A group of Ravenna neighbors participated in the July 11, 2017 RBCA board meeting and shared their comments about the Mandatory Housing Affordability (MHA) Draft Environmental Impact Statement (DEIS). In addition to requesting that the RBCA board include their comments in any communication they may have with the City regarding the DEIS, it was requested that their comments be posted to the RBCA website.
Below are their drafted comments which include a suggested alternative to zoning changes proposed in the DEIS. Thoughts about the proposal below may be left after the post. (Please note that the comments section is moderated and new comments may not immediately appear, especially if moderators are on vacation.)
To: Office of Planning and Community Development
Re: Comments to the MHA DEIS issued by the city of Seattle on June 8, 2017
We support Seattle’s effort to increase affordable housing and supports the MHA inclusionary zoning policy, the subject of the DEIS. In addition, since we support efforts to make Seattle more equitable, not just the Urban Villages, we request an Alternative 4 described herein be included in the Action Alternatives.
We strongly support requiring MHA developers in areas designated “high opportunity” to be required to include affordable units in their developments, rather than contribute a fee, as this policy will more directly ensure that affordable units are distributed equitably in the City, and minimize displacement.
Alternative 4, Part One: Where appropriate, do transitions outside of Urban Villages, implement appropriate zoning within the adjacent SF neighborhood, rather than move the Urban Village Boundary or Expand the Urban Village
We affirm much of the increased zoning proposed in OPCD’s October 2017 Plan, and parts of Alternatives 2 and 3 of the DEIS, as clarified below. In exchange for the new zoning, and in response to neighborhood concerns, and adverse impacts identified in the DEIS, we believe the MHA program goals can be better accomplished by creating a more effective transition between the Roosevelt Urban Village and Ravenna outside of the Urban Village, while keeping the Roosevelt Urban Village eastern boundary along the current border of 15th Ave NE and not expanding the Urban Village to the east.
Alternative 4, Part Two: Allocate Planning Resources to SF neighborhoods who want to plan proactively for expansion of housing opportunities in their neighborhoods
We propose to study options for increasing housing opportunities in the broader community of Ravenna/Bryant. This policy would reward neighborhoods who want to plan proactively, could extend the reach of the MHA; create more walkable neighborhood business districts; more family-size, ground related, mixed-income housing in the neighborhood.
Summary of support for proposed zoning changes and clarifications: The attached map provides an overview of zoning changes we are proposing east of 15th Avenue NE where the Ravenna and Roosevelt neighborhoods meet.
North of NE 65th:
- Adopt OPCD’s proposed rezoning from SF to LR3 along the East side of 15th Ave NE from NE 65th to NE 68th St. (same as OPCD Plan & Alternative 3, higher than Alternative 2). Our design preference would be row houses with backyards to provide more room for the tree canopy and storm water retention, and create a better buffer for lower zoning to the east.
- Adopt modified proposed new zoning from SF to LR-1 along the West side of 16th Ave NE from NE 65th to NE 68th. (change from OPCD & Alt 3 LR -2, but higher than Alt. 2)
- Change RSL to SF from the East side of NE 16th Ave to the West side of NE 17th (including the commercial on NE 65th except for the existing NC-40 on 15th Ave NE. )*
South of NE 65th–
- Keep Existing NC-40-55 south of NE 65th St along from 15th Ave. NE (same as all options)
- Retain SF south of existing NC-40-55 zoning as SF along 16th Ave NE and 15th Ave NE.
- *Change all RSL to SF because current policy restricts RSL to Urban Villages
Description of Impacts, Mitigation, and Comparisons of Action Alternatives
The proposed changes pertain to local conditions that will result in better, more gradual transitions between MF and SF and will mitigate concerns about land use impacts of bulk and scale, shade, and solar access. Not changing the Boundary will also mitigate impacts to historical resources; aesthetics, transportation & parking, as well as better protect the tree canopy, Ravenna Ravine and Creek and improve storm water management. Concurrently accepting many of the proposed changes in zoning will provide increases in density, promote needed redevelopment of 15th Ave NE and create new opportunities for MHA affordable units. The local impacts and mitigations are described below as well as a comparison of the Action Alternatives.
