November 11,2024
By Joan Bloom
Council,
Council, the final Comp Plan will affect Edmonds for 20 years to come. I beg you to consider all of the concerns that so many respected and involved long term residents of Edmonds have presented to you. Please do not ignore the serious concerns that have been expressed.
I urge Council to (1) request an extension from the Department of Commerce to complete our draft Comprehensive Plan, (2) Revisit CM Dotsch’s proposal of “a new Uptown Town Center that is based on the council’s strategic decision made in 2017 to site planned growth along the Highway 99 corridor,” and (3) Establish a new category of “Environmentally Sensitive” zoning in the Comp Plan update as proposed by Joe Scordino, for the following reasons:Salmon Restoration
(1) Former Director McLaughlin’s draft Comp Plan, was NOT based on our current Comp Plan. It was a complete re-write. This disturbing re-write failed to address critical issues:
- It did not include a stormwater assessment in the land use element as required.
- The utility element refers to the 2010 stormwater plan and the CIP/CFP. The 2010 plan did not reflect the type or rate of growth now under consideration.
- The proposed housing will result in excessive damage to our environmental assets, including our watersheds, wetlands, steep slopes, critical aquifer recharge areas, and the entire waterfront area.
(2) The Draft Environmental Impact Study provided NO guidance about how to mitigate environmental damage. Section 1.2 of the DEIS stated: “A non-project EIS does not provide site specific detailed analysis.” The Planning Board was misled by staff and believed the DEIS would provide information to assess “worst and best case scenarios for mitigation measures.”
- Because McLaughlin requested a “non-project EIS”, Herrera Environmental Consultants, Inc produced a “woefully inadequate” DEIS that failed to comply with SEPA requirements as outlined in the Washington Administrative Code in their submitted DEIS.
- The DEIS was supposed to be completed and presented for review in March, but was not available until many months later.
- Comments gathered on the DEIS, which Herrara is supposed to integrate into the final DEIS, will likely result in minimal, if any, guidance from Herrara for mitigating damage to the environment.
- The entire DEIS assumes continued compliance with CAO, despite that Edmonds’ administrations, for the past 20 years, have failed to enforce our CAO. They have consistently favored development over protection of Critical Areas.
(3) The Waterfront Activity Center is home to a huge Seismic Hazard Area, a Tsunami zone, a 100 year flood plan, rising tides, and blockage of the Waterfront by train passage. Despite these serious environmental factors, the draft Comp Plan proposes “Mixed Use Residential,” “Master Plan Development,” and “Downtown Master Plan” all in the Waterfront Activity Center.
- The DEIS doesn’t even reference the documented seismic hazard area that encompasses the Marsh, Harbor Square, Salish Crossing, extends along Sunset Ave Walkway, tapering to a point along the shoreline north of where the walkway ends. Our Critical Areas Ordinance states the following allowed uses in seismic hazard areas:
https://edmonds.municipal.codes/ECDC/23.80
B. Seismic Hazard Areas. The following activities are allowed within seismic hazard areas:
1. Construction of new buildings with less than 2,500 square feet of floor area or roof area, whichever is greater, and which are not residential structures or used as places of employment or public assembly;
2. Additions to existing single-story residences that are 250 square feet or less; and
3. Installation of fences. [Ord. 4314 § 105 (Exh. A), 2023; Ord. 4026 § 1 (Att. A), 2016; Ord. 3527 § 2, 2004].
- Our Critical Areas Ordinance does not allow “residential structures” within seismic hazard areas.
- Our CAO does not allow “places of employment or public assembly” within seismic hazard areas.
- The Waterfront Center is a place of “public assembly” yet it was built in a seismic hazard area. Salish Crossing, with an art museum where the public assembles, was built in a seismic hazard area. These are blatant examples of past administrations failure to enforce our CAO.
(4) If housing (Mixed Use Residential) is allowed in the Waterfront Activity Center, the cost to build, and the cost to insure the buildings, if they can even be insured, will be so high that the cost to live in the buildings will be prohibitive.
(5) Goal H-1. Enable diverse housing types for people of all economic and demographic backgrounds.
- This goal in McLaughlin’s draft plan gives lip service to providing supposedly affordable housing, yet ALL of the proposed housing will be MARKET RATE.
- No information is provided as to how these “diverse housing types” will be enabled. What is meant by “enable”? This type of vague language is rampant in the draft plan.
(6) The draft Comp Plan does not address required infrastructure to support the proposed housing. To quote John Zipper:
“It should be obvious to anybody looking at the locations of the planned “hubs and centers” that road and sewer improvements, attempted “mitigation” of the stormwater/erosion impacts on our watersheds (especially Shell Creek and Perrinville Creek), construction impacts for the next 20 years or so, and traffic LOS impacts will all require that the City spend money as mitigation. Increased property taxes and utility rates for all of Edmonds will be needed to pay for the infrastructure improvements.”
Edmonds property owners and stakeholders will pay dearly for the proposed housing. Developers will benefit to the determent of those least able to afford to continue to live, or wish to live, in Edmonds.
Please seriously consider all of the above.
Respectfully,
Joan Bloom
Edmonds is a gift. Let’s show our appreciation