By Joan Bloom
October 29, 2024
Council,
Herrera Environmental Consultants, Inc has failed to comply with SEPA requirements as outlined in the Washington Administrative Code in their submitted DEIS. If Council accepts this “woefully inadequate” DEIS and uses it to inform their decisions about the Comp Plan, Council will fail ALL Edmonds’ taxpayers.
I agree completely with Edmonds Environmental Council’s October 28, 2024 email:
DEIS is Inadequate to INFORM City Council on Comp. Plan Update Decisions
EEC states “The DEIS and the process leading to the development of the DEIS do not conform with State SEPA requirements.” EEC then references numerous unmet WAC requirements.
I agree that “This DEIS is woefully INADEQUATE in environmental ANALYSIS and measures to minimize adverse impacts of increased housing.”
My comments on Herrara’s DEIS:
(1) I can find NO reference to 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. See our Critical Areas Ordinance for allowed uses in seismic hazard areas: https://edmonds.municipal.codes/ECDC/23.80
There is also no reference in the DEIS to the Tsunami zone at the waterfront.
(2) Despite “allowed uses” in Seismic Hazard areas listed in Edmonds CAO, the “Waterfront Activity Center” is identified in the Draft Comp Plan as allowing “Mixed Use Residential.”
The Draft Comp Plan proposes housing directly on, or very near:
- An extensive Seismic Hazard Area
- A Tsunami zone.
- A Flood Plain (deemed 100 year but now frequently flooded)
- Rising tides due to climate change
Imagine the cost to build, and the cost to INSURE, any dwellings built at the waterfront. But more importantly, why would Edmonds City Council risk the health and safety of those who would live in “Mixed Use Residential” at the Waterfront?
(3) The statement: “Continue to comply with development standards related to Critical Areas and Storm water management,” is seen throughout the DEIS.
Edmonds administrations have failed to enforce our Critical Areas Ordinance for at least two decades, resulting in enumerable infrastructure issues. The DEIS assumption of CONTINUED compliance with “Critical Areas and Storm water management” is further proof that this DEIS is “woefully inadequate.”
Edmonds Environmental Council represents a large group of well informed taxpayers. Council should listen to their warnings of basing Comp Plan decisions upon this DEIS. Please extend the review of the draft Comp Plan until you have received WAC compliant recommendations regarding mitigation of environmental damage.
Council, if you do not require another DEIS from Herrara, please extend public comment on the draft Comp Plan for an additional month (to December 4) beyond the November 4 deadline.
Respectfully,
Joan Bloom
Edmonds is a gift. Let’s show our appreciation.