. This insulation thickness will be calculated to minimize heat losses while simultaneously keeping air conditioning re- quirements for summer use at a minimum. 4. An energy management system is planned to limit heating and electrical demand by reducing loads on a priority basis. Interior lighting systems will cycle to eliminate unnecessary energy use. 5. The air balance will be maintained and recycled to minimize losses to the outdoors from the heating and air conditioning systems. 6. Directional skylights would be used to provide natural light where feasible. This will reduce the artificial lighting requirements during daylight hours. 7. Artificial lighting will use the new low energy systems which provide more light for a given amount of energy. UTILITIES Electrical Power The proposal site is bordered by an electrical distribution system that can be expanded to serve the proposed development. There are presently double feeder lines along both Strander Boulevard and Andover Park West which have the capability of supplying power to the area via either of two distribution routes. Additionally, the capacity of the overall system to carry the addi- tional electrical load will be enhanced by the already proposed construction of a new substation on Southcenter Parkway, approximately one mile south of the site. 90 NatI ral Gas A four -inch intermediate pressure gas line is located on Strander Boulevard. A similar two -inch line runs along Andover Park West. Both lines belong to the Washington Natural Gas Company. The gas company will provide any minor offsite distribution alterations and expansion necessary to supply the proposed devel- opment. The Washington Natural Gas Company has an adequate supply of gas to provide energy for space heating, cooling, cooking, and other needs into the future. The company is presently in a position to contract for power needs to 1995, and predicts no problem in providing fuel into the next century. Telephone Pacific Northwest Bell has forecasted the demand for telephone service to the proposal and has the capability to respond to that demand. To assure timely and effective service, the developer should provide Pacific Northwest Bell with a specific construction schedule and details on the number of lines required to serve the complex. Water Approximately 2,200 feet north of the site, there is a 60 -inch water main, the Bow Lake pipeline. This line provides the primary water supply for the City of Tukwila and has adequate capacity to supply water to the proposed development. The distribution system between the Bow Lake pipeline and the site consists of 8 -inch and 12 -inch mains. These existing lines should provide adequate water volume and pressure to meet all the requirements of the proposal. If detailed engineering studies reveal that City of Tukwila standards are not met by the existing distribution system, the system would be altered and improved to comply with city standards. Sanitary Sewer The proposed site is bordered on the north by a 12 -inch sewer line located on the south side of Strander Boulevard and a 27 -inch city sewer main located on the north side of the street. To the east of the site, a force main runs north along Andover Park West. All these lines drain to the east along Strander Boulevard to a 36 -inch METRO line on the east side of the Green River. The proposed development would be adequately served by these existing sewer lines and the METRO system is capable of handling the additional sewer volume gene- rated by the project. 91 Storm Drainage Exising Conditions The proposal site lies in the southeasterly corner of a watershed area esti- mated to cover about 1,730 acres. The basin includes a large, relatively high and steep area west of Interstate 5 and north of Interstate 405, and a low, relatively flat area which includes the proposal site, the Southcenter area and portions of Andover Industrial Park. The site includes the lowest remaining part of this latter area which was formerly all a part of the floodplain of the Green River. Stormwater runoff from the entire basin is piped to the south side of I -405 where a combination of open channels and 108" diameter pipes conveys the water eastward to a discharge point in the Green River. A flap gate at this point prevents backflow when the river level is high. The U.S. Army Corps of Engineers may, under certain conditions, discharge up to 12,000 cubic feet per second (cfs), as measured at Auburn, into the Green River system from the Howard Hanson Dam. This flow plus local downstream inflow is estimated to raise the river level, in the vicinity of Interstate 405, as high as approximate elevation 25 (above Mean Sea Level). Under present regulations from the Department of the Army, no pumping into the Green River will be permitted when the river flow at Auburn equals or exceeds 9,000 cubic feet per second. The storm drainage system for this watershed, therefore, must operate as a gravity system during high river conditions with retention /detention as required. A large portion of the Southcenter and Andover Industrial Park areas have been filled and developed to elevations in the neighborhood of elevation 23 to 25. The subject property, being the sole remaining large undeveloped and partially unfilled area, is at elevations ranging from about 15.5 (normal pond surface level) to 20.5. A section of Andover Park West adjacent to the site has a low area of about elevation 19.5. The elevation at the southern watershed boundary in this area is approximate elevation 21.9. A storm drain on Andover Park West drains this low area northward to the 108" pipe near I -405 and thence to the river. In recent years there have been several occurrences when the river level has approached elevation 23. When this occurs, the storm runoff from the basin 92 backs up in the drainage system towards the lowest point on Andover Park West and floods the subject property and the adjacent street. The water continues to rise until the system balances or sufficient elevation is achieved to restore flow into the river. When the river level drops, the pond water returns through the drainage system and into the river. Available information indicates that the flood elevations along Andover Park West have never exceeded an approximate elevation of 21.9, at which point the flood waters would have breached the watershed boundary into the adjacent P -17 drainage basin to the south. It is estimated that, under the worst recent flooding conditions seen in this area, the subject property and the adjacent street may have stored as much as 140 acre feet of flood water between the outfall pipe invert of elevation 15+ and elevation 21.5. There may be other isolated low areas in this portion of the watershed which have experienced this flooding condition. However, they are considered minor and have not been specifically investigated. The amount of available storage in the existing underground piping systems is not known. The subject property, along with some other adjacent properties which have since been filled to above present flooding elevations, are shown as a "Special Flood Hazard Area" on the Department of Housing and Urban Development Flood Hazard Boundary Map, dated September 13, 1977. Environmental Impact The proposal would fill portions of the site, modify the size and shape of the pond and utilize its capacity for retention and storage of on -site stormwater runoff. It is estimated that the present 40 acre site, under the effect of a 1:25 year frequency storm, would have a peak discharge rate from the site of approximately 6.2 cubic feet per second. Under the fully developed condition, the maximum discharge rate would be restricted to this amount and all surplus runoff water would be impounded in the storage pond. When high river conditions exist and the off -site system begins to back up in the pipes, off -site runoff flow would be prohibited from entering the on -site drainage pond by an automatic drainage gate. At this point, all surface runoff developed on -site would be fully retained. It is estimated that at full site development, approximately 23 acre feet of storage capacity would be required for full retention of a 7 -day, 25 -year frequency storm. A more intensive storm 93 i (1:100 year frequency), or an extended period of high river level, could add an additional 5 or more acre feet to the storage requirement. The total volume of the pond basin after redevelopment would be about 60 acre feet between elevation 15 and elevation 21.5. However, future management programs for the wildlife habitat aspects of the pond may require that the pond level be allowed to rise and remain above elevation 15 during the late fall and winter. This could reduce the available runoff storage capacity by 10 to 15 acre feet. It is therefore estimated that; under a worst case condition of a high initial pond elevation, an extended period of high river level and a local storm of greater intensity than a 7 -day, 25 -year frequency storm; the pond basin would have adequate capacity, with only a small excess, to store all on- site runoff until flow to the river was restored. The principal impact of the proposal on the City's storm drainage system would be the loss of the existing floodwater storage capacity of the pond. The existing pond basin and other low areas of the site are estimated to have provided as much as 120 acre feet of storage for floodwater originating off - site during the recent December storms when ponding reached approximate eleva- tion 21.5 (an additional 20+ acre feet of runoff from the site is also esti- mated to have been stored in the system). With this extra storage capacity removed, it is expected that off -site ponding levels in the lower part of the watershed would be increased somewhat for a given storm occurrence. The maximum ponding level, however, would be limited by the street elevation at the southern watershed boundary. Above elevation 21.9, excess floodwater would flow to the P -17 drainage basin to the south, and maximum ponding levels in the Southcenter- Andover Industrial Park area would be approximately one -half foot higher than the high levels which have occurred in recent years. The addi- tional flow into the P -17 drainage system would, under certain conditions, load that system beyond its design capacity. Mitigating Measures A number of potential solutions are available to the city to compensate for the reduced storage capacity. All would require further study of the hydraulic characteristics of the watershed to determine the actual level of deficiency. Measures which could be studied include: (1) provision of additional storage capacity along the 108" pipe corridor along .I -405, (2) provision of separate 94 storage for a portion of the runoff from the higher elevation areas, possibly in storage ponds in the vicinity of the freeway interchange, (3) collection of runoff from all or a portion of those watershed areas of sufficient elevation to gravity drain to the river at maximum river level, and provision of a pressurized outfall to the river, thereby reducing the overall basin storage needs, and (4) increasing the design capacity of the adjacent P -17 system to handle the overflow. Solid Waste The Southgate Disposal Company would provide solid waste service to the pro- posed development. They would have no problem in serving the project but they suggest consultation between the disposal company and the project designers to assure an efficient solid waste disposal system design. All on -site waste facilities would be located and screened to minimize adverse visual impact. HEALTH The tenants of the Tukwila City Center will be required to adhere to all health standards in maintenance and the operation of food service. No conditions would be created that would become health hazards to the building occupants or to the surrounding population. AESTHETICS Existing Conditions The 39 -acre site is currently vacant and much of it is covered with grasses and low shrubs. Clumps and rows of trees are visible along the pond and along the southern and western site boundaries. The pond is partially visible at a distance of about 450 feet from Strander Boulevard. A closer view of the pond is available from one point along Andover Park West. The site, along with a 16 -acre vacant parcel to the east, constitutes the largest undeveloped area in the vicinity. Surrounding development is predomi- nantly one- to three -story structures; mostly warehouses, office parks and shopping facilities with adjacent surface parking lots. An eight -story hotel and a five -story office building are being completed immediately to the west of the site, indicating a new trend toward taller structures in the vicinity. 95 The site and surrounding area are basically flat. The site and pond are visible from surrounding hillsides and appear as an open area in the midst of nearly two square miles of flat roofs and parking lots. Environmental Impact The proposal would be somewhat different in character from existing develop- ment in the vicinity. The proposed seven- and ten -story buildings on the northwest and southeast portions of the site would be visible for some dis- tance, and these vertical elements would provide a visual focus which does not now exist in the area. When viewed from the hillsides to the north and west and from the freeways, these mid -rise towers would combine with the proposed major department stores, the existing major stores at Southcenter and the new hotel and office building to the west, to produce the appearance of a major activity center or "downtown" area. From the adjacent streets, the view would not be one of low buildings set beyond street -level parking lots, as is typical of most surrounding develop- ment. Instead, much of the periphery of the site would consist of landscaping which slopes up a few feet from sidewalk level to the base of buildings set back 50 to 70 feet. The small areas of surface parking would also be elevated a few feet and screened with landscaping. The proposed modifications to the pond and its associated natural area would make this aspect of the site more visually attractive as a development amenity. A variety of views of the pond would be provided from the hotels, offices, arcades and park areas, greatly increasing the visual use of the pond by the public. Although different in scale and character from surrounding development, the proposal would not be aesthetically incompatible with any nearby activities. No significant views would be obstructed and no offensive views would be created. RECREATION Existing Conditions The site currently provides little recreational opportunity with the exception of occasional use by birdwatchers or casual strollers. The property is not linked with existing trail systems or near other recreation facilities. 96 Environmental Impact It is anticipated that a variety of facilities would be added in conjunction with the hotel and office development. These would include a pool, jacuzzi, sauna, gameroom, outdoor park -like areas and possibly athletic courts. The shopping center and mall would provide a form of recreation for many casual shoppers. The improvements to the pond and wildlife habitat area, in conjunction with the provision of numerous viewing points, would greatly increase opportunities for observing wildlife. Interpretive displays would identify species using the site and the seasonal changes in habitat and use. ARCHAEOLOGY /HISTORY The State Office of Archaeology and Historic Preservation reports that no resources are known to exist on or near the site. The City of Tukwila has identified some historic buildings and sites throughout the area, but the proposed development would have no impact to archaeological or historical sites or structures. ECONOMICS Tax Revenues Table XIII summarizes the assessed value and total annual sales potential of the proposal and estimates the tax revenue generated. Assessed values are based on estimated construction costs, including factors for structured park- ing and other site improvements such as redevelopment of the pond. Unit costs are on the conservative side. Real estate tax revenue is based on an estimated rate of 15 mills, somewhat below the recent figures of 16 to 17 mills because of increased State funding of schools. Total tax revenue is estimated. at $8.64 million; $2.25 million from property taxes, $6.2 million from sales tax and $190 thousand from the 2% room tax. Tukwila's direct portion would be $1,065,000 annually. Employment Total on -site employment would be approximately 4,500 persons. The shopping center would provide about 1,700 jobs (1,000 permanent full time and 700 part - time or seasonal) based on one job per $60,000 in sales. The office complex 97 a: would employ about 2,400 persons at one /250 square feet. The hotel complex, at' one /$50,000 in sales, would employ 300 persons. About 100 jobs would be created in management, maintenance, service and auxiliary employment to oper- ate the Tukwila City Center. TABLE XIII REAL ESTATE & SALES TAX REVENUE A. Estimated Assessed Value Retail 800,000sf $ 50.00 /sf $ 40,000,000 Office 600,000sf $ 80.00 /sf 48,000,000 Motel 775 rooms $ 60,000 /rm. 47,000,000 Subtotal $117,000,000 $135,000,000 Land 10% Tukwila Portion .5% $ 585,000 ($ 8.50 /sf ±) 15,000,000 Total $150,000,000 Tax Revenue @ 15/1,000 Total $ 2,250,000 3.2/1,000 Tukwila Portion $ 480,000 B. Sales Tax DSTM Sales 650,000sf x $125 /sf $ 80,000,000 Other Retail 150,000sf x $150 /sf 22,500,000 Hotel /Motel Room Rental 9,500,000 Other Income 5,000,000 Total $117,000,000 Sales Tax @ 5.3% $ 6,200,000 King County- Stadium - Convention Tax, 2% Room Rental $ 190,000 Tukwila Portion .5% $ 585,000 Market Factors The following analysis is a summary of a detailed Market Analysis and Economic Impact Evaluation conducted during September and October, 1979. It is to be noted that the market analysis portion of this discussion is not intended to be, and should not be interpreted to be, a justification or recommendation of the proposed Tukwila City Center development. In addition, the size and type of tenancies of the proposed development are evaluated as a "given" by the sponsors. 98 1 1 1 i 1 1 1 1 1 1 t a 1 Office Demand The proposed project includes 600,000. square feet of office space. In order to assess the impact of the provision of this space, the forecasts for employment increases from 1980 -1990 were utilized as the basis for projections of office space demand. As shown in Table XIV, a total of 33,000 jobs requiring office space (between 1980 -1990) indicates a need for approximately 8.25 million square feet of office space. This projection does not, however, include an allowance for replacement, nor a factor for higher space requirements. The - actual demand may total one million square feet per year, or ten million square feet over the 1980 -1990 time period. A large portion of this demand, approximately 40 %, would be allocated to the Seattle CBD, with 30% to Bellevue, and the remaining 30% to the Tukwila, airport, and other portions of King County. The proposed project, therefore, accounts for 7% of the County's total ten -year demand, or 25% of the-demand indicated for the Tukwila /Airport area. Although this may appear somewhat 1/ optimistic, it is important to note that substantial interest has been expres- sed for the proposed office space and, therefore, the proposal is not entirely dependent on this speculative demand forecast; the actual development may, in fact, involve an employment increment over and above the present forecast. 