VIDEO: See neighborhood groups’ challenge to HALA’s Mandatory Housing Affordability upzoning plan

6:26 PM: Last Friday, we told you about a citywide coalition of neighborhood groups, including 3 from West Seattle, planning to challenge the city’s plan for HALA (Housing Affordability and Livability Agenda) upzoning, as released with its Final Environmental Impact Statement two weeks ago (this interactive map shows proposed zoning changes). Today, representatives of the more than 20 groups gathered in the City Hall lobby downtown to formally announce the appeal. Here’s our unedited video of the 20-plus-minute event:

The three West Seattle groups participating in the appeal are from three of West Seattle’s four urban villages: Morgan Community Association (Morgan Junction), Junction Neighborhood Organization (West Seattle Junction), and Westwood-Roxhill-Arbor Heights Community Coalition (Westwood-Highland Park). And we have just received the coalition’s official “notice of appeal” document – read it here, or embedded below:

We’ll be reading it in the hours ahead and adding notes; in addition, as mentioned today, several neighborhood groups are pursuing their own individual appeals – those include MoCA and JuNO, as well as some from elsewhere in the city; the city Hearing Examiner‘s files already show four appeals, from Beacon Hill, Wallingford, and Fremont groups, as well as an individual citizen from North Seattle.

From the city side, Councilmember Rob Johnson – whose office has a leadership role in the HALA process as he chairs the Planning, Land Use, and Zoning Committee – has published his reaction to news of the appeals, concluding:

Though Council is prohibited from taking final action during the appeal process, we will continue our planned 8-month outreach and deliberation process so that when the appeal is resolved, we can act quickly to implement a critical strategy that will result in more income and rent-restricted housing and more housing options across our city for people of all incomes.

More later.

ADDED 11:20 PM: We’ve read through the coalition’s 17-page appeal document, and also received the notices of appeal by the two local groups that have also filed their own, JuNO and MoCA. Those documents are after the jump, along with toplines from the coalition appeal if you don’t have the time or inclination to read through the full document:

In general, the argument of the appeal is that the city’s neighborhoods are unique and distinct, and the Final Environmental Impact Statement doesn’t recognize it as such. But first, from the opening paragraphs:

SCALE supports the concept of increased density and supports the broader goal of increasing affordable housing and livability in the City of Seattle. Many members of SCALE have worked for decades with the City to plan for growth productively. They have dedicated countless volunteer hours toward developing, creating and commenting on neighborhood plans, all in the interest of doing density right.

But the City’s approach with the Mandatory Housing Affordability program has been focused purely on increasing housing development capacity, not good land use planning. The City has disregarded numerous existing neighborhood plans and has not engaged in any meaningful, targeted, neighborhood specific planning or collaboration throughout the entire HALA/MHA process. Now we have an FEIS that reinforces this approach. Rather than disclosing and studying the unique impacts to each of the neighborhoods in the study area, the FEIS provides a non-specific summary of the existing environment, impacts, and mitigation for a generic urban village.

The appeal challenges two elements, “adequacy of conditions” and “adequacy of [the] EIS.”

Another excerpt:

It is the mission of SCALE to seek adoption of legislation that would accomplish the goals of increasing affordable housing based on wise land use planning that would promote maintaining all the things that make Seattle a great place to live, including adequate infrastructure (transit, roads, schools, and utilities) and resources essential for a livable community, such as parks, open space, and abundant trees.

….The FEIS … failed to adequately disclose and analyze the significant impacts that the MHA Program will have on SCALE and its members (and) failed to discuss reasonable alternatives that could accommodate the planned growth and generate more rent-assisted housing and affordable housing with less impacts to the quality of life of people who live in the city.

It’s suggested that the city could have done an EIS for each neighborhood. And it alleges that the FEIS doesn’t disclose that the MHA proposal conflicts with the city’s comprehensive plan and multiple neighborhood plans. (This is the subject of separate actions that some neighborhoods are taking, as well as the city – seeking dueling comprehensive-plan amendments to either remove the conflicting conditions in MHA, or the conflicting conditions in the neighborhood plans.)

