HomeMy WebLinkAboutCOW 2024-12-09 Item 4B / 5B - Public Hearing - Ordinance Adopting 2024-2044 Comprehensive PlanITEM INFORMATION
STAFF SPONSOR: NANCY EKLUND ORIGINAL AGENDA DATE: 09/23/24
AGENDA ITEM TITLE PUBLIC HEARING – 2024-2044 Tukwila Comprehensive Plan Update (#3 of 3)
CATEGORY Discussion Motion Resolution Ordinance Bid Award Public Hearing Other
Mtg Date 11-18-24 Mtg Date 12 -16 -24 Mtg Date Mtg Date 12 -09-24 Mtg Date Mtg Date 11-18 -24 Mtg Date
SPONSOR Council Mayor Admin Svcs DCD Finance Fire P&R Police PW
SPONSOR’S
SUMMARY The City of Tukwila is completing the 2024-2044 Comprehensive Plan Periodic Update, as
required by the Washington Growth Management Act. The November 18, 2024, Public
Hearing is the second in 3 hearings on the draft Comprehensive Plan. This hearing will
focus on the Transportation Element, although the comment may be provided on the
overall Plan, as well. The Council is asked to consider comment and provide final direction.
The final hearing (12-09-24) will be followed by proposed adoption on 12-16-24.
REVIEWED BY Trans&Infrastructure Svcs Community Svcs/Safety Finance & Governance Planning & Community Dev.
LTAC Arts Comm. Parks Comm. Planning Comm.
DATE: COMMITTEE CHAIR:
RECOMMENDATIONS:
SPONSOR/ADMIN. Department of Community Development
COMMITTEE NA
COST IMPACT / FUND SOURCE
EXPENDITURE REQUIRED AMOUNT BUDGETED APPROPRIATION REQUIRED
$0 $ $ Fund Source:
Comments:
MTG. DATE RECORD OF COUNCIL ACTION
09/23/24 Public Hearing on Draft Comprehensive Plan
11/18/24 Public Hearing on Draft Comprehensive Plan
12/09/24
MTG. DATE ATTACHMENTS
12/09/24 Informational Memorandum dated 12-03-24
Attachment A - Response to Final Comments on Plan
Attachment C - Comprehensive Plan Elements for Public Hearing
Attachment D - Background Reports for Elements
Attachment B - Proposed Adopting Ordinance for Comprehensive Plan Periodic Update
C OUNCIL AGENDA S YNOPSIS
----------------------------------Initials --------------------------------- I TEM N O.
Meeting Date Prepared by Mayor’s review Council review
09/23/24 NE
11/18/24 NE
12/09/24 NE
4.B.
5.B.
17
18
City of Tukwila
Thomas McLeod, Mayor
INFORMATIONAL MEMORANDUM
TO: City Council
FROM: Nora Gierloff, AICP, Department of Community Development, Director
BY: Nancy Eklund, AICP, Long Range Planning Supervisor
Neil Tabor, AICP, Senior Planner
CC: Mayor McLeod
DATE: December 3, 2024
SUBJECT: PUBLIC HEARING, 12/9/24 – 2024-2044 Tukwila Comprehensive Plan
Update (#3 of 3)
ISSUE
The City of Tukwila is completing the 2024-2044 Comprehensive Plan Periodic Update, as
required by the Washington Growth Management Act (GMA) in RCW 36. 70A.1 30(l). The City
Council Public Hearing held on December 9, 2024, incorporates all agency comment, and public
and Council comment received at the two previous hearings on September 23, 2024, and
November 18, 2024.
Staff proposes that this draft Plan move forward for adoption at the December 16, 2024, Council
meeting.
BACKGROUND
The Washington Growth Management Act requires that Comprehensive Plans be updated
periodically. Tukwila’s last major review of the Plan occurred in 2015; the current update of the
Plan will address the 2024-2044 planning period.
The City must update its Comprehensive Plan no later than December 31, 2024. The Tukwila
Plan consists of several parts: the elements, which include a brief summary about the topic, plus
the goals and policies for that element and background reports, provided for some elements
(but not all) and which identify greater detail about the element, including an inventory and
known capacity and growth issues.
Implementation strategies for the Plan are relevant for Tukwila in documenting how the City
has undertaken the action to implement the Plan’s policies, but those will be presented to the
Council in early 2024. In 2029, the City will report back to regional and state agencies on the
City’s accomplishments in implementing its Plan.
DISCUSSION
As noted in the Information Memo for the September 23, 2024, Public Hearing, the City Council
has reviewed the Comprehensive Plan on several occasions over the past year.
As noted at the October 18, 2024 Council meeting, staff has requested review of the draft Plan
by the Washington Department of Commerce, the Puget Sound Regional Council, and the King 19
INFORMATIONAL MEMO
Page 2
County Affordable Housing Committee regarding their respective Growth Management Act
consistency analyses. Tukwila Staff have made the requisite updates to the Plan (see the matrix
of questions and responses in Attachment A, as well as the Plan drafts in Attachments B (Plan
Elements) and Attachment C (Plan Background Reports).
Following adoption of the Plan, staff will put the plan in final format, which will include addition of
maps, photographs, and other formatting that bring the document together. In addition, links to
referenced documents, and other items will be incorporated into the final draft (e.g., Title page,
Table of Contents, Acknowledgements, Land Acknowledgment, Glossary, Implementation
Strategies matrix, and Index).
Environmental Review
The proposed Amendments to the Comprehensive Plan have been reviewed relative to the
Washington State Environmental Policy Act (SEPA), and a Determination of Nonsignificance and
Addendum to the Tukwila Comprehensive Plan Environmental Impact Statement was filed with
the Washington Department of Ecology SEPA Register. Those files are available for review here:
https://apps.ecology.wa.gov/separ/Main/SEPA/Record.aspx?SEPANumber=202405256.
Adopting Ordinance and Final Council Actions
In anticipation of the Council’s final review and adoption of the 2024-2044 Comprehensive Plan
Period Update, also attached is a copy of the Proposed Adopting Ordinance for Council
Consideration (Attachment D). If Council has any questions or comments on the Ordinance,
please let staff know.
NEXT STEPS
•December 16, 2024 – Tukwila Comprehensive Plan Update: Deliberate and Adopt Plan (The
approved Comprehensive Plan will be put into a final format following adoption).
FINANCIAL IMPACT
N/A
RECOMMENDATION
At this third and final hearing, Council is asked to consider the draft Plan and the public input and
provide any final direction to the staff regarding the final Comprehensive Plan document. The
Council is asked at their December 16, 2024, meeting to adopt the Plan.
ATTACHMENTS
A.Response to Final Comments on Plan
B.Proposed Adopting Ordinance for Comprehensive Plan Periodic Update
C.Comprehensive Plan Elements for Public Hearing
D.Background Reports for Elements
20
Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 1 of 42
# Comment Response
WA Department of Commerce (11/19/24
letter)
Catherine McCoy
Senior Planner
Growth Management Services
Washington Department of Commerce
1 1) Land Use Element
a) The Land Use Element shall provide a consistent population
projection throughout the plan which should be consistent with
the jurisdiction’s allocation of countywide population and
housing needs. RCW 36.70A.115, RCW 43.62.035 and WAC
365-196-405(f)
The land use assumptions in the land use element form the
basis for all growth-related planning functions in the
comprehensive plan, including transportation, housing, and
capital facilities. In our review of the city’s draft
comprehensive plan we did not find consistent language in the
land use element or throughout the draft plan related to
population projections as required by the Growth Management
Act (GMA). To better align with statute we recommend a
distinct (‘front and center’) set of population projections in
your land use element, and for consistency, throughout other
elements in your plan particularly in the housing element, the
transportation element, and in the capital facilities element.
Commerce’s recently updated HAPT includes a way to
calculate consistent population projections associated with
housing targets that the city may use if desired. Based on your
adopted target and the HAPT calculation, the 2044 population
projection for Tukwila (based on a future housing need of
6,500 units) is 34,666. Contact Laura Hodgson for more
information or the actual file with this data. Or contact
Rebeccah Maskin at King County for population projection
support.
Housing Element and Land Use Element have been updated to include populatfon
projectfon in the introductory text.
36,000 estfmatfon is based on per household totals used with previous OFM reports, with
some smoothing to the nearest thousandth.
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1
Attachment A
Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 2 of 42
# Comment Response
2
b) Estimates of population densities and building intensities
based on future land uses and housing needs. RCW
36.70A.070(1) (amended in 2023), WAC 365-196-405(2)(i).
For cities required to plan under the Buildable Lands
Program, RCW 36.70A.215, amended in 2017, some
jurisdictions may need to identify reasonable measures to
reconcile inconsistencies. See Commerce’s Buildable Lands
Program page.
In our review, we did not find identification or assessment of
population densities and building intensities based on future
land uses and housing needs. We recommend including the
assumed densities used to calculate capacity in each zoning
category in your land capacity analysis documentation or
discussing these in the Land Use Element, per RCW
36.70A.070(1). Estimates should include assumed densities to
accommodate housing needs. (See WAC 365 -196-210(6), and
Housing Element Book 2: Step C and footnote 30 on page 26.)
Assumed densitfes used are consistent with the urban growth capacity report/buildable
lands process. Housing and employment capacity exceeds requirements for each of these
metrics.
3 c) Counties and cities must review drainage, flooding, and
stormwater runoff in the area or nearby jurisdictions and
provide guidance for corrective actions to mitigate or cleanse
those discharges that pollute waters of the state, including
Puget Sound or waters entering Puget Sound. Water quality
information may be integrated from the following sources:
In our review of the land use element we noticed that
mitigation measures were included in the environment
element, the shoreline element, and the utilities element,
however we did not find policy direction or specific discussion
provided to address impacts and corrective actions in the land
use element as required per RCW 36.70A.070(1) and WAC
365-196-405(2)(e). Please include a review of city drainage,
flooding and flood prone areas and stormwater run -off; provide
guidance in the land use element and, if applicable, reference
the additional information found in other elements of the plan.
Water quality information may be integrated from the
following sources:
Environmental policies reside in the Natural Environment element (and Background
Report), although new Land Use policy 2.4 directs the reader to that element for more
detailed descriptfon and policy language. The Plan proposes adoptfon by reference the
City’s functfonal plans (e.g., Stormwater, etc.) for more discussion of Stormwater issues
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Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 3 of 42
# Comment Response
• Planning and regulatory requirements of municipal
stormwater general permits issued by the Department of
Ecology that apply to the county or city.
• Local waters listed under Washington state's water quality
assessment and any water quality concerns associated with
those waters.
• Interjurisdictional plans, such as total maximum daily
loads.
4 d) The Land Use Element must provide identification of lands
useful for public purposes such as utility corridors,
transportation corridors, landfills, sewage treatment facilities,
storm water management facilities, recreation, schools and
other public uses. RCW 36.70A.150 and WAC 365-196-340
In our review of the land use element we did not find language
and/or mapping identifying lands useful for public purposes as
described above. We found reference only to the Parks,
Recreation, and Open Space element – lands useful for trails,
open space networks and additional parks and civic spaces. We
recommend adding policy language and/or maps consistent
with RCW 36.70A.150 and RCW 36.70A.160 to the land use
element or adding a reference within the land use element to
the element where this required provision is located in your
comprehensive plan.
