Rainier Square Development

University of Metropolitan Tract

Addendum to Final Environmental Impact Statement Downtown Height and Density Changes January 2005

Master Use Permit Project No. 3017644

City of Department of Planning and Development

February 11, 2015 DRAFT FOR CITY STAFF REVIEW 0NLY

Prepared by: Parametrix Inc.

Environmental Impact Statement Addendum

Addendum to ENVIRONMENTAL IMPACT STATEMENT for the Downtown Height and Density Changes January 2005

Addressing Environmental Impacts of

Rainier Square Development University of Washington Metropolitan Tract Rainier Square Redevelopment

Master Use Permit # 3017644

City of Seattle Department of Planning and Development

This Environmental Impact Statement Addendum has been prepared in compliance with the State Environmental Policy Act (SEPA) of 1971 (Chapter 43.21C, Revised Code of Washington); the SEPA Rules, effective April 4, 1984, as amended (Chapter 197-11 Washington Administrative Code); and rules adopted by the City of Seattle implementing SEPA – Seattle’s Environmental Policies and Procedures Code (Chapter 25.05, Seattle Municipal Code). The Seattle Department of Planning and Development (DPD). DPD has determined that this document has been prepared in a responsible manner using appropriate methodology and DPD has directed the areas of research and analysis that were undertaken in preparation of this DSEIS. This document is not an authorization for an action, nor does it constitute a decision or a recommendation for an action.

Date of Issuance of this EIS Addendum ...... DATE

Rainier Square Development i University of Washington Metropolitan Tract Environmental Impact Statement Addendum

Cite as: City of Seattle Department of Planning and Development University of Washington Metropolitan Tract Rainier Square Redevelopment February 2015 Addendum to Final Environmental Impact Statement Downtown Height and Density Proposal, January 2005 Prepared by Parametrix Inc., Seattle, WA.

554-4475-012 ii Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum

Fact Sheet

TITLE Rainier Square Development, University of Washington, Metropolitan Tract, Rainier Square Redevelopment

DESCRIPTION OF Construction of an office, retail and hotel development including PROPOSAL AND  A 59-story office/residential tower, 846 feet high with 780,750 ALTERNATIVES square feet of office development and 178 residential units  A 160 to 180 room hotel  Approximately 74,000 square feet of retail space  Below grade parking for approximately 879 vehicles

PROPONENT University of Washington, Wright Runstad and Company

ANTICIPATED Demolition of the existing Rainier Square is anticipated to begin in the CONSTRUCTION first quarter of 2016. Construction of the office/residential tower and hotel may proceed separately. Occupancy of the lower office levels of the tower are expected in the summer of 2018 with full occupancy of the office and residential levels in 2019.

LEAD AGENCY City of Seattle

RESPONSIBLE OFFICIAL Diane Sugimura, Director City of Seattle, Department of Planning and Development 700 Fifth Avenue, Suite 2000 PO Box 34019 Seattle, WA 98124-4019

CONTACT PERSON Bruce Rips, Land Use Planner City of Seattle, Department of Planning and Development Seattle Municipal Tower 700 Fifth Avenue, Suite 2000 PO Box 34019 Seattle, WA 98124-4019 Telephone 206-615-1392 FAX: 206-386-4039 E-Mail: [email protected]

Rainier Square Development i University of Washington Metropolitan Tract Environmental Impact Statement Addendum Fact Sheet (continued)

LICENSES, PERMITS, AND  Final Approval and Notice to Proceed by the University of APPROVALS POTENTIALLY Washington REQUIRED  City of Seattle Permits o Master Use Permit o Demolition Permit o Clearing and Grading Permit o Stormwater Control Permits o Street Use Permits, including truck hauling specifications o Electrical and Mechanical Permits

AUTHORS AND PRINCIPAL Parametrix Inc. CONTRIBUTORS 719 2nd Avenue, Suite 200 Seattle, WA 98104 206.394.3700 EIS Preparation

THIS DOCUMENT IS A This document is an addendum to the Environmental Impact Statement SUPPLEMENT TO for Downtown Height and Density Changes, January 2005 Copies are available at: University of Washington Suzzallo Library Seattle Central Public Library DATE OF ISSUE OF EIS DATE ADDENDUM LOCATION OF City of Seattle, Department of Planning and Development BACKGROUND Seattle Municipal Tower INFORMATION 700 Fifth Avenue, Suite 2000 Seattle, WA 98124-4019 Or, Internet project library: http://web6.seattle.gov/dpd/edms/ Project number: 3017644

DATE OF FINAL ACTION ON Master Use Permit approval is expected summer 2015 THE PROPOSAL Construction Permits are expected between July and December 2015

ii Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum

Fact Sheet (continued)