The appeal also alleges the FEIS doesn’t adequately address a variety of potential impacts, from aesthetics to traffic to trees to noise to pollution, as well as parks, open space, public facilities such as schools, and small businesses.

It also suggests the FEIS is contradictory in spots, such as: “The FEIS claims that the City does not have a threshold for determining significance of tree loss. The FEIS then concludes that the tree loss anticipated as a result of the proposal is not a significant impact.”

Toward the goal of MHA, the appeal suggests there are other ways the affordable-housing goals can be reached, such as “increase in various funding sources, increased incentives in the Incentive Zoning program and other measures (including partnerships with major employers) … could generate more affordable housing, but none of these options is analyzed in detail. Other viable alternatives not analyzed in detail … include the option of directing more growth to the areas of the city with the greatest amount of under-utilized development capacity; providing low-interest loans to small landlords for major maintenance projects in exchange for limits on rent increases; incentivizing homeowners to build mother-in-law apartments or accessory dwelling units (incentives would include forgiving of permitting fees and dedicated staff to help with the permitting process) and phasing in the density increases discussed in the action alternatives so that each area can be evaluated in a finer-grained analysis (as has been done with the University District and lower Queen Anne).”

The appeal also goes into detail about displacement concerns, including saying it “fails to disclose the existing levels of housing losses in the city caused by redevelopment under existing zoning and the extent to which this will increase with any of the action alternatives. (Appeal contends) more homelessness will result.” Meantime, the appeal says, the FEIS acknowledges it’s “possible”that older housing provides more affordable housing than new construction and, that, therefore preservation – not destruction – of “historic” housing may benefit affordability efforts. But the complaint is that’s only mentioned in a discussion of historic resources which in turn doesn’t adequately assess those either, nor the potential for loss.

Another claim: That the assessment doesn’t adequately analyze areas outside of urban villages that are subject to MHA … (contending that) it therefore overlooks a significant percentage of affected areas.

And it alleges “a serious lack of true neighborhood outreach” as well as inadequate response to comments

Bottom line, the relief requested is for the Hearing Examiner to send the FEIS back to the city “with instructions to prepare a Supplemental EIS(s) as necessary to adequately assess the environmental impacts and mitigation for a reasonable range of alternatives, including an assessment of the impacts and potential mitigations that are associated with each individual neighborhood that is impacted by the proposal.”

The Hearing Examiner will set a date for a hearing.

Meanwhile, as mentioned, some of the participating groups are filing their own appeals. Late tonight we received the documents for those filed by the two West Seattle groups who have chosen to do so. We are working on a separate followup about the WS-specific concerns, but meantime, in case you’d like to read the documents for yourself, here they are. First, from JuNO – PDF here, or embedded below:

And from MoCA – PDF here, or embedded below:

If you haven’t browsed the Final EIS already, you can find it here.

12 Replies to "VIDEO: See neighborhood groups' challenge to HALA's Mandatory Housing Affordability upzoning plan"

  • Matt November 27, 2017 (11:00 pm)

    The city must have seen this coming because they planned dozens of hearings, open houses, etc, over the next year while this mess gets sorted out, so there’s no excuse that you didn’t have time to comment. 

  • CAM November 28, 2017 (6:33 am)

    It really seems odd to me that JuNO and MJCA continue to bill themselves as representing the community when the vast majority of people in those areas do not attend the meetings, for a variety of reasons. What outreach have they done to residents in the area requesting feedback on their actions regarding this issue or any other? Have they attempted to survey residents to get a broader perspective of people’s opinions? Have they gone door to door asking questions? If the only feedback they are getting is from those who are able to attend their meetings then how can they say they represent the communities? The neighborhood council’s seem to have more resemblance to special interest groups at this point than to groups truly attempting to represent the opinions of community members. Maybe that is how it always has been but it’s still discouraging to see. 

