Why should downtown towers be exempt from transportation mitigation?

Mayor Durkan, PLUZ Committee Chair Johnson and members of the Seattle city government,


Council Bill 119398, seeks to change the Transportation Concurrency Level of Service (LOS) standard perhaps because a balanced ‘traffic volume-to-street capacity’ standard can no longer be met.  The new standard replaces quantifiable traffic measurements from new development and replaces it with a simple goal to reduce the number of Single Occupancy Vehicles (SOV) trips across the city. 


The bill requires small and mid size new development in traditional residential neighborhoods to comply with transportation mitigation measures.  But it specifically exempts downtown towers from requiring any mitigation.  It assumes downtown towers will not have significant transportation impacts and have complied with any mitigation requirements solely because they're close to non-SOV transit options.


Nothing could be further from the truth.  This bill may be adequate for the rest of the city but it fails to address downtown gridlock and irresponsibly denies the impact of planned tower density.


Attached is a map of 12 new and proposed downtown developments, 11 of them towers that will feed into Virginia St. for four blocks on either side of the street.  Altogether they will bring 6,500 new residents, 2,500 new parking stalls and well over 10,000 new daily vehicle trips from tower residents, office workers and maintenance and delivery people to this concentrated area.


Just one tower at 2000-3rd Ave. will generate 1,310 vehicle trips a day coming and going from the alley.  The current Transportation Concurrency LOS standard required the project to evaluate existing traffic performance levels and traffic levels projected once 2000-3rd and nearby projects are completed. 


2000-3rd’s traffic analysis failed to include projected impacts from a new tower 60' away on its own alley and one across the street but either way the outlook is grim. To paraphrase the conclusion; ‘traffic is bad now and will continue to be bad so no need to fix anything.’  Or specifically:


"The evaluated screen-lines would all continue to operate below the concurrency threshold with construction of the project.  As a result, no concurrency-related mitigation is warranted or required for the project."  (see attachment for 2000-3rd Traffic Impact)


A traffic crisis is looming. Now isn't the time to abandon quantifiable LOS concurrency standards and give a free pass to downtown towers and hope everything works out. 


We expect our City Council to take congestion and the public’s concerns seriously.  Please answer these basic questions on CB119398:


1)     What research supports the premise that downtown towers will not add to SOV traffic?

2)     How will non-SOV impacts be measured and mitigated downtown? This includes the rising number of Uber trips and the doubling of package deliveries to the core. These growing rapidly even without the population explosion new towers will bring.

3)     Will the scaled-back Move Seattle levy provide enough transit capacity to sustain increased density and demand for transit service to downtown?


This bill also paves the way to streamline the SEPA process for downtown tower approval.  Proposed legislation related to CB119398 assigns downtown towers a SEPA Threshold Determination of Non-Significance (DNS). It automatically assumes downtown towers will not have a significant adverse impact upon the environment. 


1)     If a downtown tower is considered in compliance with the new LOS Concurrency standard does that mean its transportation impacts can't be challenged at SEPA?

2)     Do SDCI, SDOT and the City Council believe there will be significant adverse impacts from the cumulative congestion coming from the tower blocks adjacent to Virginia St.?  If so, how will these impacts be addressed if CB119398 says urban towers don't require mitigation?

3)     At the Dec. 5th PLUZ meeting it was said Transportation Impact Analysis’ (TIAs) may still be prepared for new towers.  Will TIAs be required and what info will they provide?  If a future TIA shows traffic volume to street capacity that’s off the charts, (such as the case for 2000-3rd Ave.) what relevance would that information have to the project’s approval?

4)     The goal of the new LOS concurrency standard is a reduction in SOV levels across a wide area of downtown, Lake Union and west Capitol Hill.  It will be measured with data supplied by a voluntary household survey conducted every two years by the Puget Sound Regional Council.  Does the PLUZ think this is an adequate measure and relevant to the traffic situation brewing downtown? 


There appears to be a deep belief in City government that tower fees and the increased tax base they represent will solve Seattle's affordable housing and transportation woes.  This view overlooks the impacts of tower density.  If not mitigated their costs will exceed perceived benefits and threaten downtown's safety and ability to function.


We await your answers to these questions on CB119398.  LOS standards should require new downtown towers mitigate their impacts on transportation concurrency.  We need legislation that provides a realistic framework to assess responsible development everywhere in the city and especially downtown.


Please add these comments and attachments as part of the public record for the following tower projects: #3033067/#3033057,  #3023025, #3023678, #3026416, #3025502, #3018037, #3019699, #3028017, #3026266, #3032531, #3028428.


Thank you for your consideration.


Megan Kruse


Please refer to the link and attachments below for supporting documentation.

Project portal for 2000-3rd Ave. with Transportation Impact Analysis 

Director’s rule on Transportation Concurrency LOS standards

Comments on Proposed LOS standards