RE: Draft Shoreline Master Program
Dear Chairman Horn and Members of the Olympia Planning Commission:
I am writing this letter on behalf of myself[1] and Olympia 2012, an organization dedicated to promoting the further development of Olympia’s Downtown that is environmentally and economically sustainable. We appreciate the time and energy the staff and the Planning Commission, especially Commission’s Shoreline Master Program subcommittee, devoted to preparing this draft document. 2012’s members, including myself, attended several of this subcommittee’s meetings.
We have the following questions and concerns:
Setbacks – From our attendance at the Shoreline Subcommittee meeting, we understand that staff is recommending setback of 30 feet in the Urban Intensity designation as a placeholder while they conduct studies to evaluate various methods of protecting Downtown from the impacts of sea level rise, including building a berm. We applaud the City’s efforts to proactively address sea level rise and undertaking the study. Nevertheless, we wonder if imposing setback of 30 feet in the Urban Intensity designation (page 59) is premature before the study is complete since the impact of this requirement would make some of current structures that house some of Olympia’s best loved water enjoyment and water dependent uses nonconforming and would limit their expansion. We suggest that you wait until the study is finished, before you impose this requirement that has significant impacts.
We are also concerned that mixed used buildings need to be setback 40 feet from the Ordinary High Water Mark (OHWM ). (Policy 6.7.4.B, page 67) While we support public access and shoreline restoration, we do not believe that a mixed used project containing a mix of commercial and residential causes more environmental impacts than residential buildings and buildings that house water dependent and water enjoyment uses. Some of the commercial uses could include some water enjoyment uses. Also, some commercial uses that are not water dependent add interest to the waterfront experience. For instance, along Portland’s waterfront promenade on the Columbia River, shops selling ice cream, candy, kites, and biking gear make the waterfront pedestrian’s experience more interesting and attract people to the waterfront. This policy needs clarification so it does not apply to desirable mixed use projects or restrict commercial uses that enhance the waterfront pedestrian’s experience. We have similar concerns about Policy 6.7.1 B, page 65.
Heights in the Urban Intensity Zone – We support allowing building heights of 65 feet for buildings that are more than 100 feet from the OHWM. (page 58). However, we also support heights of 65 feet for buildings that are within 100 feet of the OHWM. We would like to understand the rationale for not allowing taller buildings in this area of the Shoreline. Studies done previously by City pointed out that buildings must be at least five stories to include structured parking. If the reasons for not allowing buildings of more than 42 feet are aesthetic in this part of the Shoreline, we believe these shorter buildings would be less aesthetically pleasing as they most likely would include surface parking closer to the waterfront – a poor use of land anywhere but especially here where the waterfront and the amenities built along the waterfront have the ability to attract the density the City plan says we want.
Further, buildings of 65 feet also allow more units to be built in the downtown, especially in this area most likely to attract residents to the Downtown. Maximizing housing in this area would help achieve the City’s housing, transportation, and economic development goals and would not be inconsistent with Shoreline Master Program guidelines.
View Protection – We are unsure about the intent, effect, and consistency of the Figure 5.1 Key View Corridors (page 51) Policy 5.4.1 (page 34) Policy 5.10.2 A and B ( page 48) and Policy 6.10.2 F (page 72). Policy 5.4.1 A states, “Existing public access should be protected and maintained so the public may continue to enjoy the physical and aesthetic qualities of the shoreline.” Does this mean that entire view corridors must be preserved as they exist today? We support preserving existing public access and the policies and regulations in this section seem to be designed to do that. Because the rest of this section deals with actual physical public access to the shoreline, it is not necessary to include “view corridors” here.
The draft SMP defines Urban Intensity Designation’s purpose (page 29) “to provide for high-intensity water-orientated commercial, transportation, industrial and high density residential (emphasis added) uses .. .” We are concerned that the intent of these policies and regulations are not clear and the interpretation of Policy 5.4.1 A, Regulations 5.10.2 A and 6.10.2 F combined with the View Corridor maps could work against this purpose. If the intent of the View Corridors’ map and these policies is to limit the heights to 35 feet or prohibit development altogether on vacant or undeveloped properties in the Urban Intensity designation or near the Urban Intensity designation, we fear that some of these properties in these areas will remain in their current derelict state or will do little to provide for the amount and range of housing choices needed for a vibrant downtown, to reverse urban sprawl and to make alternatives to single person auto trips more feasible. Also, if the intent of these policies is to limit buildings in this designation to 35 feet or prohibit altogether, it severely limits the City’s ability capitalize on the investment it has made in Percival Landing and the City and State’s investment in Heritage Park. The City of Olympia has lagged behind other cities in Thurston County in adding to its tax base. Anti density and anti development policies will exacerbate the City’s ability to fund key infrastructure in its capital facilities plan.
Or if these policies are just unclear, then every future development proposal will be contentious. This kind of process creates uncertainty and acts as a major deterrent to development in the Downtown. We hope that this is not an attempt to impose process costs on potential builders with no prospect of sustaining the restriction
Dredging – Regulation 7.4.3 (page 82) prohibits dredging in the Urban Conservancy designation unless it is part of an approved restoration project or program. We are concerned that such a provision could prohibit the dredging of Capital Lake to maintain it as a lake. See description of restoration 7.7 on page 91.
We also think that the proposed dredging provisions would cripple the operations of the Port of Olympia, Fiddlehead Marina, the Yacht Club and other key water related activities. The dredging permit process is regulated by the Corps of Engineers and other entities that carefully review environmental issues related to dredging. A blanket prohibition of dredging to maintain recreational and commercial enterprises on the waterfront will have significant economic impact eliminating many family wage jobs. There has been no analysis of the impact of this provision.
Failure to Coordinate with Port Plan. The City’s previous planning documents have incorporated the Port’s Plan (that was the result of a public planning process). The citizens and taxpayers of Thurston County have a significant investment in the Port’s plan. The Port has begun to make a profit and continues to provide family wage jobs with good benefits to skilled blue collar workers. Much of the interesting and well used development such as the Farmer’s Market, Anthony’s, the Hearthfire, and development across the street from the Farmer’s Market has taken place on Port property. The Port has also continued to undertake significant environmental cleanup projects. The City has not analyzed how this proposed SMP will impact the Port’s ability to operate and continue its cleanup efforts.
Consistency with the rest of Olympia’s comprehensive plan - The Shoreline Master Program is an element of Olympia comprehensive plan. Not only must it be coordinated, it must be consistent with the comprehensive plan. This should be made clear in Policy 1.2 G (page 2). See RCW 36.70A.480 and RCW 36.70A.070.
Lack of an Environmental and Economic Impact Analysis -We are also concerned that no draft environmental statement has been prepared for this plan. Without it, it is difficult to discern the analysis of the issues or the rationale for some of the policy and regulation choices. In addition, the proposed plan is full of changes that will have significant economic and operational impact on the Port (a county wide taxing district), downtown businesses, the potential for housing and the overall vitality of downtown.
Thank you for considering our comments. Please enter them into the record on this matter.
Sincerely,
Holly Gadbaw
1625 Sylvester Street
Olympia, WA 98501
[1] I am a former mayor (1988 -1990) and member of the Olympia City Council from 1982-2001. I worked as a land use planner for the Washington Department of Community, Trade and Economic Development’s Growth Management Program (1990 -2003) and served as the head of their comprehensive plan review team. I served as a member of the Western Washington Growth Management Hearings Board from 2003-2008.