    • dhg November 28, 2017 (10:32 am)

      The meetings are open.  Can’t make it? Write or call and make your voice heard.  Democracy depends on people getting their voices heard, not on waiting to be polled.

  • CMT November 28, 2017 (9:38 am)

    I know JuNO did a comprehensive analysis of all Junction resident feedback provided to the City at every City-sponsored HALA outreach event directed to West Seattle, as well as all emails from identified West Seattle residents to the City related to HALA.  They also analyzed all feedback regarding the West Seattle Junction on the City’s own HALA consider it website.  

    The information was obtained through public records requests to ensure that JuNO’s analysis included all WSJ feedback.  The analysis, including all backup documents, was included as part of JuNO’s comments to the EIS and is part of the public record.  You can find it on the City’s website regarding the EIS and in prior WSB coverage.

    • matt December 12, 2017 (9:58 am)

      After the Jan 26th Design workshop I wrote a first person account of our table’s feedback and sent it to the city and put it in the comments of the article WSB wrote.  It was even handed, included ideas that I don’t agree with it, but the point was to gather opinions not reach consensus. 

      Imagine my surprise when reading JuNO’s Draft EIS comments that 1) it singles me out personally to minimize my contribution and 2) wrote their own summary, and 3) felt they had to include three of my tweets as an stand alone Exhibit.  That’s just weird and personal, but whatever.  

      The irony is that I wrote down my account because I was worried that voices like mine are being ignored by JuNO, and lo and behold, it goes out of its way to say ‘this resident’s opinion should be ignored.’  Thanks, y’all. 

  • Peter November 28, 2017 (10:33 am)

    I do not believe these organizations really represent neighborhoods or communities; they are exclusive groups represent only the very narrow interests of the privileged few. They are unelected, unaccountable, exclusionary by nature, and they are fighting against the best interests of the city as a whole. WE NEED MORE HOUSING. Opposing HALA is counterproductive if they really want to slow the escalation of housing costs in Seattle.

  • TJ November 28, 2017 (11:25 am)

    Who exactly are the “priveleged few”? Hopefully you aren’t just referring to home owners? 

  • anon November 28, 2017 (12:09 pm)

    Peter, those meetings are open to everyone. Not sure how they can be exclusionary when anyone can attend and voice their opinion. If you have never gone to one than I don’t think you have to portray those that do in the matter you so have. I also agree with DHG that the meetings are always posted as to when and where, attend or send your comments to them directly if you can’t. I think people are just finally realizing they didn’t do either and are complaining now that these lawsuits are happening. 

  • Diane November 28, 2017 (12:59 pm)

    both MOCA and JUNO have done excellent community outreach (way better than the city financed so-called outreach meetings with paid staff); MOCA & JUNO and other community groups have held meetings about HALA and MHA with packed rooms of WS residents in attendance; MOCA recently held a meeting specific to this topic of MHA with 50+ attending and we all got to vote on 5 different options and offer other suggestions; if people don’t show up at MOCA, JUNO, or other community meetings, all volunteers btw, how is it their fault that you didn’t show up to participate and express your point of view?

  • Diane November 28, 2017 (1:41 pm)

    TR, THANK YOU, THANK YOU, THANK YOU for this detailed story and the video; watched it last night; this makes me absolutely giddy; ps, TR is very aware of my residential status and that I’ve been participating in community meetings all over WS for years; fyi for others, I am a lifelong renter and incredibly grateful for all these folks (several are my friends) taking action to preserve what is left of our affordable housing before every non-wealthy longtime renter is forced out of Seattle

  • K8 November 29, 2017 (6:20 pm)

    JUNO did go to door and asking for feedback. Also the neighborhood watch (made up of renters and homeowners) got a group e-mail asking for feedback. Yes, they have done much better outreach than the city.

  • J Dough December 2, 2017 (2:19 pm)

    This appeal reads like a bunch of bogus technicalities meant to delay or exonerate WS from contributing to housing affordability.  Dragging our feet will only exacerbate our out of control housing costs.. living 2 blocks away from the junction, I would love to be included in JuNO’s next outreach survey.

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