At this tfme, the City of Tukwila has not identffied any lands needed for City purposes. The
City provides its commitment to work with the County and other jurisdictfons in any future
sitfng of essentfal public facilitfes in LU-Goal 6, and policies LU-6.1 and LU-6.2.
5 e) The Land Use Element must contain policies to designate
and protect critical areas including wetlands, fish and wildlife
habitat protection areas, frequently flooded areas, critical
aquifer recharge areas and geologically hazardous areas. In
developing these policies, the city must have included the best
available science (BAS) to protect the functions and values of
critical areas and give “special consideration” to conservation
or protection measures necessary to preserve or enhance
anadromous fisheries. RCW 36.70A.030(6), RCW 36.70A.172,
WAC 365-190-080. Best Available Science: see WAC 365-195-
900 through -925
In our review of the draft land use element we did not find
review assessment, or policy direction that would reflect the
city’s long-term approach to local and regional critical areas
These prioritfes are described in the Natural Environment Element, page 2, and policies
EN1.1, Goal EN-5, and EN5.1 (and policies 5.2- to 5.3), and policy EN-4.3.
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Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 4 of 42
# Comment Response
protection. We recommend adding policy considerations
pertaining to the protection and preservation of the city’s
critical areas to the land use element and, if applicable,
reference other plan elements in your comprehensive plan
where these required policies are located. Please see the
Critical Areas Handbook for additional guidance.
6 f) New section RCW 36.70A.142 (2022), HB 1799:
Development regulations newly developed, updated, or
amended after January 1, 2025, must allow for the siting of
organic materials (OM) management facilities as identified in
local solid waste management plans (SWMP) to meet OM
reduction and diversion goals. Siting must meet criteria
described in RCW 70A.205.040(3).
Our review did not find policies within the draft land use
element or comprehensive plan specific to the siting of organic
materials management. We recommend including policy
language to allow for future siting of organic waste materials
facilities in coordination with your solid waste management
providers/plans and King County, as required by the GMA.
New policy is provided in the Utflitfes Element :
Policy U-1.5 Allow for the future sitfng of organic waste materials facilitfes in
coordinatfon with the City’s Solid Waste provider and King County, consistent with RCW
70A205.040(3). Such facilitfes shall be considered “essentfal public facilitfes” and the City
shall engage with area jurisdictfons and agencies in the sitfng decision.
7 g) The land use element must reduce and mitigate the risk to
lives and property posed by wildfires by using land use
planning tools and through wildfire preparedness and fire
adaptation measures. RCW 36.70A.070(1) amended in 2023.
Our review did not find language pertaining to wildfire risk
and mitigation in the land use element. Commerce
recommends the addition of wildfire preparedness and fire
adaptation measures in the land use element with identification
of specific procedures as required by RCW 36.70A.070(1).
You may wish to reference the Wildland Urban Interface Code
(RCW 19.27.560), developed and adopted by the Washington
State Building Code Council, as an example of development
regulations intended to separate human development from
wildfire-prone landscapes to protect existing residential
development and infrastructure through community wildfire
preparedness and fire adaptation measures.
Added corresponding policy to Land Use element
LU 8.8: Consider potentfal wildfire risk preventfon measures in updates to development
standards.
Note: Tukwila is not considered a High Risk Community for Wildfire Hazards in King County.
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Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 5 of 42
# Comment Response
8 h) The city shall adopt a comprehensive plan and development
regulations that are consistent with and implement the
comprehensive plan, per RCW 36.70A.040(3).
Based on our review, the development standards with which to
implement the comprehensive plan elements, policies, and
goals are not yet available or are incomplete. Please provide a
draft of all associated development regulations and zoning
updates for the Tukwila Comprehensive Plan 2024 draft
comprehensive plan so that it may be reviewed for consistency
with the Growth Management Act (GMA). RCW 36.70A.106
No development regulatfon updates are proposed with this periodic update.
Legislatfve updates will be adopted within 6 months of the periodic update of the
comprehensive plan will be incorporated to be consistent with state law. Updates related
to SB 5290, required by the end of 2024, have already been adopted.
9 2) Housing Element
a) The Housing Element must include an inventory and
analysis of existing and projected housing needs over the
planning period, by income band, consistent with the
jurisdiction’s share of countywide housing need, as provided by
Commerce. RCW 36.70A.070(2)(a) amended in 2021, WAC
365-196-410(2)(b) and (c)
In our review, we did not find a projection of emergency
housing and shelter needs included with the housing
projections in the draft Housing Element or Housing Element
Background Report. We recommend including the city’s
allocated emergency housing needs in the Housing Element, as
required by RCW 36.70A.070(2)(a). Additionally, we
recommend providing a table or other documentation of local
allocation of housing needs by income bracket. For additional
guidance, see Housing Element Book 1, see #6 of “minimum
standards for identifying and allocation projected housing
needs” on page 60.
Emergency Housing needs are addressed both in the Housing Element (policies 2.4 and 2.5)
and in the Housing Background Report (pages 32 and 42-43).
The target number cited (1,242) is consistent with the adopted Countywide Planning
Policies.
10 b) The Housing Element must include identification of capacity
of land for housing including, but not limited to, government-
assisted housing, housing for moderate, low, very low, and
extremely low-income households, manufactured housing,
multifamily housing, group homes, foster care facilities,
emergency housing, emergency shelters and permanent
supportive housing. RCW 36.70A.070(2)(c) amended in 2021,
WAC 365-196-410(e) and (f)
It is recognized that emergency housing capacity is not compliant with Tukwila’s adopted
targets and changes to development regulatfons related to emergency housing allowances
per site and buffering between sites need to be updated in the future
It will be necessary for the Council to adopt emergency housing regulatfons consistent with
requirements following the update of the Comprehensive Plan update.
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5
Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 6 of 42
# Comment Response
The city identified that current zoning does not allow sufficient
capacity to accommodate emergency housing needs. Updates
to development regulations that create sufficient capacity for
emergency housing should help the city achieve this
requirement. We strongly recommend documenting any
planned updates to create sufficient capacity for the allocated
emergency housing target of 1,242 beds. Guidance on updating
development regulations for emergency housing and shelter
can be found in the STEP Model Ordinance and User Guide.
See Chapter 6 for model ordinance language and Chapter 7 for
demonstrating sufficient land capacity for emergency housing
targets.
Additionally, we recommend providing an updated statement
or discussion indicating there is sufficient capacity of land for
all income housing needs, including emergency housing.
Include a table showing the breakdown of capacity in zones
that add up to housing needs for all income levels, including
emergency housing. Supporting documentation of land
capacity analysis is encouraged. Housing Element Book 2, see
bottom table of Exhibit 17 on page 40 and Exhibit 20 on page
48.
All limitations on supportive housing types such as emergency
housing (EH), emergency shelters (ES), permanent supportive
housing (PSH), and transitional housing (TH) must allow the
siting of a sufficient number of units and beds necessary to
meet project needs. Housing Element Book 2, see pages 41-48.
Additionally, the zoning map must be consistent with and
implement the land use map and land capacity findings. RCW
36.70A.115(1), WAC 365-196-800.
Figures 36 and 40 in the Housing Background Report detail capacity by AMI level, detailed
out by segment.
11 c) The Housing Element must include adequate provisions for
existing and projected housing needs for all economic
segments of the community, including documenting barriers
and actions needed to achieve housing availability. RCW
36.70A.070(2)(d) amended in 2021, WAC 365-196-010(g)(ii),
WAC 365-196-300(f), WAC 365-196-410 and see Commerce’s
Housing Action Plan (HAP) guidance: Guidance for
Developing a Housing Action Plan.
Appendix B adequate provisions checklist has been completed and is available as a link
within the housing element
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Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 7 of 42
# Comment Response
We recommend including key findings from the Gap Analysis
in the Housing Element and refer to Housing Background
Report for more details. Include a list of barriers to affordable
housing needs, including barriers to emergency housing and
permanent supportive housing, Housing Element Book 2, see
page 50 and Appendix B.
Include a list of actions needed to remove barriers to affordable
housing, Housing Element Book 2, see page 61 and Appendix
B. Note: identification of barriers to affordable housing and
actions to remove barriers do not need to be in table format,
but both items need to be present in the housing element.
12 d) Identify local policies and regulations that result in racially
disparate impacts, displacement, and exclusion in housing,
including:
Zoning that may have a discriminatory effect;
Disinvestment; and
Infrastructure availability
RCW 36.70A.070(e) new in 2021
While the materials in the city’s Housing Background Report
fulfill this requirement, we recommend including key findings
from the Racially Disparate Impacts Analysis in the Housing
Element and referencing the Housing Background Report for
more details. This could be in a statement of whether data
shows if there are disparate impacts. Note: Commerce
recommends using a variety of data available for all
jurisdictions as provided on our Ezview site and in Housing
Element Book 3, pages 33-36.
Page 34-35 of the housing background report has extensive discussion of racially disparate
impacts relatfng to zoning, divestment and infrastructure availability.
13 3)Transportation Element
a) The Transportation Element must include a forecast of
multimodal transportation for a minimum of 10 years
including land use assumptions used in estimating travel. RCW
36.70A.070(6)(a)(i) and (a)(iii)(E) amended in 2023, WAC
365-196-430(2)(f)
Forecasts and project identfficatfon/prioritfzatfon sectfons have been added/completed in
the background report. All forecastfng includes all modes of transportatfon and land use
and job assumptfons are consistent throughout all Elements.
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Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 8 of 42
# Comment Response
In our review we did not see that the city’s forecast includes
multimodal transportation for a minimum of 10 years. The
forecasting needs to include automobiles, as well as pedestrian,
bicycle and transit systems. Also, please ensure that the city’s
land use assumptions are accurate and consistent throughout
the comprehensive plan.
14 b) A multi-year financing plan based on needs must be
identified in the transportation element of the comprehensive
plan, the appropriate parts of which serve as the basis for the
6-year street, road or transit program. RCW
36.70A.070(6)(a)(iv)(B) and RCW 35.77.010, WAC 365-196-
430(2)(k)(ii)
In our review we did not find a detailed multi-year financing
plan based on needs identified in the comprehensive plan.
Please provide this prior to adoption of the comprehensive
plan. If this is located in a separate document then please
provide a reference in the transportation element.
Financing sectfon has been added to the Background Report, including a multf-year
financing plan.
15 c) A transition plan for transportation as required in Title II of
ADA. Perform self-evaluations of current facilities and develop
a program access plan to address deficiencies and achieve the
identification of physical obstacles, establish methods, perform
modifications and identify leadership roles. RCW
36.70A.070(6)(a)(iii)(G).
Transportation element updates associated with HB 1181 are
not required until the 5 year implementation progress report for
2024 jurisdictions (RCW 36.70A.130(9) and (10)). However, it
is advisable that jurisdictions begin this planning process as
early as possible. ADA transition plans are an important
component of a multimodal transportation system.