1/ Hotel /Motel Demand Based on recent trends of per capita expenditures, the increase in expenditures for hotel and motel facilities is expected to grow by 40% between 1980 and 1990. This represents an increase in both business activity and the general tourist trade, and is also partially attributable to higher room rates. The $ total expenditure potential in hotel and motel receipts is shown as $175 million in 1980 and. $290 million in 1990. The number of room - nights in King I County is indicated to increase from 2.8 million to 3.9 million during the same time period. At 75% occupancy, this total 1.1 million increase results in a ten -year demand for an additional 4,000 hotel /motel rooms. The proposed project includes 775 rooms, which represents 20% of the ten -year demand of King County. Due to significant hotel /motel development in other portions of the County, the allocation of this much of the expected growth in hotel facilities to the proposal appears to be high. The Tukwila City Center project would, however, be centrally located to the larger Tacoma - Seattle 99 TABLE XIV 1980 -1990 KING COUNTY EMPLOYMENT GROWTH & DEMAND FOR OFFICE SPACE Industry Total Employment Growth Professional, Clerical, & Sales Rental Office Space User Agriculture & Self- Employment 9,600 3,300 60% 2,000 Manufacturing 20,500 11,100 40% 4,400 Construction 1,500 500 50% 200 Transportation, Construction, Utilities 8,000 3,900 50% 1,900 Trade 45,600 27,400 20% 5,500 Finance, Insurance, Real Estate 8,700 8,200 75% 6,100 Services & Miscellaneous 34,500 24,800 50% 12,400 Government 4,800 3,800 15% 500 TOTAL 133,200 83,000 40% 33,000 TABLE XV KING COUNTY POPULATION BY MAJOR SECTORS 100 1 t 1 1 1 1 1 1 1 1 1978 1980 1990 King County 1,186,900 1,235,000 1,460,000 1 NW- Seattle - Shoreline 551,500 560,000 613,000 (46.5 %) (45.35 %) (43.00 %) 2 Eastside - Bellevue- Issaquah 246,500 259,000 325.000 (20.75 %) (20.95 %) (22.25 %) 3 Southwest - Federal Way 170,400 185,000 237,000 (14.35 %) (15.00 %) (16.25 %) 4 S.E. Renton - Auburn 190,600 202,500 252,000 (16.05 %) (16.4 %) (17.25 %) Outlying 27,900 28,500 33,000 (2.35 %) (2.3 %) (2.25 %) 100 1 t 1 1 1 1 1 1 1 1 ti Metropolitan area, to the eastside area and in very close proximity to the Sea - Tac Airport, and may attain the expected market share. A first stage of hotel development appears to be feasible. A committment to monitor and review the demand prior to completion of later stages of the hotel development is recommended to ensure the feasibility of the expected market. share. Retail Sales For the purpose of analyzing the demand for retail facilities in the Department Store Type of Merchandise categories (DSTM), King County has been divided into four major sectors shown on Figure 16. The first sector is northwest King County, including the City of Seattle and the Shoreline Area. The second sector is to the east, including all of the area east of Lake Washington, from Bellevue to Redmond, and Issaquah and the northern Renton area. The third sector is south of Seattle and west of the Green River Valley including Tukwila. The fourth sector is the area to the southeast, including the cities of Renton, Kent and Auburn. The outlying areas, especially those in the Snoqualmie Valley, are designated "outlying ". Population Growth - Table XV shows the projected population for King County as a whole and for each of the individual sectors. As shown, the northwest (Seattle) sector has experienced relatively slow growth. As a percent of the County, this area is projected to decline as most of the area has matured and new building is limited largely to replacement construction. Overall, no major shift in population concentrations is expected during the 1980 -1990 time period. DSTM Expenditures - The total expenditures shown in Table XVI are based on 1978 actual sales as reported by the State of Washington which have then been adjusted for inflation and income differentials for King County residents. Per capita expenditures in King County are adjusted by a percentage equal to 60% of the income difference. In the Seattle area, per capita incomes are approx- imately 24% above the state, and the DSTM per capita expenditures are thus increased by 14.5 %. East of Lake Washington, per capita incomes are, 28% above the state's, and the DSTM expenditures are adjusted upwards by 17 %. Similar adjustments are made for other parts of the county to adjust the per capita expenditures. 101 L •1 ••o —• —•ate • s• �1 •a • •� •��• • •>,• o�� •o» o MEI 111.11M. Ell Z. Kiny Co. �ilokomisk ea 5 NW 1,9.u,evuE Karr • AP/T1/QV MILNE 11111 .MINENCE.. S. 100A17114# • tUkUJIlC1 King County city center Sectors Source: Shorett & Riely FIG. 17. 102 1 1 1 1 1 t t 1 1 1 TABLE XVI KING COUNTY DSTM EXPENDITURES BY MAJOR SECTORS Per Capita Expenditures 1978 1980 1990 State of Washington $ 974 Projected 1979 Dollars* $1,130 $1,300 King County 1 Seattle -NW +14.5% $1,115 $1,295 $1,490 2 Eastside +17.0% 1,140 1,320 1,520 3 SW- Federal Way +2.5% 1,000 1,160 1,330 4 SE- Kent - Auburn -2.5% 950 1,100 1,270 Other -6.0% 915 1,060 AVERAGE $1,070 $1,245 $1,430 Total Expenditures in ($) Millions 1 Seattle -NW $ 615 $ 725 $ 915 2 Eastside 280 340 495 3 SW- Federal Way 170 215 315 4 SE- Kent - Auburn 180 225 320 Other 25 30 40 TOTAL $1,270 $1,535 $2,085 Sales from outside County 17.8% 275 265 365 TOTAL SALES $1,545 $1,800 $2,450 * 3% real increase, 13% inflation. Source: Shorett & Riely 103 In the lower part of Table XVI, total DSTM expenditures are calculated for each King County sector and for each of the three years of 1978, 1980 and 1990. The actual expenditures in 1978 were estimated at $1,545,000,000. This consisted of $1,270,000,000 in resident expenditures plus an additional $275,000,000 from outside the county. For 1980, it is expected that the percentage from outside the county will be somewhat smaller, expecially because of the new Alderwood Mall in Snohomish County. It is expected, however, that Seattle and King County will remain an important center of DSTM facilities for a large area surrounding the county. Therefore, it is projected that the amount from outside King County will again increase and reach $365,000,000 by 1990. This, plus the resident expenditures of over $2 billion will result in total sales of $2,450,000,000 by 1990. DSTM Sales - As a basis for the analysis of the DSTM sales potential of the Tukwila City Center project, the actual 1978 DSTM sales have been allocated to the same four sectors of King County as used for the above expenditure analysis. The Quarterly Business Review (Washington State Department of Revenue) re- ported a total of $1.5 billion in DSTM sales for King County in 1978. Based on this report and on average sales volumes, it is estimated that approximately 52% of the total DSTM sales for King County occur in the Northwest sector, totaling $800 million. Approximately $210 million is estimated for the East side, $430 million for the southwestern portion, and $105 million for the southeastern portion. Table XVII illustrates a comparison between expenditures and DSTM sales for these major areas in King County. The actual estimated distribution for 1978 is shown in the upper part of this table. The expenditures generated by residents in the four major sectors are shown, as well as the balance of King County and the expenditures that are coming in from outside King County. A percentage and dollar distribution of the expenditures of each of these columns is shown to indicate sales within the corresponding sectors of King County, the total of which is shown in the right hand column of the table. It is to be noted that the Seattle (52 %) and the Southwest portion of King County (28%), including Tukwila, had a total of 80% of all sales in King County. By 1980, it is expected that this percentage will slightly decline to 78.5 %. However, no major changes are expected in the current period between 1978 and 1980. 104 t 1 ti t 1 1 E t 1 1 KING COUNTY DSTFI EXPENDITURES & SALES COMPARISON 1978 -1990 3 u. C •r N. a-) 4-) C C O N •r• N N •r a C -CT 0 N' r 4-) r- U •r L•r .--1 co "C N r 1-•O Q V) CM X •r- 0) a' • 4 rn rts o a O L W 3 {f) L.,......s...N a� 0 U ae as 2,12 O In O Lc-▪ ) N M, CO t0 U) .-1 N O O O In O •I M O CO N C' .+ a+: O CD O .-1 CD O CO .-+ 54 ae ae ae Irk U) O O U) O C CO I. U) .4 N CD In I)) O 4--1 11) O M O) N U) .--1 O U) ticik N U) In U) I h •-1 CO 1 Cr U) .+ 1 LO CO I U) t0 N CD O CD CD in O I h .-+ O 1 C • U) t0 CO I U) LO M b4 as O O SE Kent Aub.!Other Count 3 O U) U) U) O CD CD O C' N N N U) U) U) U) CD h h O in 01 .r .-1 aQ as ae a¢ U) U) O O M 0) U) N C' •--I N N U ) LC) O CD O h .--1 CD O C' t0 M U) U) U) U1 ▪ • I N .-1 U) CD O U) at O CD O O U) N w a ae ae ae U) O P • .4 O) C O) • .4 M U) U) U) U) •-+ IO M M O m h N O U) U) O U) CD .-I U) O - U) M U) CD CD O U) U) O •+ 1.0 CO U) in U) CD O ., .. U) er N U) U) U) U) • -+ h U) I U) N 1 mt 1 in Ul --1 t CO I a C U) N 64 aE CD O .-1 O I U) M I co In I In I .-1 1 O 1 O U) U) I h .1 U) I N ••1 (41 t0 I N IO .-I I Seattle -NW CD I U) N 1 O) I U) U) I U) I CO I .4 I EXPENDITURES C) DI C 7 .O L 3 7 M .0 r C N W N V) 1 N M C U) O 1 .+ 1 .-1 1 10 I .-1 U ) I U) 1 CO 1 .1 1 1980 EXPENDITURES 1 Seattle NW SW- Federal Way SE Kent Auburn EXPENDITURES a ICJ 3 3 er Z C) 10 •0 L t C) +) +-1 vr N -O C 44 i-1 LL . • Y 3i 40 N I a) 10 3 W O V) W N N O) .+ N M M. .-+ U) ID M b4 ac O O U) U) O I) Q' U) M M CD U) U) CD M CD CD In U) .--1 -4 - 11'f 1_') O C N N M N O CV M 64 ac O CD U) CD O to .+ M O O) .-1 U) O U) O .1 N t0 U) M a,e O O .-1 CD 1 U) 1 M. I h I N M I h 1 .I 1 O 1 U) O) C- b4 ae O O U) C O I h h U) I M U) U) C I .-I h .4 I 3 L )0 U ae CD CD .r O I CD I CO I N 1 EXPENDITURES Seattle NW C 3 7 .0 - 7 W M C) 4-) V) - C +) C) Y N 10 3 W W V) N -1 N M cr Source: Shorett & Riely 105 r DSTM Sales Forecast - The 1990 forecast is shown under two assumptions: first' without the proposed development, and secondly, with the proposal incorporated in the Southwest King County area. Without the proposal, DSTM sales for Seattle and Southwest King County show a 1980 -1990 decline from 78.5% to 68.5% of total sales. This would imply that with the higher percentage of population moving to the Eastside as well as the Southeast King County area, additional sales will move heavily into these sectors of King County. Under the influence of a major development near Southcenter, however, this trend is shown to moderate somewhat, such that the combined Seattle and Southwest County sales (1980 -1990) decline only from 78.5% to 71.5% of total sales. Conversely, the percentages going to the other county areas show reduced increases with the proposal, especially in the southeast, Kent to Auburn area. The specific impact on sales trends can be seen by comparing the two lower portions of Table XVII. For example: 1) 15% of expenditures from the Seattle - Northwest area now become sales in the southwest area. In 1990, this would increase to 18% without the proposal and to 20% with the proposal; 2) the East Side now captures 63% of its expenditures. This would go to 80% without and 75% with the proposal; 3) the southeast area now retains 56% of its expendi- tures. Without the proposal, this would increase' to 75 %, representing a $115 million increase in sales potential. With the proposal, the increase would only be to 60 %,or an increase in sales of $70 million. The specific differences without and with the project are shown in Table XVIII. In the upper part of the table, the Eastside is shown to draw the major portion of the additional $650 million in DSTM sales. With the Tukwila City Center Development, southwest /Federal Way is shown to capture the largest share of the growth in DSTM sales ($230 million). The decline in the increase on the Eastside, however, is relatively minor, indicating that the project will have relatively little effect on expansion on the Eastside. Specific sub -areas within the Southwest King County area are illustrated in the lower part of the table. The ten -year increase in sales without the proposed project is $105 million and mostly in the Federal Way or Sea -Tac Mall area. With the proposal, the increase will be more than double to $230 million with major increases in both Federal Way and the Tukwila area. Under this condition, it is expected that the increase in the Federal Way area will not suffer. Because of the probable restricting effect on new facilities east of the Kent area, it is 106 1 i i i • 1 1 1 i z TABLE XVII TUKWILA CITY CENTER - IMPACT ON KING COUNTY DSTM SALES 1980 - 1990 IN $ MILLIONS I. Within King County (10 -year increments) 1. Seattle - NW 2. East Side 3. SW - Federal Way 4. SE - Kent /Auburn TOTAL Without Project With Project $ 155 220 105 170 $ 105 210 230 105 $ 650 $ 650 II. Within S.W. King County (Federal Way Area) A. Total Sales 1980 1990 Without 1990 With Project 1. Tukwila $ 250 $ 270 $ 370 2. Burien 75 80 75 3. .Midway 30 40 30 4. Federal Way 150 220 260 TOTAL $ 505 $ 610 $ 735 B. 10 -Year Increment 1. Tukwila $ 20 $ 120 2. Burien 5 - 3. Midway 10 - 4. Federal Way 70 110 TOTAL $ 105 $ 230 Tukwila City Center Proposed: (650,000 Sq.Ft. DSTM) $ 80 Million 12.5% of 10 -year King County Growth 35.0% of S.W. King County Growth ($ 230 million) Source: Shorett & Riely 107 expected that Federal Way will actually draw some additional increased sales. The areas in the immediate vicinity of Tukwila such as Burien and Midway, however, will tend to stabilize as there will be a major concentration of DSTM sales both at Tukwila and the Federal Way area. It is estimated that the proposed Tukwila City Center project will draw $80 million in sales, which will comprise 12.5% of the 10 -year growth in King County. Of the total growth in the Southwest King County area ($230 million), the proposed development is estimated to draw just over 1/3, or 35 %. 108 Irreversible or Irretrievable Commitments of Resources and Short Term Environmental Uses vs. Long -Term Productivity (THE RELATIONSHIP BETWEEN LOCAL SHORT -TERM USES OF MAN'S ENVIRONMENT AND MAINTENANCE AND ENHANCEMENT OF LONG -TERM PRODUCTIVITY) Implementation of the proposed Tukwila City Center would, for all practical purposes, commit the site to the 'proposed use for the foreseeable future. Short -term gains from the proposal would include additional tax revenues for the City, additional employment opportunities, a focal point for the City and a possible transit node for the entire area. In addition, a large portion of the pond and the most uncommon habitat areas would be assured of preservation as a visual amenity, and for wildlife use enhancement, whereas they could be lost with another type of development on the site, or could deteriorate if not protected and managed. The proposal assures retention of approximately one - third of the site as open space for future generations. It does not appear that there would be any benefits gained by delaying the project. A delay in implementing the project may substantially increase its cost, and similar impacts would occur whenever the project proceeded. Building the proposal would require an initial and continuing commitment of material and capital resources. Material resources that will be consumed for construction and maintenance of the project include water, sand and gravel, lumber products and metal products. Hydroelectric energy and fossil fuel will be required to heat and light the stores and mall area, office buildings, theaters, restaurants and hotels. Construction vehicles, delivery trucks, buses and private automobiles will consume petroleum products. In addition, the development complex will require expenditures of capital., both initial investment and operating costs and manpower. The land is not now utilized for agricultural or mineral resources and does not provide significant recreational opportunity. 109 Alternatives to the Proposal THE NO- ACTION ALTERNATIVE Denial of the final waiver under Ordinance No. 1035 (see DESCRIPTION OF THE PROPOSAL) or denial of other required city approvals would leave the site in its present condition for an undetermined length of time, and would eliminate, for the immediate future, the beneficial and adverse impacts described in this document. If the proposal or a reasonable approximation of the proposal were not approved, several options are available to the sponsor. These options include: 1. Subdivide the site for sale or for other types of development; 2. Resubmit with a substantially different development proposal for the parcel; 3. Appeal or institute legal action against the city. Subdivision of the site may present financial difficulties since Resolution 656 requires permanent protection of the pond. A large portion of the site would, therefore, not be marketable, and the costs of maintaining and protect- ing the pond would have to be distributed to those portions which could be sold or developed by the sponsor. Substantial modifications to the proposal are discussed below under other alternatives. Since the proposal is substantially consistent with existing zoning and with the adopted Comprehensive Land Use Policies and Plan Map designation, and since it is in substantial compliance with adopted city guidelines for development of this specific site, denial of the proposal, or of a reasonable approximation of the proposal with conditions, would likely result in an appeal process or in legal action to overturn the denial or recover damages. ALTERNATIVE SITES The sponsor does not own or control other sites within Tukwila, or in the immediate area, which are suitable for the type of development proposed. The proposed site is the only undeveloped parcel within the city which is of adequate size, is zoned for, and which complies with comprehensive plan policies and map designations for the size and type of development proposed. 