The current boundary of 15th Ave NE makes better sense than 16th or 17th Ave NE. The proposed expansion area of the Roosevelt Urban Village is relatively small just one or two blocks east, except for a small sliver in Alternative 3 along the main arterial NE 65th from 16th Ave NE to 20th Ave NE. Boundaries normally are articulated on arterials, not on narrow residential streets, such as 16th or 17th Ave NE. In the case of the Roosevelt Urban Village, better, more legible, gradual transitions between urban village densities and SF can be created outside of the urban village, rather than changing the boundary.
The proposed zoning provides a better transition from urban form to SF. The zoning is identical to Alternative 3 in the step down from the Urban Village on west side of 15th Ave, north of 65th where a new 7 story building is being permitted next to Roosevelt High School, to L-3 on the East side of 15th . We then propose to L-1 on the West side of 16th. LR-1 makes a better transition in bulk and scale than LR2 to SF owners who choose to remain in the LR-1 zone on 16th, and to the SF across the street on the east side of 16th Ave NE. Accepting the up-zones preserves the same potential for MHA affordable units and density on 15th, and slightly less on 16th than Alternative 3, but provides significantly more on both streets than Alternative 2 or Alternative 1. North of 65th is closer to the light rail station and school than the area south of 65th, where the heights across the street in the urban village are lower. The northern end of the West side of 16th is buffered from the LR3 zone by a joint access alley.The houses on the southern end of 16th are already facing a transition to NC40, a remnant of the older zoning preference in Seattle of putting most MF on arterials. Additionally, south of 65th, the proposed expansion of NC-40(55) from SF is too stark a transition and the group has proposed keeping it as single family.
Alternative 2, which proposes RSL on 15th and 16th, would be more compatible in height and bulk to SF, but not necessarily compatible with the established architectural and urban form, and would not produce as many MHA affordable units. The difference between SF, if the boundary remained at 15th under the Sub-Alternative, and the proposed RSL in the Expansion proposed under Alternative 2 or 3 would not be significant. Many of the lots in the area are either too small to support an additional house, or because of the placement of the house on the lot, would require tearing down the existing house and many houses would likely be too expensive and/or sufficiently upgraded to meet current code, energy, seismic, and technology standards to be feasibly redeveloped as RSL within the 20-year framework of EIS analysis. This area already has ADU’s in the area, a more likely scenario to create affordable housing in this area.
Proposed increased zoning on NE 65th St needs further study. Alternative 3 proposes expansion along NE 65th to 20th. This area of 65th is topographically challenged as there is a steep slope up the hill from 16th Ave NE to the crest of the hill at 18th, and then an even steeper descent to 20th. There are no alleys serving the north side of NE 65th, both of these factors are noted in the DEIS to potentially be mitigated by adopting less intensive use. (3.121). This idea currently has some interest in the community but needs further study.
Community Planning recommended by DEIS as mitigation for land use impacts. The DEIS specifically mentions that the current criteria for land use rezones may not be met in Roosevelt (p. 3.118), and that mitigation measures might include, “address potential land use impacts as part of neighborhood level planning efforts.” (p. 3.120) Currently, only areas in Urban Villages have access to city planning resources, and the Alternative Part Two would help areas like Ravenna/Bryant do local level planning.
Neighborhood Design Guidelines Recommended by DEIS
Historic Ravenna, which includes parts of Bryant, has a consistent, established architectural urban form, and is one of Seattle’s well-preserved “bungalow” neighborhoods. Since many homes in Ravenna/Bryant are historic Craftsmen houses, concerns for historical resources and aesthetics have been expressed by neighbors, impacts which have also been identified in the DEIS. One mitigation measure suggested in the DEIS is Neighborhood Design Guidelines, which Ravenna/Bryant does not currently have. (3.165) This is another potential benefit to having neighborhoods do proactive planning.