A draft ADA Transitfon Plan was developed in ~2016. Implementatfon Strategies include an
update to the ADA Transitfon Plan.
A complete ADA Transitfon Plan is required to be in place within 5 years.
16 Zoning Code
a) Zoning designations must be consistent and implement land
use designations that accommodate future housing needs by
income bracket as allocated through the countywide planning
process. (RCW 36.70A.070(2)(c) - Amended in 2021 with HB
1220).
Pending updates to STEP regulations.
It is recognized that emergency housing capacity is not compliant with Tukwila’s adopted
targets and changes to development regulatfons related to emergency housing allowances
per site and buffering between sites need to be updated in the future.
Emergency housing regulatfons will be updated following the adoptfon of the
Comprehensive Plan Periodic Update.
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Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 9 of 42
# Comment Response
17 b) Permanent supportive housing or transitional housing must
be allowed where residences and hotels are allowed. RCW
35A.21.430 amended in 2021, RCW 35.21.683, amended in
2021, (HB 1220 sections 3-5). “Permanent supportive
housing” and “transitional housing” is defined in RCW
36.70A.030; “transitional housing” is defined in RCW
84.36.043(3)(c).
Permanent supportive and transitional housing are allowed in
the appropriate zones. However, spacing and occupancy
restrictions are inconsistent with RCW 35A.21.430, as they are
not based on a demonstrated need to address public health and
safety. Please see the STEP Model Ordinance and User Guide
for additional guidance.
Any limitations on permanent supportive housing and
transitional housing must be connected to public health and
safety and allow the siting of a sufficient number of units and
beds necessary to meet projected needs. Housing Element
Book 2, see pages 41-48.
It is recognized that PSH and transitfonal housing regulatfons are not compliant due to
various limitatfons that do not provide justfficatfon of why they are required.
The PSH and transitfonal housing regulatfons will be updated following the adoptfon of the
Plan’s periodic update.
18 c) Indoor emergency shelters and indoor emergency housing
must be allowed in any zones in which hotels are allowed,
except in cities that have adopted an ordinance authorizing
indoor emergency shelters and indoor emergency housing in a
majority of zones within one-mile of transit. Indoor emergency
housing must be allowed in areas with hotels. RCW
35A.21.430 amended in 2021, RCW 35.21.683, amended in
2021, (HB 1220 sections 3-5)
Emergency housing and shelter are allowed in the appropriate
zones, but, as identified in the LCA, current spacing,
occupancy, and intensity restrictions prevent siting of sufficient
number of units to meet allocated needs. Any spacing
restrictions should be connected to public health and safety.
Please update these regulations, to be consistent with RCW
35A.21.430. Please see the STEP Model Ordinance and User
Guide for additional guidance (links provided above).
It is recognized that emergency housing capacity is not compliant with Tukwila’s adopted
targets and changes to development regulatfons related to emergency housing allowances
per site and buffering between sites need to be updated in the future.
The emergency housing regulatfons will be updated following the adoptfon of the periodic
Plan’s adoptfon.
19 As a friendly reminder, please submit all comprehensive plan
updates and development regulation updates to Commerce for
So noted.
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Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 10 of 42
# Comment Response
60-day review prior to adoption, and submit all adopted plans
within ten days after final adoption (RCW 36.70A.106(2))
Puget Sound Regional Council (8/28/24
letter)
Maggie Moore
Growth Management
Puget Sound Regional Council
1 Housing
Plan Review Consistency Tool
Increase housing supply and densities to meet the
region’s current and projected needs at all income
levels consistent with the Regional Growth
Strategy (MPP-H-1)
PSRC Comment on Draft Tukwila Plan
The Tukwila Housing Background Report indicates
the city currently lacks sufficient capacity for its
allocation of housing affordable to all income
levels. The report indicates the periodic update will
remedy this gap – following through to provide
sufficient capacity will be important in finalizing
the plan update. RCW 36.70A.070(2)(c) states
jurisdictions must ensure sufficient capacity for all
housing types, including emergency housing and
emergency shelter, are identified in the housing
element.
The city should show capacity for housing
affordable to all income levels, including
Capacity totals for all non-emergency housing have been updated using Department of
Commerce recommended methodology to demonstrate adequate capacity.
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Tukwila Comprehensive Plan
Agency and Other Comments/Requests/Responses (November/December 2024)
Page 11 of 42
# Comment Response
emergency housing capacity. Commerce’s STEP
guidance provides further information.
2 Plan Review Consistency Tool
Identify potential physical, economic, and cultural
displacement of low-income households and
marginalized populations and work with
communities to develop anti-displacement
strategies in when planning for growth (MPP-H-12,
H-Action-6)
PSRC Comment on Draft Tukwila Plan
The city is commended for including an analysis
on racially disparate impacts.
The city should work to identffy more specific policies to
address residentfal displacement.
Housing Element policies addressing residentfal displacement include:
• H2.7: Work with the owners and managers of Tukwila’s new and existing
permanent or long-term low-income housing to maximize housing desirability,
protect long-term affordability, and strengthen community connections.
• H2.8: Strive to make alternatfve and affordable housing optfons available for
residents currently living in substandard housing, such as pre-HUD code mobile
homes.
• H3.3: Play an actfve role in regional efforts to meet the needs of low-income
community members, including monitoring of housing needs and updatfng city
policies and regulatfons to align with regional goals.
• H3.4: Contfnue to work closely with South King Housing and Homelessness
Partnership (SKHHP) and other partners to achieve development of subsidized
affordable housing for very low-, low- and moderate-income households.
• H4.2: Develop and implement strategies to reduce displacement of low-income
households in areas of redevelopment.
• H4.3: Evaluate City actfons for potentfal to increase displacement risk for naturally
occurring affordable housing and vulnerable communitfes and mitfgate or avoid
taking actfons that significantly increase this risk.
• H4.4: Support the long-term preservatfon of existfng naturally occurring affordable
housing developments by actfng as a facilitator between affordable housing groups
interested in purchasing units and property owners.
• H4.6: Contfnue to support the maintenance, weatherizatfon, rehabilitatfon, and
long-term preservatfon or replacement of existfng housing for low- and moderate-
income residents.
• H4.9: Adopt renter protectfons to ensure stable housing for Tukwila Renters.
Implementatfon strategies associated with the housing element listed below more directly
address mitfgatfng residentfal displacement:
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• Collaborate between City Staff, SKHHP and other community groups to
disseminate affordable housing opportunitfes with new income restricted housing
development.
• Explore opportunitfes to support the development of additfonal income-restricted
housing, or transitfon of naturally occurring affordable housing (NOAH) into
income-restricted housing, including but not limited to density bonuses for
affordable housing, expansion of 12-year MFTE availability, fee reductfons and
other standard flexibility for preservatfon of existfng NOAH units and infill
redevelopment.
• Review mapping of areas with greatest risk of displacement and staff knowledge
when considering zoning or other City actfons with significant potentfal to impact
displacement and consider attemptfng to offset the actfon through mitfgatfng
measures, phasing actfons with other affordable housing development or
reconsidering actfons altogether.
• Coordinate between City Staff and SKHHP to connect agencies purchasing and
managing affordable housing with interested Tukwila property owners.
• Contfnue to engage historically underserved populatfons with greater risk of
displacement through both informal means of outreach, as well as representatfon
on citfzen boards and commissions.
• Contfnue to seek partnerships with organizatfons developing affordable
homeownership project, while amending residentfal development standards to
expand viability of ownership housing types at lower price points through code
amendments and partnering with organizatfons such as the Black Home Initfatfve
to direct homeownership covenant funds and other resources toward ownership
opportunitfes in Tukwila.
• Coordinate City programming and promotfon related to rental assistance, job
training and advocacy with transit organizatfons in an effort to provide housing
access, while supportfng constructfon of new housing affordable to lower income
levels.
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3 Development Patterns, Environment & Climate
Change
Plan Review Consistency Tool
Address rising sea water by siting and planning for
relocation of hazardous industries and essential
public services away from the 500-year floodplain
(MPP-CC-10)
PSRC Comment on Draft Tukwila Plan
Because of flood risk, the plan should include a
map of the area identifying forecasted sea level
rise. The Puget Sound Hazards map provides
information for individual jurisdictions.
Addressed in the Climate Change sectfon of the Natural Environment element (p. EN-7).
In the sitfng of Essentfal Public Facilitfes, climate change issues (e.g., sea level rise) will be
considered, Per Policy LU 6.2
4 Plan Review Consistency Tool
Preserve historic, visual, and cultural resources
and consider potential impacts to culturally
significant sites and tribal treaty fishing, hunting,
and gathering grounds (MPP-DP-5-7)
PSRC Comment on Draft Tukwila Plan
The city should describe and include policies on
tribal treaty rights. PSRC’s Coordination with Tribes
resource provides more information on this topic
Two policies were added:
Policy LU 8.7 Consider the potentfal impacts of development to culturally significant sites
and tribal treaty fishing, huntfng, and gathering grounds.
Policy CC-4.6 Coordinate with tribes in regional and local planning, recognizing the
mutual benefits and potentfal for impacts between growth occurring within and outside
tribal boundaries.
In additfon, text relatfng to SHB1717 was added to the Introduction (p. 8-9) to address the
City’s outreach to Tukwila’s two tribal natfons.
Already in text:
CC-1.4.2 Consult the Duwamish Tribe on any signage reflectfng the City's past and
including the Lushootseed language. The Lushootseed language expresses placenames
that not only name the area but describe it.
CC-1.6.2 When considering adding public art to the City, among others, invite the
Duwamish Tribe to partfcipate in and design art for the City.
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EN-1.3 Collaborate with federal, state, and tribal fish and wildlife agencies to
identffy priority habitats and species, to establish appropriate protectfons to ensure no net
loss of ecological functfons and values.
5 Plan Review Consistency Tool
Identify open space, trail, and park resources and
needs, and develop programs for protecting and
enhancing these areas (MPP-En-11-12, En-15, En-
Action-4)
PSRC Comment on Draft Tukwila Plan
The city is commended for including a policy and
parks level-of-service to provide parks within ¼
and ½ of all residents. PSRC uses the Trust for
Public Land’s ParkServe mapping tool to identify
park gaps. ParkServe shows that today, 82% of
Tukwila’s residents live within a 10-minute walk of a
park
Noted
6
Regional Centers
PSRC will do an in-depth review of regional centers
in 2025 following comprehensive plan updates.
Existing regional growth centers are expected to
meet the standards identified in the Regional
Centers Framework to ensure redesignation. All
work needs to be submitted to PSRC by May 30,
2025, to be considered in the redesignation
process. Since Tukwila does not currently have a
certified plan for the regional growth center,
certification will be needed based on consistency
with regional criteria shown in the Centers Plans
Checklist.
Noted.
Staff will be taking steps shortly after the adoptfon of the periodic update to ensure
regulatfons support density and growth required in regional centers, such as removing
residentfal uses with densitfes that would not support the required actfvity units per acre.