AVAILABILITY OF THE EIS Copies of this Addendum are available for review at: ADDENDUM City of Seattle Department of Planning and Development Seattle Municipal Tower 700 Fifth Avenue, Suite 2000 PO Box 34019 Seattle, WA 98124-4019 Copies are available from the City of Seattle, Department of Planning and Development for the cost of reproduction. Copies are also available online at: http://web6.seattle.gov/dpd/edms/ Project number: 3017644http://f2.washington.edu/cpo/projects/sepa

Rainier Square iii University of Washington Metropolitan Tract

Environmental Impact Statement Addendum

Table of Contents 1 Description of Proposal ...... 1-1 1.1 Proponent ...... 1-1 1.2 Location of Proposal ...... 1-1 1.3 Background Information ...... 1-2 1.3.1 Downtown Height and Density Changes EIS ...... 1-2 1.3.2 Site Vicinity ...... 1-4 1.3.3 Metropolitan Tract ...... 1-5 1.3.4 Existing Site ...... 1-7 1.4 Project Proposal ...... 1-7 1.4.1 General ...... 1-7 1.4.2 Base Structure and Street Frontage ...... 1-10 1.4.3 Office/Residential Tower ...... 1-13 1.4.4 Hotel ...... 1-14 1.4.5 Parking and Service Access ...... 1-18 1.4.6 Construction Timing and Sequencing, ...... 1-18 2 Environmental Impacts ...... 2-1 2.1 Land Use ...... 2-3 2.1.1 Downtown Height and Density Changes EIS ...... 2-3 2.1.2 Addendum Information on Affected Environment ...... 2-5 2.1.3 Addendum Information on Impacts ...... 2-8 2.1.4 Mitigation Measures ...... 2-16 2.2 Housing ...... 2-17 2.2.1 Downtown Height and Density EIS ...... 2-17 2.2.2 Addendum Information on Affected Environment ...... 2-18 2.2.3 Addendum Information on Impacts ...... 2-20 2.3 Urban Design – Height, Bulk and Scale ...... 2-21 2.3.1 Downtown Height and Density EIS ...... 2-21 2.3.2 Addendum Information on Project Impacts ...... 2-25 2.3.3 Mitigation Measures ...... 2-33 2.4 Urban Design – Pedestrian Amenities and Open Space ...... 2-34 2.4.1 Downtown Height and Density EIS ...... 2-34 2.4.2 Addendum Information on Project Impacts ...... 2-35 2.4.3 Mitigation Measures ...... 2-37 2.5 Views and Aesthetics ...... 2-38 2.5.1 Downtown Height and Density EIS ...... 2-38 2.5.2 Addendum Information on Impacts ...... 2-43 2.5.3 Mitigation Measures ...... 2-48 2.6 Shadows ...... 2-49 2.6.1 Downtown Height and Density EIS ...... 2-49 2.6.2 Addendum Information on Affected Environment ...... 2-49 2.6.3 Addendum Information on Impacts ...... 2-55 2.6.4 Mitigation Measures ...... 2-59 2.7 Light and Glare ...... 2-60 2.7.1 Downtown Height and Density EIS ...... 2-60 2.7.2 Addendum Information on Affected Environment ...... 2-60 2.7.3 Addendum Information on Impacts ...... 2-62

Rainier Square v University of Washington Metropolitan Tract Environmental Impact Statement Addendum

Table of Contents (continued) 2.7.4 Mitigation Measures ...... 2-65 2.8 Wind ...... 2-67 2.8.1 Downtown Height and Density EIS ...... 2-67 2.8.2 Addendum Information on Affected Environment ...... 2-67 2.8.3 Addendum Information on Potential Impacts ...... 2-69 2.8.4 Mitigation Measures ...... 2-69 2.9 Transportation ...... 2-78 2.9.1 Downtown Height and Density EIS ...... 2-78 2.9.2 Addendum Information on Affected Environment ...... 2-81 2.9.3 Addendum Information on Impacts ...... 2-84 2.9.4 Mitigation Measures ...... 2-91 2.10 Energy/Greenhouse Gas Emissions ...... 2-95 2.10.1 Downtown Height and Density EIS ...... 2-95 2.10.2 Addendum Information on Affected Environment ...... 2-95 2.10.2.1 Energy ...... 2-95 2.10.2.2 Greenhouse Gasses ...... 2-95 2.10.2.3 Policy Framework ...... 2-96 2.10.3 Addendum Information on Potential Impacts ...... 2-99 2.10.3.1 Energy ...... 2-99 2.10.3.2 Greenhouse Gas ...... 2-99 2.10.4 Mitigation Measures ...... 2-100 2.11 Construction ...... 2-103 2.11.1 Downtown Height and Density EIS ...... 2-104 2.11.2 Addendum Information on Air Quality ...... 2-104 2.11.3 Addendum Information on Noise ...... 2-105 2.11.4 Addendum Information on Drainage ...... 2-114 2.11.5 Addendum Information on Pedestrian Circulation ...... 2-115 2.11.6 Addendum Information on Construction Impacts on Transportation ...... 2-115 3 References ...... 3-1 List of Tables Table 2-1. Meteorological Factors Relevant to Pedestrian Comfort ...... 2-55 Table 2-2. Pedestrian Comfort and Safety Wind Modeling Results ...... 2-73 Table 2-3. Existing AM and PM Peak Hour LOS ...... 2-82 Table 2-4. 2020 No-Build AM and PM Peak Hour LOS ...... 2-83 Table 2-5. Mode of Travel (Weekday) ...... 2-85 Table 2-6 Vehicle Trips Generated by Proposed Development ...... 2-85 Table 2-7 Existing, 2020 No-Build and 2020 Build AM and PM Peak Hour LOS ...... 2-87 Table 2-8. LOS Screenlines with Proposed Development ...... 2-88 Table 2-9. Intersection LOS Comparison to Downtown EIS ...... 2-89 Table 2-10. Driveway Level of Service ...... 2-89 Table 2-11. Seattle Greenhouse Gas Inventory ...... 2-98 Table 2-12. Project Annual Greenhouse Gas Emissions (Metric Tons of Carbon) .... 2-100 Table 2-13. Sound Levels Produced by Common Noise Sources ...... 2-106 Table 2-14. State of Washington Maximum Permissible Environmental Sound Levels ...... 2-109

