The letter below, from City Councilmember Lisa Herbold, was sent to me here at Wallyhood unsolicited. Although Herbold represents District 1 which includes West Seattle and southwest Seattle, the issue she addresses here — the amount of parking required for new housing developments — has been hotly debated in the comments and forums here and throughout the neighborhood more generally. For that reason, we’re bending our usual rule, about content needing to be neighborhood-centric, to bring you this perspective.
On Monday, the City Council will take up Council Bill 119173 which was passed out of the Planning, Land Use and Zoning (PLUZ) committee on March 21. This bill seeks to change the parking requirements for new housing developments. An excellent, detailed discussion of this bill can be found here at SCC Insight. According to SCC,
The bill, inspired by a HALA recommendation, does several things:
- it forces parking to be rented or leased separately from housing or commercial space in buildings above a certain size;
- it allows for off-street private parking to be handled more flexibly, including allowing excess parking spaces in a residential building to be used as paid “flexible use” parking available to non-residents of the property;
- it rewrites the definition of “frequent transit” as it applies to areas where the minimum parking requirements for new developments are removed (because of close proximity to frequent transit service);
- it expands the distance that off-site parking can be from a use;
- it adjusts parking requirements for affordable dwelling units;
- it limits exceptions to maximum parking requirements.
While the bill contains a mixed bag of recommendations, some residents fear that the overall effect would be to require developers to provide even less parking than they are currently required to. Herbold believes that some of these changes need a little tweaking.
“To insert a little common sense,” as she puts it, Herbold plans to introduce amendments to the bill which, she believes, are grounded in requirements put forth in the State Environmental Policy Act (SEPA). Finally, the SDCI which she refers to is the Seattle Department of Construction and Inspection which handles building permits and, obviously, inspections, and is thus in a position to enforce compliance with these City rules.
Email from Councilmember Lisa Herbold
I’m writing to you today regarding legislation before the City Council to expand the areas throughout the city where developers, because of legislation passed in 2012, can build projects with reduced or no parking. To get a quick overview, here is a piece SCC wrote about the topic as well as my blog post, here.
As you’re likely aware, the PLUZ committee voted this parking legislation out of committee last Wednesday. But as the Council expands the areas throughout the city where developers can build projects with reduced or no parking (because of legislation passed in 2012), I’m trying to insert a little common sense, based upon data that others, I think, may not be considering, based also upon the lived experienced of people living all over the city.
I have attached two constituent letters signed by folks in neighborhoods throughout the City to pass on their perspective. I am contacting you because two of the signers of this letter Donn Cave and Susanna Lin are residents of the community that your blog covers. Since the signer, is a resident of your neighborhood beat, and they are writing about an issue that impacts your readers, I thought I’d ask you to consider writing about the issue, as well as my proposed amendment. Donn and Susanna are copied here on this correspondence so that you can get in touch.[Author’s note: While addressed to me, this email actually came to me through our writer Susanna Lin who, along with Donn Cave, another Wallingford resident, and several other City residents, had twice written to City Council President Bruce Harrell outlining their objections to Council Bill 119173. These are the “constituent letters” referred to. I have linked to them here and here.]
A quick description of my amendment that I will be bringing to the 2pm Full Council meeting on Monday April 2:
Allow (not require) SDCI to mitigate parking impacts in urban villages with frequent transit service, where no parking is required in developments, in locations where on-street parking occupancy exceeds or would exceed 85%, this is the capacity threshold that both SDCI and SDOT use.
State SEPA policies require consideration of parking impacts. However, the City has entirely removed the authority to mitigate the parking impacts of projects that have impacts when those projects are in areas where the City has removed parking requirements, areas referred to as “Frequent Transit Areas.” In other words, State SEPA is requiring developers to do parking studies as part of the permitting process, but even when those studies show that a development without parking is going to create a problem, SDCI can’t require mitigation. In those instances this is what SDCI tells (see the attached email for an example) the public:
“while impacts to parking could be substantial, we are unable to mitigate the impacts by requiring additional parking on-site.”
The spokesperson for SDCI has been quoted by the press saying “[W]e have said that when on-street parking capacity exceeds 85 percent, finding parking becomes more difficult, and parking mitigation (in areas where we have authority to mitigate parking impacts) may be appropriate.” But again, SDCI does not have the authority to mitigate on-street parking impacts in Frequent Transit Areas.
Some say that SEPA should only mitigate for environmental impacts. However, the reality of SEPA in Washington State is that it requires us to look not only at the impact of decisions on plants and animals, air quality, and water; but also on housing, public services, and historic preservation. The state requires that we look at parking as part of that comprehensive analysis of impacts of development. Also, Seattle is the city that is 5th in the nation for time spent in a car looking for parking. I think that’s an environmental impact.
Other opponents of my amendment have referred to it as an “exemption” to the parking reductions. Again, it is not an exemption because it does not obligate SDCI to require mitigation, it only gives them the flexibility to do so under some very, very narrow conditions. Additionally, mitigation under SEPA may include, but is not limited to
- transportation management programs,
- parking management and allocation plans,
- incentives for use of alternatives to single occupancy vehicles, such as transit pass subsidies, parking fees, subsidies for participation in car share or bike share programs or similar mobility choice programs, and provisions of bicycle parking space,
- increased parking ratios, and
- reduction in non-residential development densities.