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# Comment Response
Plan Review Consistency Tool
Jurisdictions with regional centers: Support the
update of regional center subarea plans to be
consistent with the revised Center Plan Tools (DP-
Action-8)
PSRC Regional Centers Framework (2018)
PSRC Centers Profiles Data
PSRC Comment on Draft Tukwila Plan
As the city updates the land use element, growth
targets for population and employment should be
included for the regional growth center and
manufacturing/industrial center.
For urban growth centers, targets should be for at
least 45 activity units/acre and represent a
portion of the city’s 2044 population and
employment targets.
For industrial employment centers, there should
be a minimum of 20,000 planned jobs,
representing a portion of the city’s 2044
employment target.
Additionally, industrial employment centers should
have at least 10,000 existing jobs, and North
Tukwila has less than 9,000 (2023).
Manufacturing/industrial centers that have
existing employment levels below the level
required for new regional centers must complete
a market study by May 2025 to evaluate the
potential for and opportunities to best support
center growth. The market study should show how
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# Comment Response
the center can meet targeted levels of growth
within the planning period. The jurisdiction should
demonstrate its work to address opportunities
identified in the market study.
Puget Sound Regional Council (11/6/24
letter) – Transportation Element
Liz Underwood-Bultmann
Growth Management
Puget Sound Regional Council
7
Transportation
Plan Review Consistency Tool
Provide travel demand forecasts and identify
state and local system projects, programs,
and management necessary to meet current
and future demands and to improve safety
and human health (RCW 36.70A.070, MPP-T-
4-5)
Identify maintenance and system
preservation projects and programs
necessary to maintain the ability of the
transportation system to provide safe,
efficient, and reliable movement of people,
goods, and services (RCW 36.70A.070, MPP-T-
1-2, T-4)
PSRC Comment on Draft Tukwila Plan
Travel demand forecasts, safety improvements and projects to meet
demands are now included in the background report.
Major maintenance and preservation projects and programs are included
in the identified project list now included in the background report.
All forecasting includes all modes of transportation and land use and job
assumptions are consistent throughout all Elements. Projections have
been confirmed with PSRC staff that they meet the adopted growth
targets for Tukwila.
Project projections to 2044 are included and a complete list of projects
needed is now in the Background Report. A draft ADA Transition Plan was
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# Comment Response
The travel demand forecast must be
consistent with the adopted growth targets
and with land use assumptions used
throughout the plan. Tukwila has an adopted
growth target of 6,500 housing units and
15,890 jobs through 2044. The Transportation
Background Report (p. 104) indicates that
travel demand modeling was based on
growth assumptions of 6,044 households and
11,875 jobs through 2044. The final plan should
clearly demonstrate consistency with the
adopted growth targets, and all elements and
background reports should be internally
consistent. Information on these requirements
is provided in Commerce’s Transportation
Guidebook.
The city must identify projects and programs,
including roadway projects, non-motorized
projects, ADA improvements and system
maintenance, necessary to meet
transportation demands for at least a ten-
year planning period. The city is encouraged
to provide a complete project list through
2044. Information on these requirements is
provided in Commerce’s Transportation
Guidebook and PSRC’s Transportation
Element Guidance.
developed in ~2016 and a new Implementation Strategy to update to the
ADA Transition Plan is included.
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8 Plan Review Consistency Tool
Include a 20-year financing plan, as well as
an analysis of funding capability for all
transportation modes (RCW 36.70A.070(3),
RCW 36.70A.070(6)(a)(iv), WAC 365-196-415,
WAC 365-196-430, MPP-RC-11-12, T-6, T-15)
PSRC Comment on Draft Tukwila Plan
The Transportation element should include a
complete financing plan and analysis of
funding through the 20-year planning period,
including maintenance and other
programmatic costs. The financing plan
should include projected revenue sources
that may include reasonably expected, a
comparison to expected project costs,
identification of potential additional sources
to cover any identified funding gaps, and a
reassessment strategy should funding fall
short. For more information, see WAC 365-
196-430, and the Commerce’s Transportation
Guidebook (chapter 4I) and Capital Facilities
Planning Guidebook.
Financing section has been added to the Background Report, including a
multi-year financing plan.
King County Affordable Housing
Committee (10/3/24 letter)
Claudia Balducci
Affordable Housing Committee Chair
King County Councilmember, District 6
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# Comment Response
Carson Hartmann
King County
1 1. Plan for and accommodate housing needs (CPP H-1)
Relevant Countywide Planning Policies
CPP H-1 requires Tukwila plan for and accommodate its
allocated share of countywide future housing needs for
moderate-, low-, very low-, and extremely low-income
households as well as emergency housing, emergency
shelters, and permanent supportfve housing.
Tukwila’s Proposal and AHC Findings
Policy H2.2 states that Tukwila will “encourage housing
development to all income segments sufficient to meet needs
consistent with adopted targets.” However, CPP H-1 requires
that jurisdictfons plan for and accommodate allocated housing
needs for moderate-, low-, very low-, and extremely low-
income households, as well as emergency housing, emergency
shelters, and permanent supportfve housing needs.
Recommendatfon 1: To align with CPP H-1, Tukwila should also
commit to planning for and accommodatfng moderate-, low-,
very low-, and extremely low-income housing needs, not just
growth targets, as well as emergency housing, emergency
shelters, and permanent supportfve housing needs in Policy
H2.2.
Capacity totals are consistent with required targets across income levels. It is recognized
that emergency housing capacity is not compliant with Tukwila’s adopted targets and
changes to development regulatfons related to emergency housing allowances per site and
buffering between sites need to be updated in the future.
Staff will initfate the process to update emergency housing regulatfons following the Plan’s
adoptfon.
2 2. Identify sufficient capacity of land for emergency housing
needs (CPPs H-1 and H-11)
Relevant Countywide Planning Policies
CPP H-1 requires Tukwila plan for and accommodate 1,748 net
new housing units, including 1,242 emergency housing beds.
CPP H-11 requires jurisdictfons identffy sufficient capacity of
land for emergency housing.
Tukwila’s Proposal and AHC Findings
The draft plan’s Housing Background Report identffies that
Tukwila lacks adequate capacity to accommodate its target of
emergency shelter and emergency housing. It also identffies
It is recognized that emergency housing capacity is not compliant with Tukwila’s adopted
targets and changes to development regulatfons related to emergency housing allowances
per site and buffering between sites need to be updated in the future.
Staff will initfate the process to update emergency housing regulatfons following the Plan’s
adoptfon.
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# Comment Response
intensity of use and spacing requirements that serve as
barriers to the development of emergency housing facilitfes
(page 39). Policies and associated implementatfon strategies
in the draft plan address this gap, including a commitment in
implementatfon strategy H2.(4.5).1 to “review and amend
regulatfons and fees for emergency shelters, transitfonal
housing, emergency housing, and permanent supportfve
housing (STEP Housing) through code amendments and to
ensure capacity and feasibility of STEP Housing development.”
However, Tukwila did not include an emergency housing
capacity analysis. Without this analysis, the AHC cannot
determine if Tukwila is planning for and accommodatfng its
emergency housing need and has sufficient land capacity to
accommodate its emergency housing need allocatfon, as
required by CPP H-11.
Recommendatfon 2: To align with CPPs H-1 and H-11, Tukwila
should show sufficient land capacity for its allocated
emergency housing needs. Tukwila should follow Washington
State Department of Commerce’s guidance for completfng an
emergency housing land capacity analysis.
3 3. Prioritize extremely low-income households (CPP H-2)
Relevant Countywide Planning Policies
CPP H-1 requires that Tukwila plan for and accommodate
1,367 units affordable to households below 30 percent of area
median income (AMI). CPP H-2 requires Tukwila to prioritfze
the need for housing affordable to households less than or
equal to 30 percent AMI (extremely low-income).
Tukwila’s Proposal and AHC Findings
The draft plan demonstrates sufficient capacity for 0 to 30
percent of AMI housing needs. However, the AHC is concerned
that policies and implementatfon strategies in the draft plan
do not prioritfze 0 to 30 percent of AMI housing needs.
Specifically, Tukwila indicates that Housing Element policy
H2.1 and H2.2 and implementatfon strategy H2.(1-3).1 address
CPP H-2. Policy H2.1 states that Tukwila will encourage
Capacity totals are consistent with required targets across income levels. Updates were
made to the initfal submittal to King County based on Department of Commerce guidance.
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# Comment Response
productfon in all neighborhoods of diverse housing types that
are appropriate for residents in all stages of life and all
household sizes. H2.1. states that Tukwila will encourage
development affordable to all income segments sufficient to
meet needs consistent with adopted targets. Neither of these
policies names housing affordable to 0 to 30 percent of AMI
households or demonstrates a clear prioritfzatfon of extremely
low-income households. Implementatfon strategy H2.(1-3).1,
which commits Tukwila to amend its residentfal development
standards to incentfvize broader diversity of housing types,
increase incentfves for affordable housing, and reduce
regulatfons that increase housing development cost, also does
not mentfon extremely low-income households.
Recommendatfon 3: To align with CPP H-2, Tukwila should
explicitly prioritfze the housing needs of extremely low-
income households in plan policies and implementatfon
strategies. For examples of strategies Tukwila could use to
align with CPP H-2, see the CPP Housing Chapter Technical
Appendix.
4 4. Complete the housing inventory and analysis (CPP H-3)
Relevant Countywide Planning Policies
CPP H-3 directs jurisdictfons to conduct a housing inventory
and analysis to help identffy and address the greatest needs as
well as summarize the findings in the Housing Element.
Tukwila’s Proposal and AHC Findings
While Tukwila’s submission includes many data points and
substantfve analysis, the AHC could not find specific
informatfon required by CPPs H-3(b), (g), (m). This includes:
b. the number of existfng housing units by conditfon;
g. populatfon age by race/ethnicity; and
m. the housing needs of communitfes experiencing
disproportfonate harm of housing inequitfes including Black,
Indigenous, and People of Color.
This analysis should inform additfonal comprehensive plan
policy responses and strategies. For example, analysis
responsive to CPP H-3(m) could help Tukwila further identffy
Demographic and housing related data points, including by race can be found in Sectfon 2 –
“Community Profile” of the housing background report.
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and address gaps in existfng partnerships, policies, and
dedicated resources for eliminatfng racial and other disparitfes
in access to housing and neighborhoods of choice, as required
by CPP H-4 and H-20.
Recommendatfon 4: Tukwila should include all inventory and
analysis components as required by CPP H-3 and summarize
the findings in the Housing Element. This additfonal analysis
should inform additfonal comprehensive plan policy responses
and strategies.
5 5. Identify and address gaps in policies to meet the
jurisdiction’s housing needs (CPPs H-4, H-12, and H-13)
Relevant Countywide Planning Policies
CPP H-4 requires jurisdictfons to evaluate the effectfveness of
existfng housing policies and strategies to meet the
jurisdictfon’s housing needs and identffy gaps in existfng
partnerships, policies, and dedicated resources for meetfng
housing needs. CPP H-12 requires jurisdictfons to adopt and
implement policies that improve the effectfveness of existfng
housing policies and strategies and address gaps in
partnerships, policies, and dedicated resources to meet the
jurisdictfon’s housing needs. CPP H-13 requires jurisdictfons to
implement strategies to overcome cost barriers to housing
affordability.