111 VARYING THE MIX OR SIZE OF PROPOSED USES A number of variations in the mix or size of the proposed uses can be studied by altering the square footage of one or more elements of the proposal. For the purpose of examining the effect of such modifications, the chart below was developed which shows changes in square footage of each use in the proposal in increments of 200,000 square feet, or 10% of the total proposal. The approxi- mate percentage change in the average weekday vehicle trips (AWDT) generated is shown for each change. IMPACT ON TRAFFIC GENERATION RESULTING FROM CHANGES IN SIZE OF THE VARIOUS USES IN THE PROPOSAL Square Footage Footage Change Total Project In Proposal Increment Change in AWDT Retail 800,000 Sq. Ft. +200,000 Sq. Ft. +12% Office 600,000 Sq. Ft. +200,000 Sq. Ft. +7% Hotel 775 Rooms + 260 Rooms +7% (600,000 + Sq. Ft.) ( +200,000 Sq. Ft.) According to the sponsor's design criteria, changes resulting in an overall increase in the scope of the proposal would be accommodated through increasing the height of the hotel and /or office structures and by providing additional structured parking within the proposed development area. Changes resulting in an overall decrease of the scope would replace a portion of the structured parking and /or building area with surface parking. Within the limits of plus or minus 400,000 square feet, none of the above variations would be likely to result in a significant change in the overall configuration of the proposal or in a significant or more than proportionate modification to the impacts identified in this document. Proportional changes resulting from a somewhat larger or smaller project of a similar nature would occur in the following elements: • Abundance of wildlife utilizing the pond area as affected by building heights and the level of human activity. • Air quality as affected by traffic volume. 112 • Future intensification of land uses in the vicinity as indirectly affected by the intensity of the proposal. • Pressure for additional higher density housing as affected by site em- ployment. • Traffic volumes in approximate proportion to the size of the proposal. • Economic impacts regarding tax revenue and site employment. REDUCED SCALE PROJECT BASED ON SURFACE PARKING ONLY A number of sizes and configurations were studied before the current proposal was selected by the sponsor. For comparison purposes, one alternative would be development of the site at a lower density comparable to many of the surround- ing uses with no structured parking. Based on the land area available for parking, the maximum size of this alterna- tive would be in the range of 700,000 to 800,000 square feet, considering a mix of uses similar to the proposal. Approximately half of the site would be devoted to parking, and the pond and natural area would cover about 25 percent of the total site. Maximum building heights would be four to five stories. In order to preserve the most viable habitat areas, the retained portion of the pond would be approximately in the same location as in the proposal. To take advantage of the view potential of the pond, the buildings would be clustered mostly in the southern central portion of the site, and the bulk of the parking would be located on the north one -third of the site, adjacent to Strander Boulevard. Additional parking would be placed along the balance of the east and west site boundaries, adjacent to Andover Park West and on the existing filled area west of the pond. The reduced project size would generate fewer financial resources for retention, enhancement and maintenance of the pond and natural area. Changes in Impacts Topography - Approximately 75 percent of the site would be filled for con- struction of parking areas and buildings. Finished level would be a few feet above adjacent streets. Geology and Soils - Greater settlement of adjacent streets and properties would occur due to the additional fill over a more extensive area. Approximately 240,000 to 260,000 cubic yards of fill would be imported, compared to the proposed export of 200,000 to 220,000 cubic yards. 113 Air - Air quality would improve at a faster rate in the project vicinity due to the decrease in vehicular traffic. Water - The pond would be somewhat further reduced in size. Water quality may not be maintained to the same degree as in the proposal due to reduced pond size and reduced funding for mitigating measures and maintenance. Vegetation - Less area would be planted with food and cover vegetation for wildlife use. Wildlife - The pond and natural area would be somewhat reduced in size, build- ing setbacks from the pond would be reduced, and expenditures for habitat enhancement would be less. It is probable that the abundance of wildlife using the site would be further reduced, and that the diversity of species may also be lessened, although the exact degree of this effect is difficult to estimate. Land Use - The intensity of the site development would be reduced, and the secondary effect of furthering the trend toward more intensive land utiliza- tion in the vicinity would not occur to the same degree. Transportation /Circulation - The reduction of 60+ percent from the size of the proposal is estimated to reduce traffic generation by 50+ percent, assuming a similar mix of uses. Although demand on the local arterial system would be reduced accordingly, most of the improvements suggested in the traffic anal- ysis would still be necessary or desirable. 1985 trips` into and out of the project vicinity cordon area would be about 8 percent less with the smaller alternative than with the proposal. The reduced office employment density likely would not provide a significant transit focus, and therefore the opportunity for major METRO service improve- ments to the Tukwila area would be reduced. Pedestrian circulation between the site and the adjacent sidewalk system would be less attractive due to the intervening parking lots, and the potential people mover system would probably not be feasible. Aesthetics - The reduced scale of this alternative would be more similar in appearance to much of the older existing low -scale development to the north and east of the site. The building setback from Strander Boulevard would be approximately 450 feet and would contain the major parking area. This would 114 result in a cumulative area along both sides of Strander Boulevard, between the alternative buildings and the Southcenter structure, of about 1300 square feet which would contain only roads and parking lots. The lower height of the alternative buildings would not produce the vertical focus or the appearance of a "downtown" type of activity center, characteristic of the proposal. Economics - Sales tax revenues would be reduced by about 45 percent and proper- ty taxes by about. 65 percent, for an overall reduction of about 50 percent, relative to the proposal. Tukwila's direct portion would be reduced from $1.1 million to about $490 thousand, annually. Total site employment would be reduced from 4500 to about 1800. The reduced provision of shopping center space would approximately proportion- ately reduce the shifts in DSTM sales growth within the county over the next decade. The Tukwila area would still become a major regional retail drawing area, and the most significant impact would still be to reduce future sales growth in the southeast portion of the county. FILL ENTIRE SITE AND DEVELOP A MIX OF COMMERCIAL USES This alternative would be essentially the same as the earlier proposal by the former site owner, Seattle City Light, which is described in a final environ- mental impact statement dated May, 1976. It is likely that the site would be subdivided and sold to a number of developers and that a mix of uses including office, distribution and some one -story retail uses would occur. The actual impacts from development could not be determined until specific proposals were made. The following discussion summarizes the major changes in impact resulting from filling of the site and pond, and generally discusses changes due to an accom- panying reduction in the scope of development. Topography - The entire 38.9 acre site would be filled to a final elevation a few feet above street level. Soils - Filling the entire site would require importation of approximately 425,000 cubic yards of fill material. Truck trips would be approximately doubled to 30- 35,000 trips, probably over a single period of about 210 working 115 days. A borrow site would need to be identified. Additional settling or adjacent ground would occur. Air - Dust entrainment would increase during the filling operation. Probable decrease in long term traffic generation would allow for air quality to improve at a faster rate in the project vicinity. Water - Over 1,000,000 cubic feet of water would be pumped into the drainage system during filling, the pond would be eliminated and on -site retention/ storage would have to be replaced with an alternative facility. Wildlife - Nearly all of the 80 or more wildlife species would be permanently eliminated from the site. Land Use - Final development would probably include low intensity uses similar to the older uses around the site. The existing trend toward more intensive land utilization in the vicinity may be slowed. Transportation /Circulation - Future development would likely generate from 50% to 80% less traffic, depending on the ultimate mix of uses. The transit focus probably would not occur. Pedestrian circulation would be diminished. Utilities - Storm Drainage - Elimination of the pond would remove the capabil- ity of the site to store all of its stormwater runoff during high river level periods. Additional storage demand would be placed on the city's system. Aesthetics - The site would probably be developed with a number of commercial/ distribution buildings, each with its own parking and loading areas, similar to the industrial park areas in the vicinity. No visual activity center focus would be created, as in the proposal. Economics - Tax revenue and employment would be reduced, commensurate with the reductions and changes in uses from the proposal. Since a proposal to fill the entire site was previously denied by the city, and since elimination of the pond would violate many of the guidelines established by Resolution 656 regarding the site (see DESCRIPTION OF THE PROPOSAL), it is unlikely that this alternative would be considered viable unless Resolution 656 was rescinded and the Comprehensive Land Use Plan Map was amended to eliminate the "special development considerations" designation on the pond. These actions would constitute a reversal of adopted and implied city policy. 116 Unavoidable Adverse Impacts • Minor compaction and settling of soils on and immediately adjacent to the site, • Exportation of 200,000 to 220,000 cubic yards of mainly previously - placed fill, requiring about 15,000 to 20,000 truck trips to other construction sites in the valley; • Loss of grassland vegetation and some wildlife species from about two - thirds of the site; • Reduction in the size of the existing pond; • Reduction in numbers of wildlife using the pond area; • Minor reduction in diversity of wildlife species on the site; • Increase in traffic of 20% to 40% on the local arterial system; • Increase of 3% to 5% on nearby freeway traffic volumes; • Reduction in floodwater storage capacity of the local storm drainage system. 117 References Beaton, J. L., A. J. Ranzieri, E.C. Shirley and J.B. Skog, Mathematical Approach to Estimating Highway Impact on Air Quality, CA- HWY -MR 6570825(4)- 72 -08, State of California - Division of Highways, 1972. City of Tukwila, Tukwila Comprehensive Zoning Ordinance (Ord. 251), Tukwila, Washington, 1957 (Updated). City of Tukwila, Office of Community Development, Land Use Survey, 1978, Tukwila, Washington, 1978. City of Tukwila, Office of Community Development, Data Inventory: Tukwila Plan- ning Area, Tukwila, Washington, 1975. City of Tukwila, Comprehensive Land Use Policy Plan, Tukwila, Washington, Adopted September 19, 1977. City of Tukwila, Final Environmental Impact Statement for Seattle City Light Tukwila Pond Fill Proposal, Tukwila, Washington, May, 1976. Dames & Moore, Correspondence of September 4, 1979, regarding Geology and Soils input to Tukwila City Center EIS. ENTRANCO Engineers, Transportation Improvement Plan, City of Tukwila Department of Public Works, Bellevue, Washington, August, 1979. Environmental Protection Agency, A Manual for the Review of Highway Noise Impact, 55/9 -77 -356, Washington, D.C., 1977. Environmental Protection Agency, Compilation of Air Pollutant Emission Factors, AP -42 (with. revisions), Research Triangle Park, N.C., 1973. Environmental Protection Agency, Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety, 55019 -74 -004, Washington, D.C., 1974. Erickson, Albert W., Ph.D., Wildlife Evaluation Review of the Proposed Tukwila Pond Development, Seattle, Washington, August, 1979. Food, Chemical and Research Laboratories, Inc., Certificate of Analysis (Water and Soils Samples from Pond), Seattle, Washington, August, 1979. Pacific Northwest River Basins Commission, Climatological Handbook - Columbia Basin States, Vancouver, Washington, 1968. Puget Sound Air Pollution Control Agency, Air Quality Data Summary, Technical Services Division, Seattle, Washington, Published Annually. Puget Sound Council. of Governments, Central Puget Sound Region - Population and Housing Estimates as of April 1, 1978, Seattle, Washington, 1977. Salzer, Scott, Correspondence of October 12, 1979, regarding bird species at the Tukwila City Center site. 119 Shorett & Riely Market Research Services, Market Analysis & Economic Impact Evaluation of Tukwila Pond Development as proposed by Chartwell Development Corporation, Seattle, Washington, October, 1979. U.S. Census Bureau, Characteristics of the Population - 1970 Census of Popula- tion, Washington, D.C., 1973. Washington State Department of Ecology, Ambient Air Quality Standards, Olympia, Washington, 1971. Washington State Department of Ecology, Maximum Environmental Noise Levels (WAC 173 -60), Olympia, Washington, 1975. Washington State Department of Ecology, Motor Vehicle Noise Performance Stan- dards (WAC 173 -62), Olympia, Washington, 1975. ORGANIZATIONS CONSULTED: City of Tukwila Department of Public Works City of Tukwila Fire Department City of Tukwila Police Department King County Hydraulics Pacific Northwest Bell Puget Sound Power and Light Company Valley General Hospital Washington Natural Gas Company Washington State Department of Transportation 120 List of Elements of the Environment ELEMENTS OF THE PHYSICAL ENVIRONMENT PAGE Earth 31 Geology Soils 31 Topography 31 Unique physical features 41 Erosion 31 Accretion /avulsion n/a Air Air quality 35 Odor 35 Climate 34 Water Surface water movement 41 Runoff /absorption 44 Floods 42 Surface water quantity 41 Surface water quality 42 Ground water movement 33 Ground water quantity 44 Ground water quality 44 Public water supplies 91 Flora Numbers or diversity of species 46 Unique species 46 Barriers and /or corridors 46 Agricultural crops 46 Fauna Numbers or diversity of species 47 Unique species 50 Barriers and /or corridors 47 Fish or wildlife habitat 47 Noise 53 Light and Glare 57 Land Use 57 Natural Resources Rate of use 56 Nonrenewable resources 56 Risk of Explosion or Hazardous Emissions 57 121 ELEMENTS OF THE HUMAN ENVIRONMENT PAGE Population 63 Housing 63 Transportation /Circulation Vehicular transportation generated 70 Parking facilities 21 Transportation systems 67 Movement /circulation of people or goods 67 Waterborn, rail and air traffic 67 Traffic hazards 69 Public Services Fire 85 Police 86 Schools 87 Parks or other recreational facilities 87 Maintenance 88 Other governmental services 87 Energy Amount required 88 Source /availability 88 Utilities Energy 90 Communications 91 Water 91 Sewer 91 Storm water 92 Solid waste 95 Human Health (including mental health) 95 Aesthetics 95 Recreation 96 Archeological /historical 97 Economics 97 122 Appendix APPENDIX A General Description of Noise Noise is any sound which is undesirable because it interferes with speech and hearing or is otherwise annoying (the term "environmental noise ", as used by the Environmental Protection Agency, means the intensity, duration and char- acter of sound from all sources). Noise is a physical phenomenon created primarily from mechanical vibration. Noise occurs in a predictable fashion where free sound radiation is governed with minor variance by an inverse relationship (as the distance from the source increases, the sound is reduced) and its transmission is determined by the physical properties of the transmit- ting medium (usually air). Man's response to noise is determined by the sound level emanating from the source of noise and the frequency spectrum of the sound. Noise intensity represents the level of sound which is weighted in accordance to the apparent loudness perceived by an average human observer. This number is expressed in "A "- weighted decibels and is written as dBA. This descriptor is the one generally accepted as having the best correlation with human judgements of loudness. Each increase of 10 dBA in the noise level is subjectively judged as a approximate doubling of loudness. Noise intensity covers such a broad range that it is measured logarithmically and noise levels usually represent a statistical average for a given period of time. Since noise is rarely steady or constant for long periods, average noise levels do not readily account for very high noise levels of very short dura- tion. For example, a long -term average of a 60 decibel (dBA) sound level over a 24 -hour period might include peak sound levels of 110 dBA, but such an event might be less than one second in duration. This fluctuating noise can be described statistically by noise levels exceeded for given percentages of time during a prescribed time period. The commonly used statistical levels are L90, L50, and L 10' for which the number in the subscript indicates the percentage of time that the given level is exceeded. The L90 is indicative of background noise in the absence of local noise events. The L50 is the median or "average" sound level exceeded 50 percent of the .time. The L10 is usually indicative of maximum noise from recurring events such as traffic during peak volumes. The total noise exposure for a prescribed time period is given by the Leq, or equivalent level, which is the dBA level of a constant sound having the amount of acoustical energy contained in the time - varying measured noise. The Ldn, or day -night sound level, is the Leq over 24 hours with a 10 dBA weighting applied to the nighttime (10:00 PM to 7:00 AM) noise. The Ldn environmental noise descriptor is preferred by the U.S. Environmental Protection Agency. The criteria used for evaluation of noise impacts are as follows: Regulations and Guidelines for Environmental Impact Statements The U.S. Environmental Protection Agency Noise Guidelines for Environmental Impact Statements identify levels which can be used to evaluate noise impacts. These levels are not to be construed as standards. The document states that "until more definitive guidelines are established for various types of proj- ects, EPA personnel will be guided by the general considerations" indicated below for residential areas: Ldn 55 dBA Levels are generally acceptable; no noise impact is generally associated with these levels. Ldn 55-65 dBA Adverse noise impacts exist; lowest noise level possible should be strived for. Ldn 65 -70 dBA Significant adverse noise impacts exist; allowable only in unusual cases where lower levels are clearly demonstrated not to be possible. Levels have unacceptable public health and welfare impacts. Ldn 70 dBA The guidelines classify noise increases over the present ambient as follows: 0 -5 dBA slight impact 5 -10 dBA significant impact over 10 dBA very serious impact The guidelines also specify the information that is needed to evaluate noise impacts and the abatement measures that should be considered if abatement is required. The Washington State Department of Ecology (WAC 173 -60) has also specified regulations relating to maximum environmental noise levels. They have class- ified various areas or zones and established maximum permissible noise levels. 