As you can see, while increasing parking is one of the available tools, SDCI has many tools to mitigate parking impacts in a number of different ways.
I also asked central staff to look into the impacts this amendment might have. They found that last year, of 136 projects, only 6 were projects in areas at 85% parking capacity. Of those 6, 3 projects provided some amount of parking – meaning SDCI would be unlikely to require mitigation in those instances even if they had the authority to do so. So, if last year is typical, then over the course of a year, maybe 2% of projects would be impacted by the amendment I propose.
In general, I have a problem with a one size fits all strategy. But, in the specifics there are lots of bad conclusions – without good data to support them – being reached with this policy:
1) There is lots of unused parking capacity throughout the city because people are getting rid of their cars.
They have demonstrated that this is the case in a couple neighborhoods, but it doesn’t track to the areas designated as “frequent transit areas.” This map shows quartiles of renters by census tracts and the numbers are the percentages of households that do not have a vehicle. Finally, this map overlays the two previous maps to give a clearer picture of where new frequent transit service will be in comparison to renters as well as car owners. The significance of these maps is to show that the oft reported statistic, that is being used as the policy basis for this legislation is misleading. The SDCI Director’s report says that “For the one-quarter of Seattle census tracts with the highest proportion of renter households, 40% of all renter households have no vehicle.” For instance, in the Freemont urban village there are car ownership rates of 83% and 92%, but no parking minimum in the urban village and a 50% reduction outside of the urban village. Additionally, in the Wallingford urban village there is a car ownership rate of 79%, and again, no parking minimum.
2) Access to, and use of, good transit results in less car ownership.
There are no Seattle studies that support this conclusion. Again, the law that allows developers to build projects with reduced or no parking passed in 2012, car ownership in Seattle has remained pretty flat since that time.
Another interesting objective of this bill that has been revealed to me in the debates in committee on this topic is that the goal is not just to get people to drive less – which as a bus commuter, I whole-heartedly support – but to not own vehicles at all because vehicles take up space that can otherwise be used for living. Though Seattle Household Median Income is about $90K a year, more than half of our population earns less than that, and nearly 70% of renters earn less than the Seattle median income. The point being, is it good public policy to make car-ownership difficult for people who need their cars (because they are already struggling financially and the car plays some useful role in their lives – either because a car is a job requirement or other reason) in the hopes that in our making their already difficult lives more difficult we will make them get rid of their cars?
I hope that you consider covering this issue in your publication by Monday morning if you haven’t already.
District 1 Councilmember
The above email from Herbold came with two other emails in the chain. These are alluded to by Herbold in her email. I reproduce them here because I feel it offers the rest of us a “view from the trenches” when average citizens try to interact with the Seattle bureaucracy. In the first email, Timothy Boyd tries to offer up his opinions on a housing development going in near him. The second email is the City’s response. (At Boyd’s request, I have redacted his contact info.)
Email from Resident Timothy Boyd
From: Timothy Boyd [[email protected]]
Sent: Wednesday, August 23, 2017 3:25 PM
To: PRC <[email protected] <mailto:[email protected]> >; Herbold, Lisa <[email protected] <mailto:[email protected]> >
Subject: Single Family Neighborhood Apartment-Barton Street, West Seattle
Hello Neighborhood Planner!
The neighborhood review is coming up for the 66 unit complex proposed for our single family neighborhood. Since the proposed building represents a 17-fold population increase from the current complex, I, along with every neighbor on our street have serious concerns about the additional traffic and pressure that will be put onto the parking situation in our diverse and already dense neighborhood.
After attending the last design review meeting we learned that that meeting is not the venue for discussing these matters, so please let me know what venue, time, place, paperwork, office, etc. we need to contact in order to raise our concerns!
Thank you for your help on this matter!
Response from City of Seattle
———- Forwarded message ———-
From: “Guillory, Carly” <[email protected]>
To: ” [email protected]ail.com ” < [email protected] >
Cc: “Herbold, Lisa” <[email protected]>
Date: Thu, 24 Aug 2017 15:53:32 +0000
Subject: FW: Single Family Neighborhood Apartment-Barton Street, West Seattle-3024558
Thank you for your email.
Yes, the authority of the Design Review Board is limited to evaluating the design of the structure and providing guidance, while environmental impacts, such as transportation, parking, or construction impacts, are evaluated by staff. So, the place to submit your comments is here, to [email protected] or straight to me at [email protected]. Staff reviews all comments and evaluates the application documentation against city codes and policies.
You can find all application documents, such as the traffic study, here. As you’ll see, the applicant conducted an on-street parking utilization analysis and estimates that during peak residential demand times, there will be a future parking utilization rate of 40% (counting this project as well as other nearby projects currently under review), with an average future demand of 173 cars parked in the 434 spaces available within 800-ft of the site. Should you have specific questions about the traffic documentation, we can loop in our SDCI Transportation Planner, Michael Houston, to answer those questions. Important to note is that our environmental regulations (SEPA), do not allow for mitigation to parking impacts for development within an urban village at least 1,320-ft from a street with frequent transit service. So, while impacts to parking could be substantial, we are unable to mitigate the impacts by requiring additional parking on-site (for example). You can find those regulations in Seattle Municipal Code 25.05.675.M
I hope this information is helpful.
Carly Guillory, Senior Land Use Planner
Seattle Department of Construction and Inspections
700 Fifth Avenue, Seattle, WA 98104