Tukwila’s Proposal and AHC Findings
Tukwila’s draft Housing Background Report discusses barriers
to housing development, specifically housing affordable to
incomes below 80 percent of AMI (pp. 36-37). The report also
proposes strategies to enable greater affordable housing
productfon, including reducing restrictfve development
requirements, streamlining development and design review
processes, and providing incentfves for affordable housing
development (pp.37-38).
However, this discussion does not outline specific gaps in
policy effectfveness, existfng partnerships, and dedicated
resources, nor specific cost barriers to housing affordability to
which outlined strategies are meant to respond. The draft plan
The adequate provisions checklist has been completed and is linked at the end of the
housing element.
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also does not commit the City to implementfng any strategies
identffied in the Housing Background Report. Instead, the
draft plan generally proposes to “identffy and remove
excessive regulatory barriers to housing productfon” (Policy
H1.2), “modify residentfal zoning designatfons and
development standard to align with city goals” (Policy H1.3)
and “pursue establishing, or expanding, programs to provide
tax incentfves for increased housing development” (Policy
H3.2). Therefore, the AHC finds that the draft plan does not
meaningfully:
• evaluate the effectfveness of existfng housing policies and
strategies to meet the jurisdictfon’s housing needs and
identffy gaps in existfng partnerships, policies, and dedicated
resources to meet housing needs, as required by CPP H-4;
• adopt and implement policies that improve the effectfveness
of existfng housing policies and strategies and address gaps in
existfng partnerships, policies, and dedicated resources for
meetfng the jurisdictfon’s housing needs, as required by CPP
H-12; and
• implement strategies to overcome cost barriers to housing
affordability, as required by CPP H-13.
Recommendatfon 5: To align with CPP H-4, Tukwila should
include an analysis that identffies specific gaps in the
effectfveness of existfng housing policies and strategies to
meet the jurisdictfon’s housing needs and identffy gaps in
existfng partnerships, policies, and dedicated resources for
meetfng housing needs.
This analysis should inform draft policies and implementatfon
strategies that address CPPs H-12 and H-13. Tukwila should
commit to addressing specific gaps in adopted policies and
implementatfon strategies. Tukwila may provide updated
implementatfon strategies to the AHC in 2025.
Please see the Washington State Department of Commerce’s
“Adequate Provisions Checklists” as a guide for how Tukwila
could conduct a gap analysis and address gaps in policies and
strategies.
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6 6. Prioritize the use of local and regional resources for
income-restricted housing (CPP H-14)
Relevant Countywide Planning Policies
CPP H-14 requires jurisdictfons prioritfze the use of local and
regional resources (e.g. funding, surplus property) for income -
restricted housing, partfcularly extremely low-income
households, populatfons with special needs, and others with
disproportfonately greater housing needs.
Tukwila’s Proposal and AHC Findings
Tukwila indicated in their submitted completeness checklist
and implementatfon strategies that draft policy H2.2 and
implementatfon strategy H2.(1-3).1 address the requirements
of CPP H-14. Draft policy H2.2. states that the City will
“encourage housing development affordable to all income
segments sufficient to meet needs consistent with adopted
targets.” Implementatfon strategy H2.(1-3).1 commits Tukwila
to amend its residentfal development standards to incentfvize
broader diversity of housing types, increase incentfves for
affordable housing, and reduce regulatfons that increase
housing development cost.
Neither the policy nor implementatfon strategy demonstrates
an intentfon to prioritfze local or regional resources, such as
funding or surplus public land, for income-restricted housing.
Policy H2.2 and implementatfon strategy H2.(1-3).1 also do
not mentfon regional or local resources or refer to extremely
low-income households, populatfons with special needs, or
other groups with disproportfonately greater housing needs.
Recommendatfon 6: To align with CPP H-14, Tukwila should
include a policy and implementatfon strategy that commits
Tukwila to prioritfzing available resources for income-
restricted housing (e.g. funding, surplus property), partfcularly
extremely low-income households, populatfons with special
needs, and others with disproportfonately greater housing
needs. For strategies to align with CPP H-14, see the CPP
Housing Chapter Technical Appendix
Housing Element policies listed below address allocatfng local funds, resources or
incentfves to support affordable housing:
• H3.2: Pursue establishing, or expanding, programs to provide tax incentfves for
increased housing development.
• H3.4: Contfnue to work closely with South King Housing and Homelessness
Partnership (SKHHP) and other partners to achieve development of subsidized
affordable housing for very low-, low- and moderate-income households.
• H4.6: Contfnue to support the maintenance, weatherizatfon, rehabilitatfon, and
long-term preservatfon or replacement of existfng housing for low- and moderate-
income residents.
• H4.8: Support programs and City actfons that increase homeownership
opportunitfes for vulnerable populatfons.
• H4.9: Adopt renter protectfons to ensure stable housing for Tukwila Renters.
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7 7. Expand and support the supply of income-restricted
housing near high-capacity and frequent transit while
mitigating displacement (CPPs H-16, H-17, H-21, and H-23)
Relevant Countywide Planning Policies
CPP H-16 requires jurisdictfons to expand the supply and
range of housing types, including affordable units, at densitfes
sufficient to maximize the benefits of transit investments
throughout the county. CPP H-17 requires jurisdictfons to
support development and preservatfon of income-restricted
affordable housing near high-capacity transit. CPP H-21
requires that jurisdictfons adopt policies and strategies that
promote equitable development and mitfgate displacement
risk; mitfgate displacement that may result from planning
efforts, large-scale private investment, and market pressure;
and implement antf-displacement policies prior to or
concurrent with development capacity increases and public
capital investments. CPP H-23 requires that jurisdictfons adopt
and implement policies that protect housing stability for
renter households and expand protectfons and supports for
moderate-, low-, very low-, and extremely low-income renters
and renters with disabilitfes.
Tukwila’s Proposal and AHC Findings
Tukwila’s draft plan’s future land use map (FLUM) proposes
both “High Density Residentfal” and “Regional Commercial
Center” zones—both of which allow for housing types
typically affordable to households below 80 percent of AMI—
in close proximity to the Tukwila Internatfonal Boulevard Link
light rail statfon. The FLUM also proposes maintaining high-
density residentfal districts along frequent and high-capacity
transit routes, include Metro’s RapidRide. The draft plan
designates the zone in immediate proximity to the city’s
Sounder statfon as a “Tukwila Urban Center – Transit Oriented
Development” zone which contains a substantfal portfon of
the city’s total capacity for housing types typically affordable
to households earning less than or equal to 80 percent of AMI.
It is recognized that additfonal density increases are needed near the Tukwila Internatfonal
Boulevard Light Rail Statfon, and that this area is also the most a risk for displacement of
lower-income and BIPOC populatfons.
Staff antfcipates contfnuing previously unfinished subarea planning around the TIB statfon
in the second half of 2025. This will include proposals increase density allowances and
incorporate antf-displacement measures for existfng NOAH and lower-income renters.
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The AHC commends these efforts to orient future housing
development around frequent and high-capacity transit;
however, the AHC finds that proposed plan does not
meaningfully expand the supply and range of housing types,
including affordable units, at densitfes sufficient to maximize
the benefits of these transit investments, partfcularly light rail
and RapidRide, as required by CPP H-16. The plan also does
not meaningfully support the development and preservatfon
of income-restricted affordable housing that is within walking
distance of these existfng high-capacity and frequent transit
investments, as required by CPP H-17.
Specifically, the draft plan maintains low-density zones within
one-quarter and one-half-mile buffers of its existfng light rail
statfon, RapidRide stops, and frequent transit stops,
partfcularly along Internatfonal Boulevard directly south of
State Route 518 and west of State Route 599 (Housing
Background Report, page 36). Many of these areas are also
designated as “qualified census tracts” by the Department of
Housing and Urban Development, which are more likely to see
federal low-income housing tax credit investment than others
(Housing Background Report, page 6). The draft plan also does
not commit to adoptfng any specific incentfves for affordable
development within zones near transit, despite discussing
such incentfves in the Housing Background Report (page 37).
The AHC recognizes that Tukwila has identffied areas nearby
Internatfonal Boulevard as at high risk of potentfal
displacement and that increased development capacity
sufficient to maximize nearby transit investments could result
in unintended displacement of low-income renters, immigrant
households, and communitfes of color from homes and
businesses (Housing Background Report, pp.32-34). However,
the AHC considers low-income housing development to be a
key antf-displacement strategy. There is also potentfal for
Tukwila to implement new tenant protectfons and other
displacement mitfgatfon and equitable development measures
to support potentfally impacted communitfes, in alignment
with CPPs H-21 and H-23.
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Recommendatfon 7: To align with CPPs H-16 and H-17, Tukwila
should amend, edit, or propose new land use and housing
element policies and implementatfon strategies to support the
development and preservatfon of affordable housing near its
existfng light rail and RapidRide statfons. The City should also
implement new, higher density zones or overlays and
affordable housing incentfves that would support the
development and preservatfon of affordable housing near
transit.
Concurrent with development capacity increases, Tukwila
should implement measures that mitfgate the involuntary
relocatfon of residents, cultural assets, and businesses from
their current locatfons and promote equitable development in
areas at high-risk of displacement, partfcularly nearby to
Internatfonal Boulevard, in alignment with CPP H-21. Tukwila
should also expand renter protectfons, in alignment with CPP
H-23. For strategies to align with CPPs H-21 and H-23, see the
CPP Housing Chapter Technical Appendix
Washington Department of Natural
Resources; Washington Geological Survey
(10/30/2024)
Tricia R. Sears (she/her/hers)
Geologic Planning Liaison
Washington Geological Survey (WGS)
Washington Department of Natural Resources (DNR)
Cell: 360-628-2867 | Email: tricia.sears@dnr.wa.gov
1 In keeping with the interagency correspondence
principles, I am providing you with comments on
Tukwila’s Comprehensive Plan and Development
Regulatfons update (Commerce ID# 2024-S-7496).
For this proposal submitted via Planview, I looked at the
proposal and focused on areas related to WGS work. Of
--
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note, but not limited to, I look for language around the
geologically hazardous areas, mineral resource lands,
mining, climate change, and natural hazards mitfgatfon
plans.
Specifically in this proposal, I reviewed the Draft Comp
Plan Elements – Tukwila document. I focused on the
Land Use Element, the Natural Environment Element,
the Shoreline Element, and the Utflitfes Element.
2 Land Use Element: Critfcal areas are mentfoned in Policy
LU 1.3 and Goal 2. Climate change is mentfoned once in
Policy LU 6.2.