124 1'T•hese " EDNA's" (Environmental Designation for Noise Abatement) are classified as: a) Residential areas - Class A EDNA b) Commercial areas - Class B EDNA c) Industrial areas - Class C EDNA The maximum permissible noise levels for these zones are shown in Table A -1. EDNA OF NOISE SOURCE CLASS A CLASS B CLASS C TABLE A -1 NOISE, LIMITATIONS EDNA OF RECEIVING PROPERTY CLASS A CLASS B CLASS C 55 dBA 57 dBA 60 dBA 57 60 65 60 65 70 Between the hours of 10 :00 PM and 7:00 AM, the noise limitations of the above table shall be reduced by 10 dBA for receiving property within Class A EDNA's. These noise levels may be exceeded on the receiving property by 15 dBA for 1.5 minutes, 10 dBA for 5 minutes, 5 dBA for 15 minutes for any one hour, day or night. The limitations suggested by the State are approximately equivalent to the Ldn levels indicated by the EPA in residential areas. The State regulates noise from motor vehicles under a different standard than the one shown above (WAC 173 -62). However, the standards apply to noise from individual vehicles and not motor vehicles as a class. 125 1.E:,:,...: :' . ,we .want to do:anoffice- hotel -'com 5 i:$y GREG AND ERSON :.. ,City Editor : a . "We want to have our commercial The long and „stormy `history of `' retail area, complimentary to. South , :t 4 - Tukwila* pond may be about to add - : center'•' shopping ::center, and not .• yet another chapter ' ` -, . compete: We might want to put.some 'f ^ - A Bellevue - development firm : :restaurants in around an ice skating 3 :'plans to' make`.a presentation to rink, and have a corporate user'for 4 `. Tukwila City Council :Tuesday night;:;:.:,-,the. office space. It's' all prettypre- : • 'outlining Plana the has for the liminaryright now," McDonald said ' pond. Those plans;_ according 'to -a "_; ". f pond preserved • : partner in the firm, Include a hotel, McDonald. -said .Tukwila ".'Pon -, commercial- retail'area' and possibly, ,would be preserved, "but we don't .f 'an ice skating rink': ,. , *: .see it as .significant as the,:last.. • The development firm of Birtcher -'` environmental impact statement ._ '...McDonald-Frank Properties has an showed it was." ' - r , - ::option to buy the 39 -acre site from:. • •Chartwell Development; whose-. . . A the: owner ;' Chsrtwell:Developmeiit • parent ': firm '.is `Springridge Invest - > Co., according;to;Bob`McDonald. ;_ : ment •Co.'fof 'Victoria, B. C.; Ipurch -- . .. ;-.He said . his - firth. has .a . "long : _ased the site from the City of Seattle option" on. tl a ;ptoperty.to get;ques;F.;s, -: 1979 •.for.about- $4.8:million. :.gr4 '•. lions about' the., site;an'swered'before,°i? '' ::Runoff water.�from'the.Southeent- : a final- commitment to' buy is '.`made:" `:verplain drained into a portion: of the • Financially troubled Chartwell has.::;' 39 -acre site : more- thana,decade ago : been -trying to sell •the property: fora as; construction mounted: :Eventual -- : year ' ' = : ' > ly,. a wetlands habitat was .dreated • Chartwell, which iad •planned to :,.which covers 44"acres:and tii,# udes. : build •.a $170' Million' hotel -retail the pond, locatedlust�south • office complex ; on° the; environmen Shopping center. . `" 1- : tally sensitive - site, found itself lost ,. :_ -The 'City. of.'Tukwila, seeking 'to -• in a maze of municipal regulations protect the habitat ; ; - placed -special regarding development of the site:.;: development restrictions on thesite. • Smaller scale' : -• ' • ": : -° " But Seattle City Light, which owned;. But McDonald- 'said "his ., firm's ::�' the land, :claimed the restrictions - - plans are •on a'smaller ~scale, `with :2,,:- .the value of the_ emphasis on office'spacerather then'''.' land. In : March 1978,''' Seattle City ' r: retail ,like Chartlwell''s ;concept: He , • Light Sued Tukwila: for $3 - million. salt-Office "'space. generates .much :;That' suit still is unsettled.. �.' - -1 •;. less traffic than retail- commercial, a :. Tukwila :City :.Council. - ;members:- • key issue in the Chartwell plans;`:; ;. : will 'hear : proposals. °from the Bel.; , a: • "Hopefully, our plan'will be, better levue firm during a meeting at7.p m.., •r-than the last one from'Cbartwell," . Tuesday in the counciLchamberaof • McDonald joked Friday. :"Generally; Tukwila. City; Hall: ar,~ ' ..i4,-,:,-.-. :- ••,' • ecan i7 y�: �l�'!s"a i ? +s,'�s.�l'� ,k,`t,�f� ° '- '•T,'',, °,;,�s3�i! •u °^ � -.,� :iJ i •f� i �if' F � �' '% • ' J: , { >.�Y;;i;' i f. °C�' :y�. ,i ^�f. r qi -� .:A; �} , . ':''' � � �:�,- „:F'- { :.; Mason: Frank,.' representing;' the the 'retail area would' be bu existing, : development,. but.who do you intend., ;_; ' By BILL S, IL . , 4 , developer, Butcher, McDonald and ;<; pond by''a.small' channel:. The plan to lease the theater toy” Hill asked 3 (Staff Reporter a;, <• r; i ;Frank Properties of Bellevue, ap= calls for jogging'tratls; throughout :: Aprospectivesbuyer'of the:Chart peered before the- Tukwila' City. •t the site Cliartwell Development 'porch well 'Development site;in .Tukwila's :Council: Tuesday night to, unveil ja: A retail area' would be built: bet 'seed the 39 =acre site from the City of i industrial., area;; envisions :draining r; tentative layout for • the site: Also ;, weep the parking lot, and, the office..... Seattle in •1979. millioell s proposal li water off of Tukwila Pond,,to forma ' :representing :.the developer .was;:.;.buildings.., Gerron said:: that ;,the ' office comalex on.the prootel -re met t.'second pond on the property .`,;,Gerald J. Gerron of; McKinley Az' _;, f; businesses. would: not compete With r.; • - p p onm y stiff oppositIoii from envionmental f,. The(' . developer; however, would ..chitects, Seattle. , , s-; : �, Southcenter;i located directly ..north ; 'fists and members of the 'council who' .; probably reduce the : size of\,the ,The .. four office 'buildings, • one of the site, but instead offer publi▪ c Original., pond to fit into its;tentaiive °,,.'perhaps as high as.16 stories, would facilities, and stores to complement wanted to protect the • pond. The ; -s Bellevue Pirdn has obtained an option errsna'etail:ar` a4ando' bo el The rune nigtrou hl f om the northwest:' is considering the. ossibilitelof ar ..to.p'urchase the site from Cngfinall, .ing ► f .. � .a , < , g . g Y g p° y -• • a :v�hich has. beenexperiencing finan • � tentative plan ishows . a:, buffer of corner of the property to the south = ;skating rink, restaurants or a movie , ' ;landscaping• :'between :a: parking' lot : east. corner.: Tukwila Pond, would , theater. ' . , cial• difficulties: ' , ,, - tt=4uld the two main'stree e.that border , i remain in the southwest corner, with Councilman George • Hill jokingly Council members appeared to be + ; the site ; Strander Boulevard; and ;! an' area filled in on the: west side,. > made an apparent: reference to Rog more : receptive to,_the:• Birtcher, :Andover' Par}i :West.•�Gonstrucdon ; possibly to accomodate the construe er Forbes, adult sinovie theater o_ wn.c: McDonald t, and 'Frank proposal,' .. ? ;would :• cover about'$1 5 , million , °don of. a hotel. A smaller pond would: t er;•when questioning Gerson ,; 4. - which. is ,smaller in :scope than thi square feet, a+, r � be dug near the northeast corner of "I realize' it's a little early in the plan proposed by Chartwell.•. • ilk 4i AI:.,:i4.i i .5: .. 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Ir c.. vka qea- soon-A.' -too lov or L.wA.I..w% 1- _ - _ _ _Y g waf t }� i vt-f ° 1_ K p-4( c144;t 4c. / • -helps .6. vvtivVtl ?t^4J ._a-"- t. a —4 r.oda tvi b u.-k, to f oar v 1'x • fro._ f -Fi L s fi o_tn a..v<.d ec -Ho t^s7 17 Ail Lt. rikrlioni - r ter INtjtvvb ftiw P o f — T-vA,,A.,Po r±A.+101/1 I ▪ %t4I -G -^41 lowvA(,0 'iYAAA.i o r+x-1 O N "FAN cdie s VeiLr • W- Wakr4 /04( Sac,. /23f ivE /oe 0, rkilktitd,/ (,4 • f,033 f-Ar-ord • At/Pri kt-- rt/callio4t c7'7#14 a Ach TUKWILA CITY CENTER DEIS CHARTWELL DEVELOPMENT CORP DEVELOPMENT OF RETAIL NEAR TUKWILA POND EPIC- 18 -79 -SA FILE #2 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 BEFORE THE CITY COUNCIL CITY CT TUKWILA, WASHINGTON In re the Matter of: ) Public Hearing on Draft ) Environmental Impact ) Statement for Project ) entitled "Tukwila City ) Center" as proposed by ) Chartwell Development ) Company. ) A hearing in the.above..matter was held on February 4, 1980, commencing at the hour of 7:00 o;clock p.m. at the Tukwila City Hall before Mayor FRANK TODD and City Council Members GEORGE HILL, GARY VAN DUSEN, DAN SAUL, LIONEL BOHRER, REID JOHANSON, DORIS PHELPS and.MABEL HARRIS. Diane Attleson, Court Reporter 44.4 Central Building 810 Third Avenue Seattle, Washington 98104 (206) 622 -0111 DIANE ATTLESON COURT REPORTER 9 10 11 12 e 13 14 15 16 17 18 19 20 21 22 23 24 25 P R O C E E D I N G S MAYOR TODD: This public hearing was called as a result of a petition being submitted to the City which requires that a public hearing be held under law. It has to do with the Draft Environmental Impact Statement filed in regard to the Tukwila City Center project as proposed by the Chartwell Development Company. This hearing will be recorded by a court reporter. Anybody wishing to speak, when you come to the podium after being recognized or called by the chair, please state your full name and speak clearly and slowly, please, . so that we make a complete legal record of the proceedings. Thank you. I now declare the public hearing open and. ask Mr. Scott Salzer to please speak on his behalf. MR. SALZER: Mr. Mayor and Council - persons, I would like to basically address my comments to the wildlife issues that are brought forth in the Draft EIS. I would like to preface it by one statement that•is made in the Draft Environmental Impact State- ment, and that is, "The variety of the productivity of the site are unmatched on any comparable sized site in the Green River Valley or the Greater Seattle Area." DIANE ATTLESON COURT REPORTER 10 11 12 • 13 14 15 16 17 18 19 20 21 22 23 24 25 This is a very powerful statement. I don't believe that the Draft Environmental Impact Statement addresses this clearly, particularly based t,n the standpoint that there is one passing reference into observations made, particularly on the avifauna of the area. These observations were made during the month of August. And while August may be a very nice time to spend down there because it's warm and it's not wet on the grass- lands, it is not the best time to see particularly the breeding birds and the large variety of water foul that utilizes the . area in the wintering. periods. I would also like to stress that the Draft EIS does point out to where two- thirds of the site will be altered for buildings and /or parking. Now, it also further_ states that the additional 11 acres or remaining third of that 11 acres will be modified very heavily for the enhancement of this wildlife. I would like to make myself available also to the consultants that are working on this project. I have past correspondence with them. I would like to make myself available to yourselves and those people in the future. In closing, I would like to say that they say that there may be a minor reduction within particularly the avifauna that do frequent the site. Now, I have DIANE ATTLESON COURT REPORTER 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 personally been visiting the site since 1974, for a period of approximately six years, and in that time I have observed 80 specie of birds in that area. And if you consider that 20 of these are likely to be displaced or it is very probably it will be displaced, and likely many more, you are looking at a 25 percent reduction. I would like to thank you for a chance to make these comments. I appreciate it. MAYOR TODD: Thank you. Randy Coplen. MR. COPLEN: Your Honor, City Council, my name is Randy Coplen. I am president of the Greater Tukwila Chamber of Commerce. I would like to speak on the land owned by the Chartwell Development. This land is very valuable land and I feel the opportunity to properly develop this piece of land should clearly be understood. There are many questions in the planned development relating to transportation, fire control, ecology and others that, I think, still need further consideration. It is my request that the business community, along with the Industrial Council Division of the Greater Tukwila Chamber of Commerce, be given time to study the Chartwell proposal further and in greater detail so that the Chamber could make suggestions DIANE ATTLESON COURT REPORTER 4 2 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 formed from the consensus of the business community and offer suggestions that might relate to this EIS. I would further suggest that more EIS statements be distributed. I would also like the City to seriously consider the long —range transportation problems that are anticipated in the future. Even without the Chartwell Development these are very severe problems. I think a lot more effort should be used in considering the traffic problemsthroughout the Valley area and the plans that are being considered or should be considered should be implemented as soon as possible. It is a, suggestion of the Chamber that these flow problems be handled as soon as can be. Thank you. MAYOR TODD: Thank you, Mr. Coplen. Ronn Griffin. MR. GRIFFIN: I would like to thank the Councillor taking the time to hear these issues. I agree with the comments on the wildlife pond. That area is currently utilized by wildlife ., and I mean to emphasize the word wildlife. I believe the development as presently proposed would change it to more of a domestic duck pond rather than a real wildlife habitat. I think all efforts should be extended to insure that there is a minimum of public access to the pond and that DIANE ATTLESON COURT REPORTER 5 2 3 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 it is set up in an isolated manner so that the wildlife really has a chance to utilize it. I believe that was the intent of the past restrictions placed on that area, to preserve it as a wildlife area, and that that needs to be emphasized throughout the work that is done to update that EIS. Particularly the idea of just making several visits during the dry period is not a sufficient effort to determine what the baseline condition is. I would suggest that at least a full year of study that would entail a visit during all seasons to catalog the use of the pond be established. As also mentioned, traffic is a problem in the area already. And this project in its own EIS states there will be a 20 to 40 percent increase in traffic. I do not believe the present road system is equipped to handle this. I would also like to know how these roads are going to be paid for. As far as air quality goes, I would like to say that the model that was used was a linear diffusion model, which assumes a constant rate of traffic flow through the area. In this case I believe they were using 20 miles an hour. Nowhere in the calculations did I see an account made for the effects of idling time or delay, which have a very significant impact on the amount of DIANE ATTLESON COURT REPORTER 6 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 air emissions you would have from the automobiles coming in and out of that site. Also, the traffic figures that were used were based on early 1979 figures. And as we all know, there has been a considerable traffic increase even in that short time and that the traffic will further increase during the next five years that it is proposed to take to complete this project. I would refer to the comments made by Allied Stores . and the Southcenter Corporation made. He covered . that quite well,I believe. And, also, they have more engineering expertise to review the engineering design. Of particular concern to me would be the problem of water removal from the underground parking and where they are going to go with that water during high -water times, since probably discharge to the river would be prohibited and there would probably not be enough storage on site for that water, not to mention the fact that the site currently stores water from other areas in Soutcenter. The impacts that the City itself needs to consider are the cost of the roads, the sewer system and the other services that would be required by a development of this size. Nowhere in the EIS does the authors suggest what these costs are or really do what we call a cost benefit analysis to the City. There is an DIANE ATTLESON COURT REPORTER 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 indication of the tax revenue that would be provided in the City in the area but I do not see a corresponding detailed analysis of the costs involved to generate this revenue. Also, the comment that there could be 4,000 to 5,000 jobs created by this project does not include the secondary impactsof secondary jobs resulting from these primary jobs. In other words, more people would be attracted to.the areathan just the 4,000 or 5,000 indicated, with the consequences being increased loads on schools and other services. And, again, there are costs associated with this to the City. I would also like to point out that all the services that are proposed to be offered by this project are already presently available by the development of Southcenter and other businesses in the area. So there is no . need to rush to a conclusion and approve this project, that it is not providing anything that is essential to the area or presently unavailable. I believe that more public input is justified both in the form of hearings such as this and as suggested by other businesses in the area. I think, considering the magnitude of the project, being one and two- thirds the size of the largest retail center in the area already, suggests that perhaps detailed engineering work both from a hydraulic and soils DIANE ATTLESON COURT REPORTER 8 3 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 standpoint and a.structural standpoint and traffic flow . and air quality, is- needed. Thank you. MAYOR TODD: Marcelle Regal. MRS. REGAL: Marcelle Regal. Mr. Mayor and Council, I wonder where these people were when I sat practically