Actions Needed:
1. Submit comments on the Draft Environmental Impact Statement (EIS) to Scott Ringgold, City Planner
2. Attend the Public Forum for the EIS. July 10, 6-8 p.m. - Center for Urban Horticulture
Participation Brings Influence.

Saturday, October 27, 2007

Community Response to the City's EIS Planning Report

It's time to study up for the pre-Halloween CAC Meeting and review the Laurelhurst Community Club's blistering evaluation of the Department of Planning and Development (DPD)'s EIS Scope Report.

Land Use Planner Carol Eychaner explains that the DPD is out of line to conclude that the Hospital (CHRMC) can disregard the bulk of the alternatives proposed by the LCC. (Note that the Citizen's Advisory Council (CAC) voted unanimously to encourage the Hospital to consider these alternatives in its EIS.) Furthermore, Carol says that the DPD provides such "ambiguous direction" for the Hospital's EIS scope that the "DPD abdicates to CHRMC its role and responsibility as lead agency under SEPA. "

She concludes:

“…DPD’s decision to severely limit the master plan EIS alternatives and reject reasonable design alternatives that address significant impacts, is fundamentally flawed. Pursuing nearly identical, look-alike alternatives, all with very significant impacts, does not enable the SEPA process, but instead frustrates the public’s, CAC’s and the decision-makers’ ability to analyze development and mitigation options for the CHRMC site.”

Carol's report deserves a careful read. Only a few points are excerpted here:

“In its October 12 letter, DPD states that it will not revise its EIS scoping report to include any of the LCC alternatives in their entirety. DPD also refused to explore most of LCC’s specific design parameters that were not already part of CHRMC’s proposals, including, importantly, LCC’s restrictions on roadways in the landscaped perimeter buffers and on vehicle entrances to the campus (no new entrance points), LCC’s lower MIO heights, and LCC’s alternative rezone of the Hartman property. While DPD has required an alternative(s) with “lower overall height,” it did not specify any MIO height to be studied and provided no guidance as to how much lower the alternative should be, leaving this decision to CHRMC. As described in more detail on the following pages, DPD’s response to CAC’s recommendation, and rejection of LCC alternatives, is fundamentally flawed:

  • It incorrectly characterizes the development potential in LCC’s alternatives.
  • It is based on ambiguous and unsubstantiated conclusionary statements.
  • It shirks its authority and responsibility under SEPA to require reasonable design alternatives that would reduce environmental degradation, especially for significant impacts.
  • It encourages the development of nearly identical, so-called alternatives.
  • It inappropriately abdicates the design of alternatives to CHRMC, providing little direction as to the required design parameters of the alternatives."
Carol goes on to provide detailed support for all of these points. For example, she shows that DPD is incorrect to claim that LCC’s proposal would limit new development to 250,000 square feet. Quite to the contrary-- multiple LCC alternatives lack a square footage limit. Her analysis indicates that square footage increases could range from 636,000 to almost one million square feet under different design parameters. Make sure to read the rest of Carol's report.