In the draft Comprehensive Plan, the following goals and policies address critical areas
specifically:
• Community Character: Policy 8.16
• Land Use: Goal 2
• Natural Environment: Goal 2; policies 5.1, 8.6, 9.1 through 9.6
• Shoreline Policies 9.1 and 2.1
• Capital Facilitfes 2.7 and 3.1 to 3.4
The following Implementatfon Strategies also address critfcal areas specifically:
• Natural Environment: 9.1-6.1 through 9.1-6.5 and 11&12.all.3, and 11&12.all.11
through 13.
• PROS: 6.1-8.13
Climate Change is referenced in the following goals and policies:
• Community Character: Policy 8.14
• Land Use: Policy 6.2
• Housing Policy 2.9
• Economic Development Policy 3.7
• Natural Environment: Goal 1
• Transportatfon Goal 5, and policies 5.5, 5.6. and 5.7, 5.8, 5.9, and 5.10
• Utflitfes Policy 1.16
• Capital Facilitfes Policy 2.3
And Implementatfon Strategies
• Natural Environment 11&12.all.2
• Utflitfes 1.16.2
3 Natural Environment Element: That link goes to the
Shoreline Element. There was no other link or optfon to
review the Natural Environment Element.
4 Shoreline Element: Critfcal areas are mentfoned in Policy
9.1.
5 Utflitfes Element: On page 1 it notes, “Policies pertaining
to utflitfes and vegetatfon are located in the Natural
Environment element.” Climate change is noted in Policy
LU 1.16 and Policy LU 1.21.
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6 On page EN-1 and EN-2, the sequence of informatfon is
a little off. Paragraph 4 on page EN-1 seems like it should
be located elsewhere so that the box (Figure #?) on page
EN-2 goes directly after the statement, “Some of the
benefits of trees are shown as follows.”
(The response to these comments was provided in an email – below is excerpted from that
email)
Noted. This will be addressed in final formatting
7 On page EN-5, EARTH RESOURCES AND GEOLOGIC
HAZARDS
“The City has mapped areas with steep and unstable
slopes, including actfve landslide areas, to ensure that
there is adequate review of slope stability if
development is proposed in these areas. In additfon,
there are coal formatfons on the southwest side of
Interurban Avenue South, some of which have been
mined and are defined as environmentally critfcal areas
based on the City of Tukwila Abandoned Underground
Coal Mine Hazard Assessment, May 1990.” Suggest
statfng which of the geologically hazardous areas exist in
Tukwila, and then notfng that the development
regulatfons are in Title xyz of the Tukwila code. It would
be good to have a map of the geologically hazardous
areas.
Critical areas are shown on our City GIS system, and if appropriate, our code requires
submittal of a geotechnical study. I have augmented the reference to critical areas
and geologically hazardous areas in the Background Report, p. 3:
Tukwila’s critical areas regulations also define and map geologically hazardous areas
and coal mine hazard areas and require geotechnical evaluations and corresponding
design requirements to reduce risks created by development in such areas. These
critical areas are shown on the City’s iMap GIS system, and the Washington
Department of Natural Resources has developed an interactive database that can
serve as a resource for identifying geologic information: Geologic Information Portal
/ WA-DNR.
8 On page EN-7, “Recently, King County created a heat
map4, showing how Tukwila, with a relatfvely large,
paved footprint, can reach extremely high temperatures
and is unable to cool at night during extreme heat
events.” Do you plan to include “heat map”?
We will provide this link to King County’s heat map – the County is in a better
position to complete the analysis needed to develop such a map, and the City
doesn’t have resources to maintain this map. We recognize that it demonstrates
that there is a concern about the outcome of heat events; this condition drives other
policies that the City has adopted (e.g., tree canopy, etc.)
9 Good to see Goal EN-9 regarding geologically hazardous
areas and Goal EN-13 regarding climate change.
I have attached a sheet listfng out many of the Goals, Policies, and Implementatfon
Strategies that specifically address critfcal areas and climate change – this list is based on
the various Comp Plan elements; there are additfonal references in the various elements’
Background Reports. The City is scheduled to develop its climate change element in 2029.
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10 None of the Elements I reviewed included much of a
descriptfon of the connectfons between this
comprehensive plan and other plans like the hazard
mitfgatfon plan, the climate plan*, the transportatfon
plan, and so forth. Many of the comprehensive plans I’ve
reviewed have lists or paragraph descriptfons of related
plans.
The Comp Plan has adopted by reference many other City Plans, and various other
plans. Some of those plans are discussed briefly in the 2024 Comp Plan. The
Transportatfon Element/Plan draft (which was completed in late September) and is part of
this Comp Plan.
As noted, the City will develop a climate plan in 2029, although there are many
policies throughout the 2024 Comp Plan that address Climate Change.
11 Overall, the Comp Plan Elements reviewed were written
well, but reveal a lack of detail on critfcal areas
(including geologically hazardous areas), climate change,
hazards, hazard mitfgatfon plans, and how those are
integrated in land use planning in Tukwila, with
comprehensive plan elements, development regulatfons,
climate plans, transportatfon plans, hazard mitfgatfon
plans and so forth. Many of the comprehensive plans I
have reviewed include more details on these areas, for
example including narratfve, maps, and lists of related
plans. If it would be helpful, I can provide you with some
examples of comp plans that have this informatfon more
integrated.
Noted. Thank you for your offer.
12 Below, I include our usual language for future endeavors.
Recognizing the limitatfons of the current proposals, I
want to mentfon that it would be great for you to
consider these in current or future work, be it in your
comprehensive plan, development code, and SMP
updates, and in your work in general:
• Consider adding a reference to WAC 365-190-120
geologically hazardous areas for definitfons in other
areas besides the CAO. In additfon, consider adding a
reference to WAC 365-196-480 for natural resource
lands.
This language was added to the Natural Environment Background Report, p.3, and p.EN-2
of the Element:
The Washington State Growth Management Act (GMA) requires countfes and citfes
to designate and adopt policies and development regulatfons to protect critfcal
areas (RCW 36.70A.050; WAC 365-190).
The Natural Environment Element sets forth goals and policies to guide the
protectfon and management of wetlands, watercourses, springs, fish and
wildlife habitat areas, and geologically hazardous areas – collectfvely called
“environmentally critfcal areas”. It also includes goals and policies related
to flood management, surface water management, water quality, and the
urban forest (the combinatfon of trees, shrubs and other plants that make
up the formal landscaped areas of the City and the natural areas in our
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parks and on private property). The policies and development regulatfons
addressing critfcal areas in Tukwila are guided by the Washington State
Growth Management Act (RCW 36.70A.050; WAC 365-190).
13 • Consider adding a reference to the WGS Geologic
Informatfon Portal in other areas besides the CAO. If
you have not checked our interactfve database, the
WGS Geologic Informatfon Portal, lately, you may
wish to do so. Geologic Informatfon Portal | WA -
DNR
This language was added to the Natural Environment element, p. EN-2
Tukwila’s critical areas regulations also deflne and map geologically
hazardous areas and coal mine hazard areas and require geotechnical
evaluations and corresponding design requirements to reduce risks
created by development in such areas. These critical areas are shown on
the City’s iMap GIS system, plus the Washington Department of Natural
Resources has developed an interactive database that can serve as a
resource for identifying geologic information: Geologic Information Portal /
WA-DNR.
14 • If you have not checked out our Geologic Planning
page, you may wish to do so. Geologic Planning |
WA - DNR
Noted. Thank you.
Planning Commission (remaining questfons)
1 Policy Change recommended in comment
received at 3-14-24 Planning
Commission Public Hearing (comment
from Tukwila Human Services
Department)
Policy CC-8.1 Support Implement the
City’s human services strategic approach and
program in providing to support a solid
foundation for all Tukwila residents through by
providing high-quality services and actively
collaborating with service providers to help
meet basic needs and job readiness,
including:
• Safety net for urgent and basic needs,
Staff recommended version shown in draft Plan. (as shown in track changes to
the left)
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• Positive and healthy relationships,
• Support for self-sufficiency, and
• Information referral (and system navigation).
2 PC vote tfed 3:3 on whether to strike the policy
(1-25-24)
Policy LU 7.5 Mitigate potential
displacement from City actions through
communication and collaboration with
existing tenants, business and property
owners, and seek to replace lost commercial
and residential spaces within redevelopment.
Staff recommends retaining the policies as shown in the Land Use element.
This policy protects Tukwila residents and/or businesses from displacement by
communicatfng and assistfng in locatfng replacement locatfons/ development.
3 PC vote tfed 3:3 on whether to strike the policy
(1-25-24)
Policy LU 7.6 Emphasize preserving
and replacing affordable housing in
redevelopment.
Staff recommends retaining the policies as shown in the Land Use element.
This policy focuses on protectfon of residents in affordable housing.
Public Comment
Mike Pruett
Segale Propertfes
5811 Segale Park Drive C
Tukwila WA 98138 / 206/575-200
Comment/Questfon #1. Page 69 of Attachment C
indicates the city will implement “reasonable
measures” such as changing zoning and permitting
procedures and other measures to speed housing
productfon. Can you elaborate/provide more detail on
what changes will occur and how that will accelerate
housing productfon?
Reasonable measures are actfons that countfes and citfes in Washington state can take to
address inconsistencies in their comprehensive plans and to remedy the supply of
buildable land. Because Tukwila fell short in both its housing and employment
development rates, Tukwila is required to provide Reasonable Measures to rectffy the
predicted shortiall.
Optfons that the City can consider are listed in the Implementatfon strategies listed in the
of City’s TOD Housing Actfon Plan, and in the Goals and Policies listed in the Housing
Element and Land Use Element. Further discussion of potentfal measures to increase
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housing productfon can be found one pages 37-38 of the Housing Background Report. As
you know an MFTE program was reinstated and expanded by the City after the
recommendatfon of reasonable measures. Qualifying projects in the Tukwila South Overlay
and Tukwila Urban Center are eligible for 8 or 12 year MFTEs, as codified in TMC 3.90.
Comment/Questfon #2. The top of page 81 of
Attachment C contains a statement that we had
addressed in previous emails to the City during the
comment period on the Comprehensive Plan. Our
concern about the language used here remains
unchanged from the comments in the attached emails
above. Including such a statement in the
comprehensive Plan does nothing to support and
promote development but instead casts doubt and
uncertainty on the Tukwila South project that will most
certainly be negatfvely viewed by the development
community we are trying to attract to Tukwila
South/Prato District. First it is not necessary for a
developer to make a substantfally larger investment in
Tukwila South than any other development site. In fact,
Segale has worked very hard to lower the investment in
infrastructure (and tfme) necessary for a developer to
get a project out of the ground. Core key infrastructure
is already built. Entftlements are already largely taken
care of. Administratfve design review is the only step
necessary to get to constructfon documents, making this
the fastest potentfal shovel ready large development
opportunity in the region. The concern about cohesive
mixed-use development is also a negatfve statement
that may dissuade development in Tukwila South. Any
development proposed within Tukwila South must pass
through the filter of Segale, as well as the City of
Tukwila, prior to being approved and constructed, so
The language cited on page 81 is from the Economic Development element and can be
removed.