alone during many meetings when Chartwell explained everything that has been brought up tonight. It seems to me that if people would come t Council meetings and know what is going on, the attitude might be different. Here is a clipping from the December 23rd paper showing the complete layout. Why do we have to back up now? They presented their plans with film and charts and everything and we all understood it. Thank you. MAYOR TODD: Thank you. Mr. David Galvin. MR. GALVIN: Mr. Mayor, members of the City Council, I am David Galvin and I am here tonight representing the Seattle Audubon Society. Seattle Audubon has 4,000 members in the Greater Seattle Area, many of whom do live in the City of Tukwila and in the surrounding lower Green River Valley. I would like to not take very much of your time this evening but I would like to address this Draft Impact Statement which, .I am sorry, in deference to the DIANE ATTLESON COURT REPORTER 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 last speaker, that I live within the City of Seattle personally and I was not informed of the development proposals until I did receive a copy of this Impact Statement. I would like to second some of the statements that were made by earlier speakers this evening concerning wildlife. In what is a really marvelously out -of -place statement in the Draft Impact Statement it is said that, "The variety of productivity of this site are unmatched in any comparably sized site in the Green River Valley or the Greater Seattle Area. This factor, combined with the close proximity of intensely developed adjacent land, makes this site truly unusual and gives it regional significance in wildlife habitat." I would just like to stress this statement which appears in this document , that this site that you have within the City of Tukwila is a wildlife site of regional significance. Now, it might not look like that but if you drive around there it has development on all four sides of it, all the land around there has been filled in. And, in fact, that pond didn't exist previous to the development around it on all four sides. But because of that development and the filling in of this river valley, we are left with a pond there, a large significant wetland, that the wildlife in this area use extensively. DIANE ATTLESON COURT REPORTER 10 1 5 6 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 As I read the State Environmental Policy Act, which this Impact Statement is supposedly written under, that Act requires that the impacts of the proposal be adequately spelled out before the proposal occurs. I must bring to your attention that the discussion in this Impact Statement, particularly of the wildlife of this site, is not only inadequate but it hardly exists in this document. There are occasionally some statements in there that bring to light the real significance of this property but they did not do anywhere near an adequate assessment of the value of that property. Now, the City of Tukwila Resolution 656 puts certain requirements on a development on this site. I would bring your attention to that, starting on page 26 of the Impact Statement. The first guideline talks about surface runoff. You turn to the next page and the first respons is, "Detailed drainage system designs are not completed." Now, that's just one example where it's important before a development of this magnitude occurs that you do an adequate job of assessing what is going to happen. They make the statement right there that their drainage system designs have not been reviewed. They are propos- ing to dredge the majority of that property, put in below - ground parking for 6,300 automobiles and they are going to significantly diminish the size of the existing DIANE ATTLESON COURT REPORTER 11 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 pond. Guideline No. 2 says, "To encourage the pond environment to be used by wildlife." This proposal is going to do the exact opposite of guideline no. 2. Iwould just like to. close by saying that SEPA does . require that you produce an adequate assessment of the potential impacts of any action on the environment before you then go on to decide yea or nay on that proposal. And this document, I felt, was an insult to the intelligence of those people who were supposed to be reviewing it. Thank you. MAYOR TODD: Jerry Escalante. MR. ESCALANTE: Jerry Escalante is my name and I am a resident of. the Renton East Hill area. I only represent myself here tonight plus my own personal company. Basically, Mr. Mayor and Council, I appreciate this opportunity to address you tonight. I am mainly here to talk about the air quality impacts of this Draft EIS which is documented here. Mainly, I find it inadequate, it's very inadequate. It does not address the true impacts related to the Clean Air Act of 1977. It does not basically run through the guide- lines as outlined in EPA Document 450/4 -78 -001 which is entitled Guidelines for Air Quality Maintenance, Planning and Analysis, Volume 9, Evaluation, Indirect DIANE ATTLESON COURT REPORTER 12 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Sources. We are mainly talking about automobile sources which, as you know, we area nonattainment area as outlined by EPA, Region X, Puget Sound Air Pollution Control Agency, PSAPCA, and Department of Ecology. Evidently, I would not know what their comments are at this time, but it would be very interesting to find out if these agencies are working as they should. And I will be looking at those agencies to find out what their comments are on this EIS. Basically the data which I find with them, McMicken Heights is not representative of the Southcenter Area as far as air quality, automobil emissions type, which are CO, hydrocarbons and.non- methane hydrocarbons. The CEQ regs also outline wetland which if you take away certain of the wetlands you have to replace those wetlands. This is not covered or addressed within the EIS. If I may go on with air quality, the shopping center also does not provide for any inter- shopping center transportation between facilities where peoplewould not have cold starts or hot starts going from one shopping c -nter area to another shopping center area. Therefore, you would have worse emissions due to the starting up of vehicles commuting from one point to another point. Therefore, your gross emission burdens that you are putting on this air quality, or actually air resource is DIANE ATTLESON COURT REPORTER 13 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24. 25 what we are talking about, which is the same as water or anything else, in this nonattainment area. Basically the EIS does not talk about what the background concen- trations are today. And then add into that background concentrations what the result of the burdens are going to be during the peak hours, one -hour peak hours and eight -hour peak hours, which is what the CO National Ambiant Air Quality Standards are based on. By not doing this they have not done an adequate job in air quality. If these are only words that I am speaking tonight, if you are worried about building this project, if under the Clean Air Act, Part C, I believe it is, under significant deterioration and prevention thereof, action could be brought as a civil suit if the people thought that this were important enough to stop the project. I think you are all aware of that. So it could be tapped on that basis. If the people want the deteriora- tion in the air, if they want to prolong the attainment of the air, which we are given 1987 to meet that deadline in the Puget Sound Area. 1982 has been, supposedly, attainment year, which this project is built within that period. We know that we.are not going to meet the 1982 so the taxpayers are now going to have to have special maintenance,, as outlined by DOE. So they DIANE ATTLESON COURT REPORTER 14 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 are going to be paying dollars out of their pockets for these types of projects which help to cause us to go on to continue the nonattainment area. And so I don't know where we roll this back, but you are putting a burden, an additional burden, which if you look at your Table 4, I believe it is, the difference between proposed and the project, there is about a 22 to 32 percent increase in emissions that you have projected in the outline here. I think that's conservative. Mainly you are relying on other facilities such as HOV lanes along the 405 corridor, which we all know the EPA is not allowing for any additional widths in 405. Therefore, how are you going to handle these people that are -- 405 is already congested at a dead stop during peak hours. If you can't widen those roadways because of the nonattainment area, this project is only going to add an additional burden onto that facility. So I will leave that with you. And if the people are strong . enough and they don't want this project, I would be very happy to assist them in attacking this project on air quality alone. Thank you very much. MAYOR TODD: Thank. you. Mr. James Wells. MR. WELLS: Your Honor, City Council, I am here tonight. -- I am Jim Wells -- and I am here DIANE ATTLESON COURT REPORTER 15 3 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 tonight representing the Department of Transportation, Washington State. I have a letter here that.I would like to read from our Assistant Secretary of Transpor- tation and Planning. The letter goes, "The State Transportation facilities in this area are already overloaded. This project will place a burden on the facility that will be intolerable. It is mentioned in the document that improvements to the intersection of SR181 and Strander.Boulevard and the I -5 corridor will be needed to help mitigate this increased traffic. The Department has a project under consideration for an HOV lane on Interstate 405. But this project will take care of an existing problem; it is not meant to be used to promote future growth. The Department has no plans in its six -year program to develop these facilities to handle any more traffic. The Department recommends that the City of Tukwila and the developer make appropriate arrangements for funding any improvements that may be needed as a result of traffic generated by this proposal. We do have a problem about the effect this proposal will have on our facility pertaining to air quality. Since this project is in a nonattainment area, any improvements to our facilities need to satisfy the Clean Air Act and the State Implementation Plan. Since this project relies on our facility, we feel that the document should DIANE ATTLESON COURT REPORTER 16 2 10 11 12 13 14 " 15 16 17 18 19 20 21 22 23 24 25 address what effects this project will have on our facility pertaining to air quality." And it's signed, "Sincerely, Robert S. Nielsen, Assistant Secretary, Public Transportation and Planning. ". Thank you. MAYOR TODD: Will you leave a copy of that document with us, please? MR. WELLS: Yes. MAYOR TODD: Other than Mr. McBroom, are there any other people in the audience wishing to speak addressing themselves to the Draft Environmental Impact Statement? Are there none other? Mr. McBroom, you are next. MR. McBROOM: Mr. Mayor, thank you, members of the Council. I am George W. McBroom, attorney for Southcenter Shopping Center, Allied Stores Corporation, and the Bon Marche.. Some of you may have seen, may even have read in your busy lives, I doubt it -- something like 48 pages of written response from our office. I didn't realize that it was that long.' But I don't want to repeat anything that is said there, nor do I wish to repeat anything that other speakers have averted to. .There are two. things that are new that are not-presented, I believe, in my response. One thing that was new was that the City received, as I remember, 17 written DIANE ATTLESON COURT REPORTER 17 2 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 responses, and now with the State Department of Transportation's response, will have received an additional response. Two of these, one from the United States Fisheries and one from the Forest Service, felt that their comment on this particular project would not be relevant. But of the other 16 besides my own the thing that is new to me is that everyone agrees we need more responsible data than this DEIS presents. And the problem is everyone renders the DEIS and any final environmen't,al impact statement, I believe legally indefensable, and the defendant in such an action, unfortunately., would be the City of Tukwila. The second new fact that has come to my attention since the writing of my response really discusses the zoning aspect of the Chartwell proposal. And I am going to present to the Clerk, if I may, an affidavit simply to make the facts as I know them a matter of record. But here, I am told, are the facts relative to zoning: We have said in our response that we do not believe that CM zoning is proper zoning for a regional shopping center development of 800,000 square feet of space. We believe that the cascading effect of the present zoning code permits C -1, local retail uses, in CM, and C -2, neighborhood retail uses,, in a CM zone. But we do not believe that the cascading effect permits CP or planned DIANE ATTLESON COURT REPORTER 18 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 retail center, regional shopping center uses, in the CM zone. And we think that if the drafters of the present ordinance had so intended, it would have permitted a cascading not only of C -1 and C -2 but also CP. It did not do so. We also believe that it is clear that had they intended to do so, it would have required the industry standard that Southcenter is required to maintain of 5.5 cars per 1,000 square feet of retail space rather than the 2.5 cars permitted in a CM zone. We think that's right. And we discovered that on September 13, 1979, staff, planning with the approval of the then Planning Director, reached the same interpretation of your Code as we reached, precisely: Chartwell, the developer, would have to begin by rezoning from CM at least to CP in order to make this project go. Then occurred a strange thing, because on November 16th of 1979 the same Planning Director reversed the decision made on September 13th and said that the uses proposed by the developer can be made in a CM zone. These two opinions are 180 degrees in conflict. I believe you know, or at least we thinkw know, that on January 20, 1980, that Planning Director ceased to be a responsible official and contact party for the processing of the developer's DEIS. Up until that time he was. January 21, 1980. Had he processed DIANE ATTLESON COURT REPORTER 19 1 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 as I feel this DEIS ought to have been processed, and as 16 others in writing have said this DEIS ought to have been processed, he would have required much more data than is there.. I don't .want to go into detail. I have gone into 48 pages of detail with the data that is lacking. Then what occurs? On February 1, 1980, the newspaper tells us our Planning Director becomes an employee of the developer, he retires from the City and becomes an employee of the developer. And to the credit of the Planning Director, I am informed, he asked that these two conflicting opinions relative to zoning be reviewed by the Mayor or be reviewed by the Board of Adjustment in view of the fact that he didn't take it, he had then taken employment with the developer., He proposed that. And my understanding is that the matter is in the planning staff now to determine which route to go. Should we go to the Mayor? I hope not, Mr. Mayor. Or should we go to the Board of Adjustment to find out whose interpretation of our Code is correct? Is this highly intenseuse? Does it really belong in a CM zone or does it belong in a CP zone? That is the determination that has to be made, it seems to me, before we go too much further with this thing. I don't know when it is going to be made. I don't think the Planning Department really has determined, I don't think DIANE ATTLESON COURT REPORTER 20 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Council has determined who should make the ultimate interpretation.. I can say without any question of doubt in my mind that as long as that, as the DEIS speaks to CM zoning and speaks to uses permitted in CM zoning, then you don't have and the citizens don't have a legally supportable environmental process. I would think the developer more than anyone.. else would be interested in not having litigation relative to this DEIS. I have been on the other side of the fence and I know how painful I can be. Thank you. .MAYOR TODD: Thank you. Is there anyone in the audience wishing to address the Draft Environmental Impact Statement in any way? MR. GALVIN: This is David Galvin again. I thank you,for the opportunity to say one more thing. I would not .just like to -reiterate what I said but ask you as the City Government of_'Tukwila to not accept this Draft. Impact Statement and to ask the proponents of the development to please go back and review their proposal or at least go back and redo the sections of . this document to make them adequate under State Law. .Thank you. MAYOR TODD: Thank you. The gentleman with his hand up. Would you state your name, please, for the record? DIANE ATTLESON COURT REPORTER 21 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. GRIFFIN: My name is John Griffin, and I would like to suggest that if no other conclusion can come to this other than the way it is going, that the City of. Tukwila pay for an impact statement, environmental impact statement, to get this thing off the ground one way or another. .Thank you. MAYOR TODD: Anyone else wishing to speak? In the back of the room, do we have Impact Statements back there that are available? What is the status of the present DEIS? Is it available to the public at your office during the day? MR. CAUGHEY: Yes, it is MAYOR TODD: And its cost? MR. CAUGHEY.:' Four dollars. MAYOR TODD: Four. dollars. Any other comments from the audience? Any other comments? Any comments from the Council? MR. BOHRER: I did receive one call from a resident and I will pass it on. He said that he was unable.to attend the meeting tonight but he did say that he objected to the name of the project the Tukwila City Center, as he felt that the Tukwila City Center connoted a municipal meaning and that he felt that the name of the project should be changed. So I pass that on to you. DIANE ATTLESON COURT REPORTER 22 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MAYOR TODD: Any other comments? Comments from Council? I declare the public hearing closed. (Public Hearing closed.). DIANE ATTLESON COURT REPORTER 23 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 set 25 • C E R T I F I C A T E STATE OF WASHINGTON ) ):. ss COUNTY OF KING I, the undersigned Notary Public in and for the State of Washington, do hereby certify: That the foregoing proceedings held on February 4, 1980, were taken stenographically before me and reduced to typewriting under my direction; I hereby certify that the proceedings as trans- cribed are a full, true and correct transcript, including questions and answers, all objections, motions, and exeptions of counsel made and taken. Signed this \Oy1lday of February, 1980. n � jj'' Notary Public in and for. the State of Washington, residint at Seattle DIANE ATTLESON CouRT REPORTER 24 13239 NE 100th Kirkland, WA 98033 November 20, 1979 City of Tukwila Planning Department Tukwila, WA. We are very concerned about any proposed developments that are being planned now or in the future around the Southcenter Pond. We would like to be informed of these proposals when they occur. We thank you in advance for this service and look forward to working with you on these matters. Sincerely, Leonard Steiner President Eastlake Audubon Society LS /jb nington -Wednesday, January 30, 1980 n pipe outside the, bulldbig and- 4 in the early - afternoon tragedy en estimated. Staff photo by MARK MORRIS Office complex hearing Monday A public hearing on the Chartwell Development Company's proposed $100 million retail office -hotel com- plex near Tukwila Pond has been placed on the agenda for next Mon- day night's . Tukwila City Council meeting. The city council, at its Committee of the Whole meeting Monday night, decided to schedule the hearing after receiving a citizens' petition requesting one. City officials report that the peti- tion, filed by Ron Griffin of Tukwila, was mainly circulated among Boeing employees who work in the city. The project, named Tukwila City Center, would be located on 39 acres the firm owns at the southwest corner of Strander Boulevard and Andover Park West. In other action Monday night, the council directed the administration to contact the Washington Natural Gas Company regarding a natural gas leak at along'South 147th Street, in the area of 57th and 59th Avenue South. The council is requesting information from the utility on poss- ible safety and liability problems that may exist while the under - ground leak is being repaired. The council also placed a prod, street widening project on Moonily 's meeting agenda. The council will consider the transfer of $110,000 in street improvement funds to fi- nance the construction of a right tura lane northbound along Southcenter - Parkway onto Strander Boulevard. 