Alternative 3 expansion along NE 65th to 20th Ave NE needs further study. As mentioned before, there is some interest in the community; specifically to expand LR1, 1 block north and south along NE 65th from 16th Ave NE to 20 Ave NE. The goal is to promote more rapid redevelopment by creating development pathways that work for single lots because in the current intense real estate market for single family houses waiting for two or more adjacent lots to be assembled could stall development. NE 65th is the most logical walking corridor to the light rail station and could connect the business districts of Ravenna and Roosevelt.
Before embracing this idea, more study is needed because of current neighborhood safety concerns about this particular stretch of NE 65th that may or may not be addressed by SDOT’s NE 65th Street Vision Zero Project.
Parking is also a concern of many neighbors. The residential streets are very narrow, and many of the old houses do not have garages, so there is already crowded street parking. This is especially intense on 16th, which has parking on only one side of the street and is often used by students going to Roosevelt. Not moving the boundary of the Roosevelt Urban village will provide parking for the incoming residents, mitigating the impact of the new development.
Historical Resources: Ravenna is one of the older neighborhoods in Seattle, resulting in a treasured collection of historic, architecturally significant Craftsmen and Tudor houses, with some Mid-Century homes. The area has not yet been surveyed and therefore potentially historical resources would be lost as development occurs. The DEIS describes “potential decreases to the historic fabric of a neighborhood” when historic buildings are redeveloped or demolished and new buildings are constructed “that are not architecturally sympathetic to the existing historic characteristics of a neighborhood.” (3.252) Since there is significant, but not universal, concern in the neighborhood about this issue, it is another reason to not extend the boundary of the urban village before the opportunity is lost to preserve what is most important.
Biological Resources Tree Canopy and Environmentally Critical Areas (ECA)
Seattle’s urban forest, mostly located in Seattle’s SF zones, provides many ecological services such as relief from the urban heat island, cleaning our air and water, and helping with storm water management, as well as being described in the DEIS as “fundamental to the character of Seattle.” All Action Alternatives will result in loss of the tree canopy according to the DEIS. Indirect impacts are identified as “changes to stream flows from upstream development” (3.263); cumulative effects of multiple parties actions could potentially alter drainage patterns and/or affect soil and slope stability, and discharges to streams may be impacted by runoff of pollutants from street surfaces. (3.265) Cumulative effects are critical in evaluating future impacts, one construction project may be nothing, many may mean disaster.
Per the pattern of the Programmatic DEIS, these impacts are characterized as not significant city wide because of the relative small amount of acreage. (3.2700) No study specific to the impacts to the Ravenna Park riparian corridor and steep slopes is cited though there have already been problems of erosion and sink holes adjacent to the park. Ravenna Creek is a bit of an anomaly because its original source of water from Green Lake was cut off and diverted to sewer pipes when the Olmstead Brothers created Green Lake Park, thus leaving very local water table sources to provide the flow of the creek.
On a city wide basis, the pattern of growth also needs to be assessed as to whether buffers of SF areas with tree canopy are needed between urban densities that take account of the watersheds as well as just counting acreage. There is no study cited that looks at the future green infrastructure map in comparison with the projections for increasing urban densities and what appropriate policy would integrate them. It is assumed that the Urban Tree Plan protections will suffice, but a new Tree plan is under development to patch recognized deficiencies. The area to the south of 65 Ave NE nearest to the Park is especially important to protect trees to better protect the source of the flow, and to help with storm water management from the city streets.
Ravenna/Bryant has a combined sewer and storm water system which contributes to the CSO overflows and limits the capacity of West Point Sewage treatment plant to function in the new normal of heavier rain storms due to climate change. The city has spent millions of dollars on concrete holding tanks as solutions to this problem, rather than adopting much cheaper Low Impact development methods.
The RBCA board is currently considering these comments and the alternative zoning proposal as part of their review of the MHA DEIS.