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there is more than enough opportunity to ensure project
cohesiveness. There are also residentfal design
guidelines and standards that further provide for
cohesiveness and commercial development guidelines
that also do the same. The Tukwila South approval and
Development Agreement provided a vision for the future
that can and will be followed. Its tfme to let go of
negatfve statements about the project that have
persisted in city documents through the years.
Comment/Questfon #3. Attachment D of the Comp Plan
again mentfons “reasonable measures” to correct
Tukwila’s historically low housing and employment
growth. We would like to discuss and understand what
policies and implementatfon measures that city is
considering and how they might relate to the Tukwila
South/Prato District opportunity.
As noted above, there are a range of implementatfon optfons the City can consider (as
noted in links above). Please see the response to Questfon #1 for further links to discussion
and policies within the plan update. We would be happy to discuss how these optfons may
apply to Tukwila South/Prato District.
Comment/Questfon #4. Why is the TVS zoning
designated areas discussed on this page. The TSO
overlay supersedes the TVS zoning. Shouldn’t there be a
paragraph on the TSO zoning and the opportunitfes it
provides rather than the underlying zoning the TSO
zoning supersedes?
This discussion was grouped by zones, then by overlays. The TSO is an overlay that
augments the TVS zone – The zone identffies the preferred land use, while the overlay adds
additfonal regulatfons to that zone. If the overlay went away, the zone would stfll be there.
The following proposed policies address Tukwila South:
LU 4.2 addressing the Tukwila South Overlay is grouped by zoning classificatfons affected:
Areas under the Tukwila South Overlay includes lands designated TVS, HI, LDR and MUO,
and supersedes the provisions of the underlying zoning districts. It is intended to create a
multi-use employment center containing high technology, office, commercial, retail and
residential uses at the south end of the City.
LU 3.10 addresses the TVS zone:
The Tukwila Valley South (TVS) designated areas are characterized by high-intensity
regional uses that include commercial services, offices, light industry, warehousing and
retail, with heavy industrial subject to a Conditfonal Use Permit. Mixed-use residentfal is
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conditfonally permitted within 500 feet of the Green River. These uses and densitfes are
modified where covered by the Tukwila South Overlay.
This area was addressed in the 2015 Plan as follows:
Brian Kennedy
7/31/24
I’ve live here since 1978. My wife is from Ireland and
they have a Tidy Town competftfon. We need to have a
competftfon between towns and one among residents
for the cleanest and most beautfful towns and peoples
yards with substantfal prizes donated by local
businesses. The planter dividers on our streets should
constantly be landscaped; we shouldn’t have to click fix
them. The city needs to enact strict rules on loitering
and public intoxicatfon. These people should be
Thanks for your comments. I have taken the liberty of sortfng them by City department
likely to be involved:
I’ve live here since 1978.
Economic Development/Public Works:
• My wife is from Ireland and they have a Tidy Town competftfon. We need to have a
competftfon between towns and one among residents for the cleanest and most
beautfful towns and peoples yards with substantfal prizes donated by local
businesses.
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interviewed to see where their situatfon stands and get
them help to bring them up and off the streets.
Shoplifters should not be able to just steal and walk
away; they should be accountable. We should not have
to click fix graffitf, garbage, illegal parking etc. The city
should be on top of it every day. Our parks should be
safe, especially Bicentennial Park and Tukwila Pond. The
homeless should not be able to take over these parks,
these parks should be celebrated not abused. Tukwila
Pond is a great asset; it should be a destfnatfon spot.
The city could partner with Double Tree to use it for a
comfortable terrace with a restaurant or cafe that the
hotel guests and Tukwila citfzens can enjoy. A street
light or stop sign on 133d & Military Road meets. There
have been many many wrecks there. The Mall, the city
and the State need to fund more police officers . The
Southcenter taxes to the State needs to be renegotfated
to have this happen . Tukwila Days needs to come back.
Most towns in the area have fairs and events; Tukwila is
boring.
• The planter dividers on our streets should constantly be landscaped; we shouldn’t
have to click fix them.
Police:
• The city needs to enact strict rules on loitering and public intoxicatfon. These
people should be interviewed to see where their situatfon stands and get them
help to bring them up and off the streets.
• Shoplifters should not be able to just steal and walk away; they should be
accountable.
Police/Public Works:
• We should not have to click fix graffitf, garbage, illegal parking etc. The city should
be on top of it every day.
Parks/Police/Human Services:
• Our parks should be safe, especially Bicentennial Park and Tukwila Pond. The
homeless should not be able to take over these parks, these parks should be
celebrated not abused.
Parks:
• Tukwila Pond is a great asset; it should be a destfnatfon spot. The city could partner
with Double Tree to use it for a comfortable terrace with a restaurant or cafe that
the hotel guests and Tukwila citfzens can enjoy.
• Tukwila Days needs to come back. Most towns in the area have fairs and events;
Tukwila is boring.
Public Works:
• A street light or stop sign on 133d & Military Road meets. There have been many
many wrecks there.
City Budget:
• The Mall, the city and the State need to fund more police officers .
• The Southcenter taxes to the State needs to be renegotfated to have this happen .
RESPONSE: I will look at how we could integrate these comments into the Implementatfon
Strategies for the Plan (although some of your comments are very specific and not typical
of the types of items listed as Implementatfon Strategies). I will also forward them to the
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various City departments and ask those representatfves to follow up with you if they have
questfons (or you could contact them directly: see https://www.tukwilawa.gov/ for more
informatfon). Thanks for providing your ideas.
Michelle Eggert
Public Comments – Tukwila City Council
Comprehensive Plan and Ryan Hill Zoning
Monday, Sep. 23, 2024
The speaker advocated for the Ryan Hill area to be
rezoned to allow additfonal housing for all income levels
in preparatfon for a potentfal light rail statfon at Boeing
Access Road.
While staff agrees that subarea planning, including potentfal zoning changes, should be
undertaken for areas surrounding the future infill light rail statfon, it is premature to change
development standards with the periodic update of the comprehensive plan based on
several factors.
1. The preferred alternatfve for the infill statfon has not yet been determined, nor has
the final statfon locatfon been finalized. In communicatfons with Sound Transit it is
currently antfcipated that a preferred alternatfve will be selected by the Sound
Transit Board in January or February of 2025, and a final locatfon will be confirmed
in Fall 2025. Two locatfons are currently being considered, one adjacent to Boeing
Access Road (BAR) and the other just North of South 112th St and East Marginal
Way.
2. The statfon is not antfcipated to begin constructfon untfl 2028, and not antfcipated
to open untfl December 2031. The City has the opportunity through annual
comprehensive plan amendments and other code updates to amend zoning and/or
development regulatfons for another seven years or more before the statfon
opens. Staff also believe a public process, including further engagement with
residents and stakeholders should take place to determine the future for the area.
3. Although the aerial distance between many Tukwila propertfes off of Ryan Way are
within a ½ mile from the Boeing Access Road potentfal statfon locatfon, there are
significant impediments to traveling between the site without a car that will need
to be rectffied prior to the opening of the statfon. These impediments, such as a
lack of sidewalk access over the BAR bridge, interchanges, high traffic speeds, lack
of bicycle infrastructure and heavy truck traffic, will need to be address through
capital planning and project which will take several years. Without the statfon and
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associated improvements, the area does not currently support transit-oriented
development (TOD), and to rezone to TOD style development without supportfve
improvements would be premature.
4. The area within the statfon buffer is current within a Manufacturing and Industrial
Center (MIC) designated by the Puget Sound Regional Council (PSRC). As part of
designated center this area is intended to support a clustering of industrial jobs,
not necessarily compatfble with a TOD development concept. While staff agrees
that the boundary for the MIC should revisited and likely amended, this process is
required to take place with consultatfon with PSRC.
Mary Fertakis
Public Comments – Tukwila City Council
Comprehensive Plan and BAR Statfon Language
Monday, Nov. 18, 2024
There appear to be 4 components of the
comprehensive plan that have a connectfon to the
BAR Statfon project, with goals and policies that
intersect and support each other:
• Vision
• Transportatfon
• Land Use
• Economic Development
The meetfngs we have had with Sound Transit’s
community engagement staff have contfnued to
emphasize the importance of being able to connect
Tukwila’s vision to this project. I was glad to see
specific language related to the BAR Statfon and
these components of the Comp plan, and would like
to offer some specific language suggestfons to
strengthen this connectfon.
1) That communicatfons with Sound Transit cite the specific goals and policies of the
Comp Plan related to the BAR Statfon design and decision-making to make the
connectfon to the Vision clear.
a. There is substantfal communicatfon and lobbying that has taken place over
many years between the City and Sound Transit. Staff agrees that future
visioning should take place to ensure development standards and allocated
resources are aligned with the desire for the statfon area. However, with a final
statfon locatfon not formally selected, and an antfcipated tfmeline of a 2028
constructfon start and 2031 opening, if it is determined that Plan policies
should include specific guidance, those changes could be made during the
annual updates of the Plan to ensure there is adequate public engagement in
the process.
2) That specific reference to the historical and cultural importance of the Duwamish Hill
Preserve, and Tukwila & King County salmon recovery areas that are immediately
adjacent to the proposed statfon site be included in the Comp Plan.
a. The Duwamish Hill Preserve is addressed as a Special Use Park in the Plan’s
Parks, Recreatfon, and Open Space Plan. Staff will look to add language
regarding the cultural significance of the Duwamish Hill Preserve to the Natfve
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Vision:
• Sectfon on Respect for the Past & the
Present (pg. I-9 & I-10)
“The Coast Salish Tribes have lived here
since time immemorial and while each tribe
is unique, all share in a deep historical
connection and legacy of respect for the
land and its natural resources. These
sovereign tribal nations enrich the region
through environmental stewardship, cultural
heritage, and economic development.”
o There is no specific mentfon that I
could find in the Comp Plan of the
Duwamish Hill Preserve.
• “We cooperate with residents to improve
neighborhood infrastructure. We encourage
neighborhood pride and interaction.”
o The Allentown & Duwamish
neighborhoods adjacent to the
proposed sites are a transportatfon
desert as well as lacking other forms
of infrastructure. We want to see a
statfon that supports needed
infrastructure and is an
enhancement to the neighborhoods.
Land Use:
American Culture and Settlement in Tukwila Area sectfon of the Community
Character Element.
3) That the reference to zoning the area where the proposed statfon will be located, listed
as Policy LU 9., includes language that specifically says it will revised to be a TOD
“island” to support economic development in the immediate area.
a. The area is currently within the Manufacturing and Industrial Center
designatfon, an area designated for industrial uses that supports economic
growth. In order to change the designatfon boundary, the City would need to
consult with the regional planning body Puget Sound Regional Council (PSRC)
which oversees center designatfons. As the City updates its center designatfons
in 2025, it will consult with PSRC and explore removing an area around the
statfon from the existfng MIC boundary.
4) That a preference for “structured parking” (a parking garage) be specified for the BAR
statfon just as it is for the TIB statfon sectfon on pg. LU-14
a. The reference to structured parking in Policy LU 11.7 refers to parking
associated with uses around the existfng TIB statfon, not the statfon itself.