1981 budget The Army wants to spend $412 iilion in 1981 to have Boeing Aeros- ce in Seattle and Hughes Aircraft Lild 600 Rolands, short-range °bile missile launching systems. out $1.8 billion, said a Boeing spokesman. Todd Pacific Shipyard of Seatde hopes to get authorization from the Navy to build one or more of the Affidavit of Publication STATE OF WASHINGTON COUNTY OF KING ss. TherN9Zr,,s being first duly sworn on oath, deposes and says thala } ... is the .... rh .O.Z'..4 ,. er4.{ of THE DAILY RECORD CHRONICLE, a newspaper published six (6) times a week. That said newspaper is a legal newspaper and it is now and has been for more than six months prior to the date of publication referred to, printed and published in the English language continually as a newspaper published four (4) times a week in Kent, King County, Washington, and it is now and during all of said time was printed in an office maintained at the aforesaid place of publication of said newspaper. That the Daily Record Chronicle has been approved as a legal newspaper by order of the Superior Court of the County in which it is published, to -wit, King County, Washington. That the annexed is a c: L o ' i't� 1 is a eraring .,151.1 as it was published in regular issues (and not in supplement form of said newspaper) once each issue for a period of 1 consecutive issues, commencing on the day of .7.11 nu. v ,19.r.O...., and ending the day of , 19 , both dates inclusive, and that such newspaper was regularly distributed to its sub- scribers during all of said period. That the full amount of the fee charged for the foregoing publication is the sum of $ -... rs. , which has been paid in full at the rate of per folio of one hundredldor'ds for the first insertion and per folio of one hundred words for each subsequent insertion. Subscribed and sworn to before me this 31 day of ..it'C?"Zt2'$i'�• 19..4;.;. Notary Pubes in and for the State of Washington, residinglt, King County. — Passed by the Legislature, 1955, known as Senate Bill 281, effective June 9th, 1955. — Western Union Telegraph Co. rules for counting words and figures, adopted by the newspapers of the State. V.P.C. Form No. 87 Rev. 7 -79 A F F I D A I T O F D I S T R I P T I O N I, Mark Caughey , being duly sworn, hereby declare that A notice of Public Hearing on 4 Feb. 1980 for the Draft Environmental Impact Statement for Tukwila City Center project proposal has been mailed to each of the following addresses. G. Coulbourn 23710 Roberts Black Diamond WA. Donna Ciero 25655 Marine View Dr. Kent, WA T.V. Belleville 11923 1st Av. S. #216 Seattle, WA Debbie Doi 13533 N.E. 48th Redmond, WA Terry Ostree 3715 Freeman Rd. E. Puyallup, WA. Linda N. Bell 2620 Sunset Ln. N.E. Renton, Wa B.L. Scalise 12427 N.E. 72 St. Kirkland, WA. Karyn Vick 13034 S.E. 189th Ct. Renton, WA. Robert Dunda 4822 152nd St. S.W. Edmonds, Wa. Marty Spieks 1615 W. Smith #h101 Kent, WA. Lori Mirante 248 S.W. 184th Seattle, Wa. Lloyd W. Platzke 161 130th Av N.E. Bellevue, WA W.N. Sterry 247 168th 'N.E. Bellevue, WA.' Ronn Griffin 16052 46th Ave S. Seattle, WA 98188 Louvenia Jellerson 28303 4th P1. S. #106 Redondo Beach, WA 98054 A. Perry 2618 S. Dawson St Seattle, WA 98108 Janet Cole 15812 4th Av. S.W. Seattle, WA. M.J. Meola 19449 S.E. 266th Kent, WA. E.F. Shriver 22634 10th Av. S. Seattle, WA. R. Savage 4134 N.E. 143rd Kirkland, WA R.W. Melton 2012 Dayton.N.E. Renton, WA R.L. Rasmusson 2726 60th S.W. Seattle, WA. Gary Swedlund 6018 Lakeview Dr. Kirkland, WA. - 222 Kirk on . 45th P1 WA. Subscribed and sworn to before me this a y' day of 1980. No`€ary Pulbic in and for the St te of Washington, risiding at page 1 S.E. Stevens 5586 S. Juniper Seattle, WA H.O. Korbol 21012 80th West Edmonds, WA. SURMAXEMXIXDROWIM I68S2XISXMXSXXXSXWXXX Larry Burkey 21835 Military Rd. S. Kent, WA. Kathryn Crandell 4804 S. Adams Seattle, WA. Beryl Stowe P.O. Box 5326 Kent, WA. R.E. Fitch 13262 S.E. 261st Kent WA. B.W. Heyamoto 1304 S.W. 164th St. Seattle, WA. Paul Maas 25246 106th Av. S.E. #A200 Kent, WA. K.R. Hemer 4537 55th Av. N.E. Seattle, WA. Betty Brennen 20021 35th ay. S. Seattle, WA J.C. Mclendon 16518 162nd P1. S.E. Renton, WA. Dennis Mcglone 13745 56th Av S. B407 Tukwila, WA 98188 C. Varjas 3770 S. 172nd St. Seattle, WA. R. Lewis 100 N.E. Sunset Boulevard Renton, WA. Morgan Barokas 3841 81st Av. S.E. Mercer Island, WA J.M. England 16407 S.E. Cougar Mt. W. Issaquah, WA. Nancy Shega 3200 S. 176th St. Seattle, WA. 98188 A.F. Leenan 12627 S.E. 217th PL. Kent, WA 98031 S. Fishir 6925 139th P1 Redmond, Wa. 98o52 R. Rueschenberg 17477 7th S.W. Seattle, Wa. 98166 L. P. Washington 4229 S. Raymond Seattle, WA. 98118 D. Leischner 4642 144th P1. S.E. Bellevue, WA. G.E. Chase 7306 Wright Ave S.W. Seattle, Wa. W.R. Gohlke 3435 Auburn Wy. S #17 Auburn, WA. Wilsey & Ham Inc. 1980 112 Av. N.E. Bellevue, WA 98004 AttN: R. Ubaghs Dept. of Transportation Highway Admin. Bldg. Olympia, WA. 98504 Attn: W.P. Albohn King County Budget Div. room 400 King Co. Courthouse 516 Third Ave. Seattle, WA. 98104 Attn:Ii.E. McCaffree King County Planning Div. W -217 King Co. Courthouse Seattle, WA 98104 Attn: Karen Rahm Dept. of Energy Region X 1992 Federal Bldg. 915 Second Av. Seattle, WA 98174 City of Tukwila Fire Dept. 444 Andover Park E. Tukwila Wa 98188 Attn: Chief Crawley Dept. of Agriculture .U.S. Forest Service 1601 Second Ave. Bldg. Seattle, WA 98101. Attn: Jamia Murray Dept. of Fisheries 115 General Administration Bldg. Oympia WA 98504 Attn: Gordon Sandison Scott Salzer -- 14648 lath Av. S.W. Seattle, WA 98166 Seattle Audubon Society 714 Joshua Green Bldg. Seattle, WA. 98101 Attn: David Galvin Dept. of Ecology Mail Stop PV -11 Olympia, Wa. 98504 Attn: B.J. Ritchie City of Renton - Planning Dept. Municipal Bldg. 200 Mill Av S. Renton Wa. 98055 Attn: D.R. Clemens PSAPCA 410;W. Harrison St. P.O. Box 9863 Seattle, WA. 98109 Attn:-A :R. Dammkoehler Doubletree Inn 205 Strander Boulevard Tukwila, WA 98188 Attn: T.S. Dubois Dept. of Game 600.N. Capitol Way Olympia, WA 98504 Attn: Bob Zeigler • Metro Exchange Bldg. 821 Second Av. Seattle, WA 98104 Attn: R. Proctor J.C. Penney Co. P.O. Box 24087 Seattle, WA 98124 Attn: W.R. Lewis Tukwila Police Dept. 6200 Southcenter Blvd. Tukwila, WA 98188 Attn: Chief Sheets Shidler, Mcbroom, Gates & Baldwin 1000 Norton Building' Seattle, Wa. 98104 Attn: G. Mcbroom M.A. Segale P.O. Box 88050 Tukwila, WA. 98188 Chartwell Devel. Co. 555 West Hastings St, Suite 2800 Box 12128 Vancouver, B.C. Canada V6B 4N6 Chartwell Devel. Co. Tukwila Office 331 Andover Park East Suite 40 -41 Tukwila Wa. 98188 Attn: K. Cinnamon PAGE 3 City of Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of Community Development NOTICE OF PUBLIC HEARING Draft Environmental Impact Statement (DEIS) - TUKWILA CITY CENTER On Monday, February 4, 1980 at 7:00 p.m., the Tukwila City Council will conduct a public hearing on the subject DEIS. The hearing will take place in the Council Chambers of Tukwila City Hall, 6200 Southcenter Boulevard. This notice is sent to you as a courtesy only, and is not required by law. The Public Hearing is held in compliance with SEC. WAC- 197 -10- 480(2) and WAC - 197- 10- 485,of the State Environmental Policy Act. Environmental Document Files (EPIC- 18- 79 -SA) pertinent to the DEIS are available for public inspection during regular City Hall business hours. Mark Caughey Acting Responsible Official CitAf Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845. Office of Community Development ■ NOTICE OF.PUBLIC HEARING Draft Environmental Impact Statement (DEIS) - TUKWILA CITY CENTER On Monday, February 4, 1980 at 7:00 p.m., the Tukwila City Council will conduct a public hearing on the subject DEIS. The hearing will take place in the Council Chambers of Tukwila City Hall, 6200 Southcenter Boulevard. This notice is sent to you as a courtesy only, and is not required by law. The Public Hearing is held in compliance with SEC. WAC- 197 -10- 480(2) and WAC- 197- 10- 4850f the State Environmental Policy Act. Environmental Document Files (EPIC- 18- 79 -SA) pertinent to the DEIS are available for public inspection during regular City Hall business hours. Mark Caughey Acting Responsible Official *ILA City of Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 • Office of Community Development 24 January 1980 Chartwell Development Co. Suite 2800, Box 12128 555 West Hastings St. Vancouver, B.C. Canada V6B 4N6 Re: Tukwila City.Center DEIS - Request For Public Hearing, Attached is a copy of a petition requesting a public hearing on the DEIS:.. for the "City Center" development proposal. Also attached is a copy of responsible official's request to the City Council for their sponsorship of the hearing process. In the event that council declines the hearing request, said hearing may proceed before the responsible official on the evening of 4 February 1980. We shall, of course notify you in writing when the date, time, and hearing official is firmly decided. This letter is intended as a courtesy notifi- cation e, ly. rk Caughey Assistant Planner Acting Responsible Official. MC /mkb cc: City Atty.. Mayor City. f Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 • Frank Todd, Mayor MEMORANDUM TO: Maxine Anderson, City Clerk FROM: Mark Caughey, Acting Responsible Official (SEPA) DATE: 24 January 1980 SUBJECT: TUKWILA CITY CENTER DRAFT EIS - REQUEST FOR PUBLIC HEARING Attached to this memo is a copy of a petition signed by approximately sixty employees of the Boeing Company who have requested that a public hearing on the "Chartwell" project be held by the City. Mr. Hard has determined that the petition is in conformance with criteria contained in WAC 197- 10- 480(2b) and that a hearing must be held prior to 7 February 1980. The law does not specify, however,which official of the lead agency should actually conduct the hearing. I am requesting that the City Council conduct the public hearing on 4 February 1980 during their regular meeting. I am asking Council to assume this respon- sibility since they are to make a decision on the final waiver application for this project. I envision the purpose of the hearing as that of receiving testimony only; no staff report or applicant response seems warranted. Formal response to testimony received at the hearing will be included in any final E.I.S. when published. Please ask the Council President to reserve space on the Committee of The Whole meeting agenda of 28 January 1980 for discussion of the public hearing request and for establishing 4 February 1980 as the hearing date. MC /mkb Attachment cc: Mayor Todd •- COMMIiiht OF THE WHOLE - 1/28/80 3 E.I.S. INADEQUACIES: ALLIED STORES 1. Wildlife biologist report missing from E.I.S.' 2. Soil and data studies not included in E.I.S. (due to underground parking and utilities). 3. How City will integrate consequences of this project? drainage? City services? Where will water storage? 4. More traffic and circulation data. 5. Improvements for access into industrial area. 6. Shouldn't parking and use be considered in E.I.S. 7. Building not in SE area not moved. 8. Pond reduced from 17 acres to 6.8 Requested no further action by council until more data is refined into E.I.S. E.I.S.. NOT ADEQUATE - SUMMARY BUD: Under what conditions can a new prel. E.I.S. be done? LARRY: Prelim. E.I.S. done, comments submitted, city must answer or respond to continents, draft and comments and responses - make final E.I.S. Public hearing on E.I.S. has been requested by petition and is now mandatory. City has right to do an extensive redraft of preliminary E.I.S. MARK: Responsible Official can, after prel. E.I.S., can take continents and: 1) Respond to comments and include as final E.I.S. 2) If prel. is inadequate, may need to rewrite prel., respond to comments, and publish both as final. - 20 comments on E.I.S. MAIN COMMENTS: MAYOR: requested City council to allow a court reporter for PH on Chartwell E.I.S. (information gathering only, as discussion) DAN SAUL: Is gas line along Strander Blvd. in E.I.S.? If not, should it be? HUBERT CRAWLEY: Chartwell knows about it. See other buildings there was not a problem because of gas line. Committee of the Whole /28/80 Chartwell Comments PUBLIC HEARING: Chartwell on February 4, 1980. COUNCIL MOTIONS: 1. PH on EIS on 2/4/80 2. a) Have court reporter present b) Testimony only, no responses or debate KS /mkb Page 2 28• January 1980 • CITY OF TUKW'IL4 NOTICE OF PUBLIC HEARING February 4, 1980 7:00 PM. (DATE) (TIME) Notice is hereby given that the ONNOW16 City of Tukwila will conduct a PUBLIC HEARING on the above date at City Hall, 6200 Southcenter Boulevard, to =Ili= receive comments on the Draft Environmental Impact Statement (DEIS) for the project titled "Tukwila City Center" as proposed by the Chartwell Development Co. All interested persons are encouraged to appear and be heard. Mark (mighty Acting Responsible Official Published in the Record - Chronicle on Wed., January 30, 1980 J0 • January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila-Pond ". The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by the City of Tukwila. We feel that a public hearing should be held on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, or adversly impacted by a project. We the undersigned are either residents of or, consider ourselves adversely impacted by the proposed development-and as such request a public hearing as provided by WAC 197 -10 -480. NAME ADDRESS Signed SIGNITURE 2LXIC Q, 9-rv-o 4 • • January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the- "Tukwila- Pond ". The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by the City of Tukwila. We feel that a public hearing should be held on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, or adversly impacted by a project. We the undersigned are either residents of or consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197 -10 -480. Signed NAME ADDRESS SIGNITURE. 1)0034 CA a120 2'"; kotPai t- VC IU Dfz. I(-EN.T Dflutak-Esz oto r H'1 V 136E -(..V I L Le= 1 11923 I °J RYE. '. 4162.14. SEATr[.G, 1/44%. �, ► N■ Su/ //3,53 nE iil/ kanalL , u1�} a9k.0 , at}d-t 2/7/5 A,Lein a-de-901/4-66i' `Oit AO • January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila- Pond ". The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts.. At the present time no public hearing is scheduled for the project by the City of Tukwila. We feel that a public hearing should be held on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, . or adversly impacted by a project. We the undersigned are either residents of or consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197 -10 -480. - — -- ---Signed NAME ADDRESS SIGNATURE 12421 ASE 72, "`�� ST KM k [All(p � U JJ, „al J7 , i w. i"ti 41i / ks (,v . 7-7n1., ' H /O/ January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila- Pond ". The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by ti he City of Tukwila. We feel that a public hearing should be held on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, or adversly impacted by a project. We the undersigned are either residents of or consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197 -10 -480. NAME ADDRESS / .rgi%� /7. c 6u 6 kf ?mss i o /;c- r LuA Signed 17(avt-er tZ7,741_,s2/ -bfr(---11, /Vizi dArOi/n MLA-4 UM. SIGNITURE 2Y attitt) 71?4 c/o v W4 /82-41-e:: )214-e/e /%61' 4/) h/ l.oR ,4, u�r ./Es fEbF,QAC uJ,4V (4,4 / oC74-- , fl January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that. the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila- Pond ". The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by the City of Tukwila. We feel that a public hearing should be held on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, or adversly impacted by a project. We the undersigned are either residents of or, consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197 -10 -480. Signed NAME ADDRESS SIGNATURE .91-7 Je / /rfo•• /6'05 2_ 4/S GvA. c79 /f% c.V1303_ ,5f/` g 11. �5, 70/o4, SQ Q� R'S'(t)a f j lip- li` -i'',• -'/- • January 18, 1980 Mr. Djell Stoknes Director of Planning Office-of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila- Pond ". The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by the City of Tukwila. We feel that a public hearing should be held on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, or adversly impacted by a project. We the undersigned are either residents of or consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197 -10 -480. NAME M JANE M aoi i Signed ADDRESS SDUTFICEAIiE� CO Aka.UTEe.. /9449 SE 'el cb T RE_A)T '40trc;Nce.r49a— cervYvvvu C NOV__ '22404- tick • ScAt4 SIGNITURE q+2--'4,12„ I1 JGN4RO W. YEi-i DA/ 2012 DAYT1 A! AE, k,O,L„,0 I. 41010,, ►-, �- . .acswAulssoyn a -iab Gor"` s.W - S.QcL Ta-L • January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila-Pond ". The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by the City of Tukwila. We feel that a public hearing should be held on a project of this magnitude. • The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, or adversly impacted by a project. We the undersigned are either residents of or consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197-10-480. Gary Si1115/ sse di Signed ADDRESS AGILEedgt...J7 go/8 La �UQ«• lirj /C,'rkl�o� ,8222 iilj %s 0Z. k /Aipi/vb < �/ January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila - Pond ". The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by the City of Tukwila. We feel that a public hearing should be held on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, or adversly impacted by a project. We the undersigned are either residents of or consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197 -10 -480. NAME ADDRESS SH,9RDA1 CHR /5T0PliERSok ` /zoa 5a -/3 Eh' S. le). Signed SIGNITURE Qq, • January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila-Pond ". The draft EIS indicates that 27,500 vehicle trips, per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by the City of Tukwila. We feel that a public hearing should be held on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, or adversly impacted by a project. We the undersigned are either residents of or consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197 -10 -480. IJUSi r��ss�c Cial..d.ress c� -'-lam 4 I l Fay sus C0 2 S 64vatvex a./I,c.Wc s-1--i Signed w41% NAME ADDRESS SIGNITURE Vak-iNitr cyri„, Ltt t LI O! S, Avl avns Sette.. 