Why we had to appeal the SEPA Determination of DNS on MHA/HALA

Because our persistent calls for reasonable livability protections for all downtown residents have been ignored in the rush to pass the Mayor's Housing and Livability Agenda (HALA), we felt like it was our duty to appeal the Determination of Non-Significance (DNS).

First of all, we strongly support efforts to promote and require more affordable housing in Seattle. Many of us individually have and do serve and contribute regularly to local affordable housing organizations, like Compass Housing Alliance, Plymouth Housing, etc.

Second, we want to make it clear that we also support the “funding mechanism”“ of the HALA proposal, but we have big concerns that the land use and development draft legislation will have serious negative consequences on the environment and downtown livability. The City’s failure to adopt residential development standards in zones where residential construction is encouraged will exacerbate a “growing problem” of tower overcrowding.

The HALA team deserves thanks for supporting Option 2 to add equivalent development capacity through additional height rather than the additional 1000 sq. ft. per floor through additional girth in new residential development downtown. However, this alone is not enough to ensure future livability for downtown residents.

We strongly disagree with the DNS Determination. The Director’s SEPA analysis of impacts of the implementation of this legislation lacks serious rigor, misapplies city policy, market influences, and ignores the plain fact that residential development is already greatly incentivized over commercial uses in DOC1 and DOC2 because there are no density limits (FAR restrictions) for residential development as there is for commercial uses.

We want to reiterate our request to include new residential development standards to provide adequate light, air, and privacy in all future projects in the “unprotected” zones of downtown. If you can change the height limits for HALA, which you can, why not also include allowances for equivalent square footage in additional height in certain zones to solve alley congestion issues and tower separation issues affecting light, air, and privacy at the same time [with tower spacing, alley setback, minimum lot size, max lot coverage, etc.].


We strongly disagree with the claim that there are not enough potentially affected parcels (parking lots/obvious teardowns, etc.)  to warrant including these provisions. For example, even if we were to accept (and we don’t) that there are only nine re-developable parcels in the affected zones, this would still potentially produce 5.5 million square feet of new mixed use/residential development, or the equivalent of as many as 3,600 new residential units, thus affecting at least 10,000 persons in total. Is this not enough to be “concerned" about the growing problem created by the city’s flawed land use code and review process?

Often, the city passes code amendments to satisfy just one or two developers’ speculative goals. If nine parcels are not enough for the city to take the downtown residents issue more seriously, then what is enough? Quite frankly, one parcel is too many when the physical and emotional health of individuals is affected by the lack of light, air, and privacy. Who knows if something that is not considered a teardown today might be in a few years? Look at Escala and the properties right across its alley in the early 2000s, when the City failed to take action there because “nothing was likely to happen residentially” …and now look at it.

The City has done part of the job. Now they need to finish it with legislation that will do it all...PUT THE "L" IN HALA by protecting downtown livability, without reducing development capacity, and provide the funding for HALA.