Requirements for parking for future uses will be analyzed with future zoning
and development regulatfon updates for the area.
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• Goal 9 – Boeing Access Road Statfon Area on
pg. LU-12
“Zoning and development regulations will be
evaluated, and amended to anticipate and
adapt to impacts on the area with
consideration for long term vision,
compatibility, and equity.”
o This is currently zoned as a
Manufacturing Industrial Center
(Heavy) and would need to be re-
zoned as a TOD “island” in order do
the type of economic development
in line with Comp Plan goals.
o Re-zoning is also mentfoned in the
Transportatfon segment in tonight’s
materials under the Connectfvity
sectfon, designated as T3.5 on pg. 9.
Transportatfon:
• Goal 5 – Environment
“Support, encourage, and implement
transportation programs and improvements
that promote water quality and regional air
quality.” (T5.6, pg. T-14)
o Parking lots create large impervious
surfaces that change the
environment and cause pollutfon
runoff impactfng the immediate
area. Parking “structures” (garages)
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# Comment Response
reduce this concrete footprint and
are a much better use of land in
urban areas.
Language Requests for Council Consideratfon:
1) That communicatfons with Sound Transit cite
the specific goals and policies of the Comp Plan
related to the BAR Statfon design and decision-
making to make the connectfon to the Vision
clear.
2) That specific reference to the historical and
cultural importance of the Duwamish Hill
Preserve, and Tukwila & King County salmon
recovery areas that are immediately adjacent to
the proposed statfon site be included in the
Comp Plan.
3) That the reference to zoning the area where the
proposed statfon will be located, listed as Policy
LU 9., include language that specifically says it
will revised to be a TOD “island” to support
economic development in the immediate area.
4) That a preference for “structured parking” (a
parking garage) be specified for the BAR statfon
just as it is for the TIB statfon sectfon on pg. LU-
14
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# Comment Response
Continued Staff Review
Minor update acknowledging that the City’s Critfcal
Areas Ordinance will be reviewed and updated in 2025.
Sentence added, page EN-3
In 2025, the City will revisit its Critical Area regulations to ensure that they refiect current best
practices and recent legislative requirements.
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AN ORDINANCE OF THE CITY COUNCIL OF THE CITY OF
TUKWILA, WASHINGTON, AMENDING THE CITY OF
TUKWILA COMPREHENSIVE PLAN IN COMPLIANCE
WITH THE REQUIREMENTS OF THE GROWTH
MANAGEMENT ACT; ADOPTING LEGISLATIVE FINDINGS
IN SUPPORT OF SAID AMENDMENT; PROVIDING FOR
SEVERABILITY; AND ESTABLISHING AN EFFECTIVE
DATE.
WHEREAS, the Washington State Growth Management Act (“GMA”) pursuant to
RCW 36.70A.130, requires that all cities and counties periodically take legislative action
to review and, if needed, revise their comprehensive land use plan to ensure the plan
complies with the requirements of the GMA; and
WHEREAS, on December 4, 1995, the City of Tukwila (“City”) adopted its initial
Comprehensive Plan by Ordinance No. 1757 to comply with the GMA and has amended
it cyclically thereafter; and
WHEREAS, in 2023, the City initiated the mandatory 2024 update of its
Comprehensive Plan in accordance with RCW 36.70A.130; and
WHEREAS, under the schedule established in RCW 36.70A.130(5)(a), December
31, 2024, is the deadline for the City to comply with the required update; and
WHEREAS, the GMA requires each jurisdiction to establish public participation
procedures, whereby updates, proposed amendments, or revisions to the
Comprehensive Plan are considered; and
WHEREAS, the City developed, and the City Council accepted, a Community
Engagement Plan on June 12, 2023, identifying the following: the outreach objectives,
key groups and stakeholders, previous planning documents that would be reviewed for
their findings, communication methods and activities to be employed, and a proposed
schedule of outreach for the Comprehensive Plan’s development; and
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WHEREAS, during the Comprehensive Plan update process, the City solicited public
input and publicized the update efforts through articles in "The Hazelnut" and “e-Hazelnut”
community newsletters; email messages to a list of community members who self-
identified during the 2015 Plan Update, signed up for more information on the City’s
website between 2022 and 2024, and signed up at various Comprehensive Plan outreach
events offered by City staff; Community groups identified and contracted with for input on
housing issues and by contacting staff directly to receive more information; and duly
noticed public meetings, work sessions and public hearings in front of the Planning
Commission and City Council; and
WHEREAS, staff prepared an analysis of the Comprehensive Plan currently in effect
in Tukwila for consistency with the requirements of RCW 36.70A and, based on this
analysis, staff prepared proposed revisions it concluded are needed to comply with RCW
36.70A; and
WHEREAS, during review of the Comprehensive Plan, it was determined that, in
addition to containing technical information and data that were out of date, numerous
elements contained content that was addressed in other elements, had already been
accomplished, or were no longer consistent with regional and state policy direction and
should be updated and/or consolidated and streamlined; and
WHEREAS, the Tukwila Planning Commission considered the technical analysis and
proposed Comprehensive Plan amendments between March 2023 and March 2024; and
WHEREAS, the Tukwila Planning Commission held a duly noticed public hearing on
the draft Comprehensive Plan on March 14, 2024, and following public input, voted to
forward the draft plan to the City Council with a recommendation for adoption; and
WHEREAS, on December 2, 2024, the City of Tukwila issued a Determination of Non-
Significance Addendum to the Tukwila Comprehensive Plan 1995 Environmental Impact
Statement (File # E24-0001), which analyzed the potential environmental impact of the
proposed Comprehensive Plan amendments, pursuant to the State Environmental Policy
Act (“SEPA”) and the Tukwila Municipal Code, Title 21; and
WHEREAS, pursuant to RCW 36.70A.210, the City must collaborate and be
consistent with regional agencies and their plans, including the King County Countywide
Planning Policies, the Puget Sound Regional Council Vision 2050, and the requirements
of the Washington Department of Commerce and other state agencies for periodic
updates of comprehensive plans; and
WHEREAS, the City submitted the requested portions of the City’s draft Plan to: the
Affordable Housing Committee of the King County Growth Management Planning Council
on August 7, 2024; the Puget Sound Regional Council on August 7, 2024, and October
7, 2024 (Transportation); and the Washington State Department of Commerce and other
state agencies on September 20, 2024, and September 26, 2024 (Transportation), to
provide the required 60-day state notification (under RCW 36.70A.106) for comment; and
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WHEREAS, on September 23, 2024; November 18, 2024; and December 9, 2024,
the Tukwila City Council held duly noticed public hearings to receive public comments on
the recommended changes to the Community Character, Land Use, Regional Centers,
Housing Economic Development, Natural Environment, Shoreline, Parks, Recreation,
and Open Space, Transportation, Utilities, and Capital Facilities Elements; and
WHEREAS, based on its review of the requirements of Chapter 36.70A RCW, the
analysis and proposed revisions prepared by staff, the proposed revisions forwarded by
the Planning Commission, and the public comments received, the City Council; and
WHEREAS, at the conclusion of its review and deliberations on December 16, 2024,
the City Council approved the amendments to the Comprehensive Plan as set forth in
Exhibit A hereby incorporated by this reference;
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF TUKWILA,
WASHINGTON, HEREBY ORDAINS AS FOLLOWS:
Section 1.Findings.In support of this ordinance, the City Council adopts the above
recitals. The City Council further makes the following additional findings:
A. The proposed Comprehensive Plan amendments are consistent with the GMA
and other applicable state laws;
B. The proposed Comprehensive Plan amendments are consistent with applicable
countywide planning policies and Vision 2050 policies;
C. The proposed Comprehensive Plan amendments are beneficial to the City as a
whole, and to the health, safety and welfare of its residents;
D. The proposed Comprehensive Plan amendments have been processed in
material compliance with all applicable procedural requirements;
E. The City Council has considered, and has been guided by, the GMA Planning
Goals enumerated at RCW 36.70A.020, as well as all other applicable provisions
of the GMA;
F. The City Council has considered, and the proposed Comprehensive Plan
amendments satisfy, the criteria set forth in Chapter 18.80.050 TMC, as
applicable;
G. All relevant requirements of SEPA have been satisfied in relation to this ordinance;
and
H. All of the proposed Comprehensive Plan amendments have been considered
concurrently so that their cumulative effect has been appropriately ascertained.
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Section 2. Amendment of Comprehensive Plan—Adoption of 2024
Comprehensive Plan Update. The Tukwila Comprehensive Plan is hereby amended to
provide in its entirety as contained in Exhibit A, attached hereto and incorporated herein
by this reference as if set forth in full. A copy of the Comprehensive Plan, as amended,
shall be maintained for public copying and inspection at Tukwila City Hall.
Section 3. SEPA Substantive Authority. The adopted Comprehensive Plan as
amended hereby, inclusive of any future amendments, is hereby designated as a basis
for the exercise of substantive authority under the State Environmental Policy Act by the
City's responsible official in accordance with RCW 43.21C.060.
Section 4. Non-Substantive Document Formatting and Administrative
Procedures Authorized. Upon authorization of the City Attorney, the City Clerk may
make non-substantive editing changes and updates to the formatting, color, and pictures
in the Comprehensive Plan consistent with best available technology to the amended
Comprehensive Plan after adoption in order to provide for consistency and clarity in
formatting and content. The Mayor is further authorized to implement such administrative
procedures as may be necessary to carry out the directions of this legislation to include
incorporating the amended Comprehensive Plan, and preparing and publishing the same.
Section 5. Corrections by City Clerk or Code Reviser Authorized. Upon approval
of the City Attorney, the City Clerk and the code reviser are authorized to make necessary
corrections to this ordinance, including the correction of clerical errors; references to other
local, state or federal laws, codes, rules, or regulations; or ordinance numbering and
section/subsection numbering.
Section 6. Copy to Department of Commerce.Pursuant to RCW 36.70A.106, a
complete and accurate copy of this ordinance shall be transmitted to the Department of
Commerce, Growth Management Services, within ten (10) days of adoption.
Section 7. Severability. If any section, subsection, paragraph, sentence, clause, or
phrase of this ordinance or its application to any person or situation should be held to be
invalid or unconstitutional for any reason by a court of competent jurisdiction, such
invalidity or unconstitutionality shall not affect the validity or constitutionality if the
remaining portions of this ordinance or its application to any other person or situation.
Section 8. Effective Date. This ordinance or a summary thereof shall be published
in the official newspaper of the City, and shall take effect and be in full force five days
after passage and publication as provided by law.
PASSED BY THE CITY COUNCIL OF THE CITY OF TUKWILA, WASHINGTON, at
a Regular Meeting thereof this _______ day of ____________________, 2024.
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ATTEST/AUTHENTICATED:
Andy Youn, CMC, City Clerk Thomas McLeod, Mayor
APPROVED AS TO FORM BY: Filed with the City Clerk:
Passed by the City Council:
Published:
Effective Date:
Office of the City Attorney Ordinance Number:
Exhibit A: 2025 Comprehensive Plan
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