13,t rVL j. -r"c9 (4)6 7?O.732X 53 G b _p/i- F,./ /3z& z_ /= k pia a S 2 S cf-6 -10 t t" A, S t' 4P,¢L 00 (Ce.a oFFccE ; 6)-1" flv PPo��t 4T,�ii�ww�cjq f'c f537- CC-�,t ,� • 4)4,1. e • • January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila-Pond ". The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by the City of Tukwila. We feel that a public hearing should beheld on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, or adversly impacted by a project. We the undersigned are either residents of or consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197 -10 -480. NAME Signed ADDRESS SIGNITURE "efe.17. Zfh_e4r ia,c) Z' o' /3 P45' 33 244 Ave., 5o. B -'07 ,i/c t..a �. rzZy.,/ 744_ Akkefg;1,-//,r .377o - / 7 , 2 4 , / # 6 /o 0 Al 4'S��✓5 E'T!3!v . 6i✓75 .�� ,,A.,;,,G �/, AzA,plig4 3p?(- F-P.S,£ Ake„LJA,4 January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila- Pond ". The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by the City of Tukwila. We feel that a public hearing should be held on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, . or adversly impacted by a project. We the undersigned are either residents of or consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197 -10 -480. 4-/ua sk,3. Signed ADDRESS /6'07 SC 6a54/"Al /5S4zed, `h SIGNITUR 37,00 &IAA /74,A, Sev*le W4i8m6 oil „ /,2 6. s. e- ..2 r7/.� 93 03 abeg,, 5.F esced.be (a t3°! +1/4 1 ( 6lf.4.140,.t, 9430 S z •4 �fa2 -1- So, RA • January 18, 1980 Mr. Djell Stoknes Director of Planning Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: It has been brought to our attention that the Chartwell Development Corporation proposes to locate a two million square foot office, hotel and retail shopping complex in Tukwila. The complex to be located on the 38.9 acres of land located at the intersection of Andover Park West and Strander Boulevard, which includes the "Tukwila- Pond The draft EIS indicates that 27,500 vehicle trips per day will be generated by the project among other significant environmental impacts. At the present time no public hearing is scheduled for the project by the City of ,Tukwila. We feel that a public hearing should be held on a project of this magnitude. The provisions of WAC 197 -10 -480 requires that a public hearing be held on a project when requested by fifty (50) or more people residing in the vicinity of, or adversly impacted by a project. We the undersigned are either residents of or- consider ourselves adversely impacted by the proposed development and as such request a public hearing as provided by WAC 197 -10 -480. Uij( IA�'1 ��nN�,(� 5 AuRURA �uY So �q 197 -10 -465 Environmental Policy act (d) Regional air pollution control authori- ty or agency. (2) Water resources and water quality. (a) Department of game. (b) Department of ecology. (c) Department of natural resources (state —owned tidelands, harbor areas or beds of navigable waters). (d) Department of social and health ser- vices (public water supplies, sewer systems, shellfish habitats). (e) Department of fisheries. (f) Oceanographic commission (marine waters). (3) Fish and wildlife. (a) Department of game. (b) • Department of fisheries. (c) Oceanographic commission (marine waters). (4) Solid waste. (a) Department of ecology. (b) Department of fisheries (dredge spoils). (c) Department of social and health services. (5) Noise. (a) Department of ecology. (b) Department of social and health services. (6) Hazardous substances (including radiation). (a) Department of ecology. (b) Department of social and health services. (c) Department of agriculture (foods or pesticides). (d) Department of fisheries (introduction into waters). (e) Oceanographic commission (introduc- tion into marine waters). Natural resources development. (a) Department of commerce and eco- nomic development. (b) Department of ecology. (c) Department of natural resources. (d) Department of fisheries. (e) Department of game. (f) Oceanographic commission (related to marine waters). (8) Energy production, transmission and consumption. (a) Department of commerce and eco- nomic development (office of nuclear energy development nuclear). (b) Department of ecology. (c) Department of natural resources (geo- thermal, coal, uranium). (d) State energy office. (e) Energy facility site evaluation council (thermal power plants). (f) Utilities and transportation commission. Land use and management. (7) (9) [Ch. 197 -10 WAC —p 281 (a) Department of commerce and eco- nomic development. (b) Department of ecology. (c) Department of fisheries (affecting surface or marine waters). (d) Department of natural resources (tidelands or state —owned or —man- aged lands). (e) Office of community development. (10) Transportation. (a) Department of transportation. (b) Utilities and transportation commission. (c) Oceanographic commission (water borne). (11) Recreation. (a) Department of commerce and eco- nomic development. (b) Department of game. (c) Department of fisheries. (d) Parks and recreation commission. (e) Department of natural resources. (12) Archaeological /historical. (a) Office of archaeology and historic preservation. (b) Washington state university at Pull- man (Washington archaeological re- search center). [Order DE 77 -24, § 197 -10 -465, filed 12/22/77; Order 75 -1, § 197 -10 -465, filed 12/17/75.] WAC 197 -10 -470 Cost to the public for reproduc- tion of environmental documents. The lead agency shall provide a copy of any environmental document, in ac- cordance with chapter 42.17 RCW, charging only those costs allowed therein plus mailing costs. However, no charge shall be levied for circulation of documents to other agencies as required by these guidelines. [Order DE 77 -24, § 197 -10 -470, filed 12/22/77; Order 75 -1, § 1.97 -10 -470, filed 12/17/75.] WAC 197 -10 -480 Public hearing on a proposal When required. (1) If a public hearing on the proposal is held pursuant to some other requirement of law, such hearing shall be open to consideration of the environ- mental impact of the proposal, together with any avail- able environmental document. (2) In all other cases a public hearing on the environ- mental impact of a proposal shall be held whenever one or more of the following situations ms a occur: (a) The lead agency determines, in its sole discretion, that a public hearing would assist it in meeting its re- sponsibility to implement the purposes and goals of nd these guidelines; or, hen fifty or more person residing within the juris•iction of the lead agency, or who would be ad- versely affected b the en al of the pro - �OSa w ma a written request to the lead agency within thirty —five days of issuance of the draft EIS; or, 1.77,0K5 /Alex. we HAO N (12/22/77) • Environmental Policy act • 197 - 10-530 (c) When two or more agencies with jurisdiction over a proposal make written request to the lead agency within thirty -five days of the issuance of the draft EIS. (3) Whenever a public hearing is held under subsec- tion (2) of this section, it shall occur no later than fifty - one days from the issuance of the draft EIS and no ear- lier than fifteen days from such date of issuance. [Order DE 77 -24, § 197 -10 -480, filed 12/22/77; Order, 75-1, § 197 -10 -480, filed 12/17/75.] WAC 197 -10 -485 Notice of public hearing on envi- ronmental impact of the proposal. Notice of all public hearings to be held pursuant to WAC 197 -10- 480(2) shall be published in a newspaper of general circulation in the area where the project will be implemented. For nonproject actions the notice shall be published in the general area where the lead agency has its principal of- fice. The notice shall be published no later than five days preceding the hearing. For nonproject proposals having regional or statewide applicability, copies of the notice shall be transmitted to the Olympia bureaus of the associated press and united press international. [Or- der DE 77 -24, § 197 -10 -485, filed 12/22/77; Order 75 -1, § 197 -10 -485, filed 12/17/75.] WAC 197- 10-490 Public hearing on the propos- al Use of environmental documents. Whenever a public hearing is held on the environmental impact of a proposal, it shall be open to discussion of all environ- mental documents and any written comments which have been received by the lead agency prior to the hear- ing. A copy of the draft EIS shall be made available for public inspection at the public hearing. [Order 75 -1, § 197 -10 -490, filed 12/17/75.] WAC 197 -10 -495 Preparation of amended or new draft EIS. (1) A lead agency shall prepare an amended or new draft EIS whenever it determines: (a) That substantial changes have been made in the proposal, or significant new information concerning an- ticipated environmental impacts has become available subsequent to circulation of the initial draft EIS, and (b) That circulation of a new draft EIS is necessary to provide further input and review on the proposal. (2) In such event, the lead agency shall follow the provisions of WAC 197 - 10-450 through 197- 10-490 for the amended or new draft EIS. [Order 75 -1, § 197- 10-495, filed 12/17/75.] WAC 197 - 10-500 Responsibilities of consulted agencies —Local agencies. Each local agency, when responding to a consultation request prior to a threshold determination, participating in pre -draft consultation, or reviewing a draft EIS, shall provide to the lead agency that substantive data, information, test results and other material which it possesses relevant to its area of juris- diction, to the services it will provide, or to the impacts upon it associated with the proposal. Field investigations (12/22/77) are not required of local consulted agencies. Local agen- cies are not required to transmit information which has been previously transmitted to the lead agency, or which is already reflected in the draft EIS. [Order 75 -1, § 197 -10 -500, filed 12/17/75.] WAC 197 -10 -510 Responsibilities of consulted agencies State agencies with jurisdiction. Each state agency with jurisdiction, when responding to a consulta- tion request prior to a threshold determination, partici- pating in pre -draft consultation, or reviewing a draft EIS, shall immediately begin the research and, if neces- sary, field investigations which it would normally con- duct in conjunction with whatever license it requires for a proposal. In the event no license is involved, the agency with jurisdiction shall investigate the impacts of the ac- tivity it will undertake which gives it jurisdiction over a portion of the proposal. The end result of these investi- gations should be that each agency with jurisdiction will be able to transmit to the lead agency substantive infor- mation on those environmental impacts of the proposal which are within the scope of the license or activity of the agency with jurisdiction. An agency with jurisdic- tion, in its response to the lead agency, should also indi- cate which of the impacts it has discovered may be mitigated or avoided and how this might be accom- plished, and describe those areas of environmental risk which remain after it has conducted the investigations that may have been required. [Order DE 77 -24, § 197- 10-510, filed 12/22/77; Order 75 -1, § 197 -10 -510, filed 12/17/75.] WAC 197 - 10-520 Responsibilities of consulted agencies —State agencies with environmental expertise. (1) When requested by the lead agency, each state agency participating in pre -draft consultation, or re- viewing a draft EIS, lacking jurisdiction, but possessing environmental expertise pertaining to the impacts asso- ciated with a proposal [see WAC 197 - 10-465], shall provide to the lead agency that substantive data, infor- mation, test results or other material relevant to the proposal which the consulted agency possesses relating to its area of special expertise. (2) The consulted agency may at its option investi- gate, develop and transmit whatever additional informa- tion is necessary for the lead agency to meet its responsibilities under WAC 197 -10-440 or 197 -10 -442. [Order DE 77 -24, § 197 -10 -520, filed 12/22/77; Order 75 -1, § 197 -10 -520, filed 12/17/75.] WAC 197 -10 -530 Responsibilities of consulted agencies —When pre -draft consultation has occurred. When a consulted agency has engaged in the pre -draft consultation procedures set forth in WAC 197 -10 -410, the scope and depth of its required review and comment upon the draft EIS is limited to those appropriate and relevant matters which were not contained in its previous response (such as when significant new information be- comes available which was not available to the consulted ICI. 197 -10 WAC-p 29J TUKWILA CITI' CENTER DEIS CHARTWELL DEVELOPMENT CORP DEVELOPMENT OF RETAIL NEAR TUKWILA POND EPIC- 18 -79 -SA FILE # 3 1908 ' Ci ty * Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 Edgar D Bauch, Mayor M EMORANDUM TO: Receipients of Draft EIS FROM: Kjell Stoknes, OCD Director (Responsible Official) DATE: November 30, 1979 SUBJECT: Draft Environmental Impact Statement: Revised Tukwila Zoning Ordinance (Proposed) Based on the comments received in the draft EIS and the public testi- mony submitted at three public hearings, the responsible official has determined that there is a reasonable expectation of major changes to the proposed zoning document. Because such changes may seriously undermine the appropriateness of the draft EIS, the City has chosen not to pursue preparation of a final EIS at this time. Pursuant to SEPA guidelines, WAC- 197 -10- 580(3), a new or revised draft EIS will be prepared at such time as the Tukwila Planning Commission makes an official recommendation to the City Council. All parties receiving this notice will also be notified of the availabi- lity of any new or revised draft EIS on proposed revisions to the Tukwila Zoning Ordinance. KS /FS /mkb U.S. Environmental Protection Agency Region .X 1200 6th Avenue Seattle, Washington 98101 ATT Walter Jaspers Department of Ecology Environmental Review Olympia, Washington .98504 Attention: Dennis Lundblad Puget Sound Council of Governments Brian Beam, Env. Plan. Div. Grand Central on the Park Seattle, Washington .98104 Puget Sound Air Pollution Control Agency 410 West Harrisson Street P.O. Box 9863 Seattle, Washington 98109 Attention: A. R. Dammkoehler Municipality of Metropolitan Seattle Environmental Planning 821 2nd Avenue Seattle, Washington 98104 Attention: Peter Mancho King County Department of Budget and Program Planning King County Courthouse Room C205 Seattle, Washington 98104 Washington State Department of Commerce and Economic Development 312 1st North Seattle, Washington 98104 Washington State Department of Social' and Health Services P.O. Box 1788 Olympia, Washington 98504 Attention: Wallace Lane City of Kent Planning Department P.O. Box 310 Kent, Washington .98031 Attention: James P. Harris • 1 ::;• .; • I City of Renton Planning Department 200 Mill Avenue S. Renton, Washington 98055 Attention: Gordon Ericksen, Dir. Charles Baker Tukwila Industrial Council P. 0. Box 88556 Tukwila, Washington 98188 - Department of Transportation Highway Administration Bldg. Olympia, Washington 98504 Attention: H.R. Goff ................ ......................... ............. . ...................... .•• Washington State Department of Game Environmental Management Division 600 North Capitol Way Olympia, Washington 98504 Attention: Eugene Dziedzic • Washington State Department of Fisheries 115 General Administration Bldg.; Olympia, Washington 98504 Atteption: Gil Holland ..... ........................... Washington State Office of Planning and Community Affairs ......... . Insurance Building Olympia, Washington 98504 Attention: Gerald Probst Cit y tf Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 MEMORANDUM To: Kjell S es, 0.C.D. Director FROM: Fred tterstrom, Planner DATE: 16 o -mber 1979 SUBJECT: Proposed Zoning Ordinance. Environmental Impact Statement Alternative Courses of Action for Final E.I.S. According to the.SEPA guidelines (See,, WAC 197 -10 -580), the City has basi- cally two optional courses of action for preparing a final E.I.S., depending upon whether comments received seriously undermine the adequacy or integrity of the draft E.I.S. or the proposal. If the City determines that no changes are required in either the draft E.I.S. or the proposal despite critical comments received, we could press ahead and issue a final E.I.S. pursuant to WAC 197 -10- 580(2). On the other hand, if the City determines that it is appropriate to rewrite the draft E.I.S. in order to . respond to critical comments received then it may choose to re- circulate a new draft E.I.S. pursuant to WAC. 197 -10- 580(3). Criticisms of the Ordinance and E.I.S. The Planning Division has received a number of letters which have been critical of the scope and content of the draft E.I.S. on the proposed zoning ordinance. Criticism of the E.I.S. can be lumped into two main categories: 1. Inadequate discussion of the economic impact to non - conforming uses; particularly with reference to the difficulty of re- financ- ing non - conforming uses and structures with the resultant effect of reduced maintenance, and the possible future blight of certain areas in the City. Some commentors have also questioned the ultimate economic impacts to the City of designating uses as non - conforming. 