The City Planning Department recently released its EIS Scoping Report. This document contained surprising, disturbing guidance for the Hospital, plus the results of the public comment period. Highlights:
1) The City encourages the Hospital to consider growing outside its existing institutional boundaries
The City tells the hospital to consider four alternatives, including "No Action," and the two existing proposals. For Alternative #4, the Hospital
"...should consider...spreading beyond the existing boundaries if acquiring land for development appears to be feasible."
This is an astonishing recommendation given that Seattle's Comprehensive Plan and Land Use Code both clearly "discourage the expansion of established major institution boundaries" (Comprehensive Plan, LU 186, SMC 23.69.002.E).
There is no question that the Hospital is actively seeking to expand its institutional boundaries. In fact, the Hospital is actively trying to gobble up 136 units of moderately-priced housing at Laurelon. The City should be red-flagging this behavior, not encouraging it.
We can only hope that the Hospital takes the City's words in the spirit of the Code and hears them as guidance to develop a second, in-patient site.
2) Considering a slate of massive proposals is A-okay
According to the City, the Hospital should consider only proposals that achieve the Hospital's objective of adding 500-600 beds at the Laurelhurst site:
"In identifying reasonable alternatives, the SEPA requirement is: “Reasonable alternatives shall include actions that could feasibly attain or approximate a proposal's objectives, but at a lower environmental cost or decreased level of environmental degradation.” (SMC 25.05.044 D.2) Evaluating an alternative with substantially less development ... would not attain or approximate the objective Children’s has defined."
Note, of course, that SEPA certainly does not exclude the consideration of smaller proposals. CAC may wish to point this out as it pushes the Hospital to consider real alternatives.
3) The City received an exceptionally large number of comments during the scoping period.
Compare the result of this comment period with the recent comment period for the 520 bridge replacement. The 520 bridge generated only about 6 or 7 times as many comments as the hospital project.
Wow. On a daily basis, the 520 bridge affects far more people than the Hospital. Furthermore, the 520 comment period was heavily covered in the news, lasted almost twice as long and drew comments from a wide geographic area. It also addressed a real EIS, not just a plan for an EIS. Compare:
520 Bridge Replacement
- Focus: An actual, draft EIS covering real alternatives.
- Duration: 74 days during the late summer and fall.
- Public communication: 2 public meetings during the comment period. 31 outreach events at fairs and festivals, plus heavy media coverage by all outlets, occurred during and before the comment period.
- Result: 1734 unique submissions from the greater metropolitan area, across the state and even abroad.
- Focus: EIS scoping, not an actual EIS
- Duration: 42 days. All comment occurred during summer months, when many families were preoccupied with kids out of school.
- Public Communication: One public meeting on EIS scope held on day 17.
- Result: 257 unique submissions.
"The majority of the comments were in opposition to the height or size of the planned development. Many also expressed opposition to new entrances to the main campus from either NE 45th Street or NE 50th Street."
4) Another 30-day comment period will follow the publication of the Draft EIS in March 2008.
(Update: Added a clarifying sentence at the end of Section #1 after receiving a question.)