2. Inadequate discussion of alternatives has also been cited a short- coming of the draft E.I.S. particularly as this discussion, pertains to certain properties within the City which are earmarked for zone changes. Public hearings which have been held by the Planning Commission on 15 October 1979, 8 November 1979, and 15 November 1979, have also served to highlight the above issues, as well as others. While I believe the non - conforming use issue has been dramati- cally overstated, there are some uses /buildings which would become non - conforming if draft #3 were adopted where no ostensible public purpose would be served. jell'Stoknes, O.C.D. Itector Proposed Zoning Ordinance Environmental Impact Statement Page 2 16 November 1979 A definite portion of what the public has been stating is true and I contemplate changes in the proposal will result. Recommendation Based on the number and content of comments received on the draft E.I.S. and the proposed ordinance, I feel that we should not proceed with the final E.I.S. at this time. I anticipate substantial changes will be made to the proposed zoning document by the Planning Commission which will result in an ordinance significantly different from the draft #3 document. As a result, any draft and final E.I.S. which would be completed on draft #3 would have to be entirely redone following major changes to the proposal. Therefore, I recommend that the City, as lead agency, opt to rewrite the draft E.I.S. on the Planning Commission's recommendation to the City Council and follow it up by a final E.I.S. prior to Council action on the ordinance. Should you agree with this course of action, we should issue a statement to this effect to all those who have either submitted oral or written testimony on the proposed zoning ordinance or draft E.I.S. FS /mkb City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 TO: Fred Satterstrom FROM: Kjell Stokness- DATE: November 19, 979 SUBJECT: Draft #3 - Preliminary Zoning Ordinance and Preliminary Environmental Impact Statement (related to it). MEMORANDUM I agree with your analysis and recommendation on not pursuing a final Environment Impact Statement on Proposed Draft #3 of the zoning ordinance. I agree that, based on the comments at the public hearing, that the douument will be changed substantially, and that a new Preliminary Environmental Impact Statement will have to be done on the document, as changed after the Planning Commission workshops. At this point, I feel that we need to go back to the very beginning of our zoning ordinance update process, and redefine the following items: 1. As it relates to zoning changes, what are some examples of substantial public purpose? 2. What were the original objectives sought in modifications to the pre- sent zoning ordinance? 3. Are those objectives actually being accomplished with the proposed draft document? 4. Where do we go from here? On the "Where do we go from here" concept, I see two alternates. They are as follows: 1. Drop the entire Proposed Zoning Ordinance and stay with our present code. The implications of this would be as follows: a. The Zoning Map should be adopted to make the map consistent with the Comprehensive Plan. Changes to the map in the Compre- hensive Plan would also be necessary to accomplish inconsistencies between the actual land uses approved in the waiver procedure and the Comprehensive Plan Map iteself. b. The Planning Commission should determine which sections in the present zoning ordinance are in the greatest need of updating, and amend the present code on a chapter -by- chapter basis. 2. Take the comments received on Draft #3 of the Proposed Zoning Ordinance as constructive criticism, and make the type of changes needed to make the • • Red Satterstrom Draft #3- Preliminary Zoning Ordinance & Preliminary Environmental Impact Statement Page 2 November 19, 1979 document maximize its consistency with the Comprehensive Plan while not creating mass non - conformance and other related problems. I feel we should provide some direction to the Planning Commission in leading a discussion on the above subject. I feel we should be entirely open with the Planning Commission, and not lead them into a particular course of action, but provide information and try to encourage them to lead the way from this point on. I will prepare a letter to recipients of the Preliminary Environmental Impact Statement to the affect that a final will not be developed, and the reason for this decision. KS /mkb STATE OF WASHINGTON Dixy Lee Ray Governor November 5, 1979 • DEPARTMENT OF FISHERIES 115 General Administration Building, Olympia, Washington 98504 206/753 -6600 Mail Stop AX -11 City of Tukwila Office of Community Development 6200 South Center Boulevard Tukwila, Washington 98188 Attention Fred Satterstrom, Planning Supervisor Gentlemen: Draft Environmental Impact Statement - Proposed Tukwila Zoning Ordinance, King County WRIA B -09 We have no specific comments to make regarding the above - referenced document because it is a non - project proposal. We will make appropriate comments on project environmental impact statements. The document is particularly well prepared and the discussion of fish in the Green River is accurate except that game fish such as steelhead are not mentioned. We appreciate the fine section dealing with storm water and its Potential impact on the aquatic environment. Thank you for the opportunity to comment and if you have any questions contact the Natural Production Division (206) 753 -6650. Sincerely, Gordon (Sandi Director bq cc: Game 3 CIjY }I;;.YILg r 9 48/9 • STATE OF WASHINGTON Dixy Lee Ray Governor DEPARTMENT OF TRANSPORTATION KF -01 Highway Administration Building, Olympia, Washington 98504 206/753-6005 November 1, 1979 Mr. Kjell Stoknes, Director Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 City of Tukwila Proposed Zoning Ordinance Draft Environmental Impact Statement Dear Mr. Stoknes: We have reviewed the subject document and have no comments to offer regarding the proposal. Thank you for the opportunity to review this information. Sincerely, ROBERT S. NIELSEN Assistant Secretary for Public Transportation and Planning By: WM. P. ALBOHN Environmental Planner RSN:bd WPA /WBH. cc: J. D. Zirkle /T R. Burke R. Albert Environmental Section O.C.D. • CITY Of TUKWILA A 4 PONT MHO QM3 POILIWYOCA CONWAL t C MC i? Mr. Kjell Stoknes Director of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, WA 98188 Dear Mr. Stoknes: • 410 West Harrison Street, P.O. Box 9863 (206) 344 -7330 Seattle, Washington 98109 November 15, 1979 Proposed. Tukwila Zoning Ordinance In response to the Draft EIS for the proposed Tukwila Zoning Ordinance the the Draft EIS adequately addresses the impacts of the proposed action on air quality. Thank you for the opportunity to comment. tp SERVING: KING COUNTY 410 West Harrison St. P.O. Box 9863 Seattle, 98109 (206) 344 -7330 KITSAP COUNTY Dial Operator for Toll Free Number Zenith 8385 Bainbridge Island, 98110 Dial 344 -7330 PIERCE COUNTY 213 Hess Building Tacoma, 98402 1206) 383 -5851 SNOHOMISH COUNTY 12061 259 -0288 BOARD OF DIRECTORS CHAIRMAN: Gene Lobe, Commissioner Kitsap County; James B. Haines, Commissioner Snohomish County, Harvey S. Poll, Member at Large; Very truly yours, A. R. Dammkoehler Air Pollution Control Officer G -11 3,ti'il r Glenn K. Jarstad, Mayor Bremerton; William E. Moore, Mayor Everett; Charles Royer, Mayor Seattle; John D. Spellman, King County Executive; VICE CHAIRMAN: Patrick J. Gallagher, Commissioner Pierce County; Mike Parker, Mayor Tacoma; A. R. Dammkoehler, Air Pollution Control Officer. STATE OF WASHINGTON DEPARTMENT OF GAME 600 North Capitol Way, GJ -11 Olympia, WA 98504 200753 -5700 Dixy Lee Ray Governor 15 November 1979 Mr. Kjell Stoknes Director of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Mr. Stoknes: 1 DRAFT ENVIRONMENTAL IMPACT STATEMENT: Proposed Tukwila Zoning Ordinance City of Tukwila, King County Your document was reviewed by our staff as requested; our comments follow. We appreciate your maps especially those dealing with soil groups, hydrology, wooded areas and land use. They show marshy soils, and surface water in addition to showing undeveloped and farm land. Your discussion of existing conditions for wildlife is essentially accurate. The Green River does support significant runs of anadromous fishes as well as large numbers of resident fishes. The river and ponds and marshes are in the Pacific Waterfowl Flyway and do support waterfowl. Even City Light Pond provides feeding and nesting for large numbers of geese and ducks. Wetlands and stream and river bank areas support the largest number and most diverse types of wildlife and are also the most sensitive to habitat alteration. Impacts on the land surrounding standing water usually have the most significant impact on fish and wildlife as well. In a natural condition, wetlands and riparian zones have benefits beyond those to fish and wildlife as these areas maintain water quantity and quality and provide flood protection. We appreciate the fact that you are providing some reduction of the impacts to fish and wildlife over what would occur under existing zoning. However, we recommend more measures be taken to protect public resources. A shoreline zone that would prohibit alteration to the Green River channel and prohibit land - filling in the river is a step in the right direction. However, we also recommend that fish, wildlife, and other public resources be part of your planning. We suggest that urban wilds be developed and that an environmentally sensitive areas program be developed. Wetlands (marshy soils, marshes, bogs and swamps) and riparian areas are environmentally sensitive. To protect wildlife resources, 200 foot corridors of native vegetation should be left to separate development from the wetlands and /or standing water. Where there are at least 200 feet of 3 • • page 2 Mr. Kjell Stoknes 15 November 1979 undeveloped land we recommend these setbacks. Prevention of water pollution in stormwater runoff is essential to the protection of fish resources. We point out that for sedimentation ponds and oil traps to have any effectiveness, they must be cleaned frequently. We also recommend the use of native vegetation in landscaping. Native vegetation would provide the most benefit for wildlife. Thank you for sending your document. We hope you find our comments helpful. Sincerely, THE DEPARTMENT OF GAME Bob Zeigler, pplied Ecologist Environmental Affairs Program Habitat Management Division BZ:bj cc:Agencies Regional Manager • ETRD Municipality of Metropolitan Seattle Exchange Bldg. • 821 Second Ave., Seattle, Washington. November 8, 1979 Mr. Kjell Stoknes Director of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Stoknes: 9 N cm oC woo NOV 1 3 jJ 1' Draft Environmental Impact Statement Proposed Tukwila Zoning Ordinance Metro staff has reviewed this proposal and anticipates no adverse impacts to its wastewater facilities or the public transportation system. Metro's transit development staff is currently engaged in studies to develop a long -range regional transit plan (MetroTRANSITion) to support the adopted land use and development plans for the region and local jurisdictions. One of the studies resulting from this effort, "Regional Overview Study: 1990 Transit Sketch Plan Analysis /Regional Systems Issues and Implications" (May, 1979), suggests that concentrated land use, particularly in regards to employment, can significantly influence the utilization and effectiveness of a transit system. We are forwarding a copy of this study to you with this response for your consideration during the review of the proposed revisions to the city zoning ordinance. Thank you for the opportunity to review and comment. Very truly yours, Rodney G. Proctor, Manager Environmental Planning Division RGP : apg Attachment 1959-1979• Our Twentieth Year STATE OF WASHINGTON Dixy Lee Ray Governor • • DEPARTMENT OF ECOLOGY Olympia, Washington 98504 206/753.2800 Mail Stop PV -11 November 8, 1979 Mr. Fred Satterstrom Planning Supervisor Office of Community Development City of Tukwila 6200 Southcenter Boulevard Tukwila, Washington 98188 Dear Mr. Satterstrom: Thank you for allowing us the opportunity of reviewing the draft environmental impact statement for the Revised Zoning Ordinance Text and Map for the city of Tukwila. The document was reviewed in our Northwest Region and headquarters offices. The statement appears to do a good job of considering possible environmental impacts that may occur as the result of zoning changes; however, we have no substantive comments to offer. AES:mgh Sincerely, Cam. -e4e) Ann E. Smith Environmental Review Section 7 C. u.0. CITY OF TUKWILA NOV 3 wry ;1908 City of Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of Community Development 10 October 1979 TO: EIS Review Individuals and Agencies FROM: Kjell Stoknes, Responsible Official SUBJECT: Environmental Impact Statement (Draft): Proposed Zoning Ordinance, City of Tukwila Please find enclosed a copy of the draft Environmental Impact Statement on the City of Tukwila proposed Zoning Ordinance revision. The issue date of the draft EIS is 10 October 1979. Comments on the draft EIS are due by 15 November 1979. Should you have any questions or desire further information regarding the proposed action or the contents of the draft EIS, please don't hesitate to contact the Tukwila Planning Division at 433 -1845. \NILA ,c yt4 s City of Tukwila ok Planning Division W �� 0 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of .Community Development 10 October 1979 TO: EIS Review Individuals and Agencies FROM: Kjell Stoknes, Responsible Official Lu.c� SUBJECT: Environmental Impact Statement (Draft): Proposed Zoning Ordinance, City of Tukwila Please find enclosed a copy of the draft Environmental. Impact Statement on the City of Tukwila proposed Zoning Ordinance revision. The issue date of the draft EIS is 10 October 1979. Comments on the draft EIS are due by 15 November 1979. Should you have any questions or desire further information regarding the proposed action or the contents of the draft EIS, please don't hesitate to contact the Tukwila Planning Division at 433 - 1845. City of Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of Community Development 10 October 1979 TO: EIS Review Individuals and Agencies FROM: Kjell Stoknes, Responsible Official SUBJECT: Environmental Impact Statement (Draft City of Tukwila . Proposed, Zoning Ordinance, Please find enclosed a copy of the draft Environmental Impact Statement on the City of Tukwila proposed Zoning Ordinance revision: The issue date of the draft EIS is 10 October 1979. Comments on the draft EIS are due by 15 November 1979. Should you have any questions or desire further information regarding the proposed action or the contents of the draft EIS, please don't hesitate to contact the Tukwila Planning Division at 433 -1845. City of Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of Community Development 10 October 1979 TO: EIS Review Individuals and Agencies FROM: Kjell Stoknes, Responsible Official SUBJECT: Environmental Impact Statement (Draft): Proposed Zoning Ordinance, City of Tukwila Please find enclosed a copy of the draft Environmental Impact Statement on the City of Tukwila proposed Zoning Ordinance revision. The issue date of the draft EIS is 10 October 1979. Comments on the draft EIS are due by 15 November 1979. Should you have any questions or desire further information regarding the proposed action or the contents of the draft EIS, please don't hesitate to contact the Tukwila Planning Division at 433 -1845. City of Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of .Community Development 10 October 1979 TO: EIS Review Individuals and Agencies. FROM: Kjell Stoknes, Responsible Official SUBJECT: Environmental Impact Statement (Draft): Proposed Zoning Ordinance, City of Tukwila Please find enclosed a copy of the draft Environmental Impact Statement on the City of Tukwila proposed Zoning Ordinance revision. The issue date of the draft EIS is 10 October 1979. Comments on the draft EIS are due by 15 November 1979: -r:'_ Should you have any questions or desire further information regarding the proposed action or the contents of the.draft EIS, please don't hesitate to contact the Tukwila Planning Division:at 433 -1845. • City of Tukwila Planning Division 6200 Southcenter Boulevard Tukwila, Washington 98188 433 -1845 Office of .Community Development 10 October. 1979 TO: EIS Review Individuals and Agencies. FROM: Kjell Stoknes, Responsible Official SUBJECT: Environmental Impact Statement (Draft): City of Tukwila Proposed Zoning Ordinance, Please find enclosed a copy of the draft Environmental Impact Statement on the City of Tukwila proposed Zoning Ordinance revision. The issue date of the draft EIS is 10 October 1979. Comments on the draft EIS are due by 15 November 1979. Should you have any questions or desire further information regarding the proposed action or the contents of the draft EIS, please don't hesitate to contact the Tukwila Planning Division at 433 -1845. City of Tukwila Fire Department Kjell Stoknes O.C.D. Director City Hall City of Tukwila Dear Kjell: Edgar D. Bauch Mayor Hubert H. Crawley Fire Chief Fire,P.evention Bureau September 28, 1979 OCT. I Per Chief Crawley's request, I have reviewed the proposed new zoning ordinance. With regard to our long- standing problem of apparent "over- parking" and parking lot congest- ion at areas such as the Professional Plaza and the Koll complexes, I find nothing in the proposal aimed at correcting this situation. In fact, the ratio of required parking spaces for office buildings, clinics, and commer- cial buildings is identical to the old requirements. Please review these sections, and let's not let the opportunity to correct a serious problem slip by. JH :vma cc:TFD file Chief Crawley City of Tukwila Yours very truly, James A. IIoel Fire Marshal 41 Fire Department, 444 Andover P ast; Tukwila, Washington 98188 (206) 575 -4404 '1908' • City of Tukwila 6200 Southcenter Boulevard Tukwila Washington 98188 Edgar Q Bauch, Mayor MEMORANDUM TO: Plan g Commissioners FROM: Fr N. Satterstrom, Project Planner DATE: 10 ctober 1979 SUBJECT: Pro osed Zoning Ordinance Enclosed you will find copies of the following documents: 1. Proposed Zoning Ordinance 2. Environmental Impact Statement: Proposed Zoning Ordinance 3. Proposed Zoning Map (Preliminary) Please review these materials thoroughly for the zoning ordinance public hearings on October 25th and November 8th. Also, these materials are not a substitute for the staff report. A separate staff report and agenda will be sent to you in the usual manner next week. It will contain some last minute staff recommended changes to the zoning ordinance (mostly housekeeping in nature). FNS /ckh Enclosures