vi Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum

Table 2-15. City of Seattle Maximum Permissible Environmental Sound Levels ...... 2-109 Table 2-16. Noise Associated with Common Construction Equipment ...... 2-110

List of Figures

Figure 1-1. Site Location within ...... 1-1 Figure 1-2. Site and Downtown Seattle Neighborhoods ...... 1-3 Figure 1-3. Existing Site Plan and Vicinity Buildings ...... 1-5 Figure 1-4. University of Washington Metropolitan Tract ...... 1-6 Figure 1-5. Proposed Site Plan ...... 1-8 Figure 1-6. Proposed Site Plan Schematic ...... 1-9 Figure 1-7. Proposed Project Base Structure with Hotel and Towers ...... 1-10 Figure 1-8. Proposed Project Base Structure Street Uses Entry/Circulation ...... 1-11 Figure 1-9. Proposed Base Structure Upper Level – 5th Avenue and Union Street ..... 1-12 Figure 1-10. Proposed Base Structure Open Space – 5th Avenue and Union Street ... 1-12 Figure 1-11. Proposed Base Structure – 5th Avenue and Union Street ...... 1-13 Figure 1-12. Proposed Rainier Square Project Office/Residential Tower viewed from the Northeast ...... 1-15 Figure 1-13. Proposed Project Tower Massing in Relation to Existing Rainer Tower .. 1-16 Figure 1-14. Proposed Project Rendering Fifth and Union View to the South ...... 1-16 Figure 1-15. Proposed Project Rendering Fifth and Union View to the South ...... 1-17 Figure 1-16. Proposed Hotel Rendering Fourth and University View to the North ...... 1-17 Figure 2-1. Downtown Zoning ...... 2-14 Figure 2-2. View of the Project from the Northeast, Volunteer Park Water Tower...... 2-46 Figure 2-3. View of the Project from the Southwest, Hamilton Viewpoint West Seattle ...... 2-46 Figure 2-4. Shadows Produced by Existing Buildings ...... 2-57 Figure 2-5. Shadows Produced by the Proposal ...... 2-58 Figure 2-6. Seattle Wind Roses for Summer and Winter ...... 2-71 Figure 2-7. Locations Modeled for Pedestrian Wind Comfort ...... 2-72 Figure 2-8. Seattle Greenhouse Gas Inventory by Major Contributor ...... 2-98

List of Appendices

A. Distribution List (included with Addendum Text)

In separate volume B. Pedestrian Level Wind Analysis C. Transportation Impact Study D. Greenhouse Gas Emissions Calculation Spreadsheet

Rainier Square vii University of Washington Metropolitan Tract Final Supplemental Environmental Impact Statement

Acronyms and Abbreviations

BMP best management practice °C degrees Celsius CMP Construction Management Plan dB decibel dBA A-weighted decibel Ecology Washington State Department of Ecology EDNA environmental designation for noise abatement EIS environmental impact statement FEIS final environmental impact statement I-5 Interstate 5 mph miles per hour SCL Seattle City Light SEPA State Environmental Policy Act SMC Seattle Municipal Code SR State Route SWPPP Stormwater Pollution Prevention Plan TDR Transfer of Development Rights TESC Temporary Erosion and Sediment Control TMP Transportation Management Plan UW University of Washington WAC Washington Administrative Code WSDOT Washington State Department of Transportation

viii Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum

1 DESCRIPTION OF PROPOSAL

1.1 Proponent The proposal is sponsored by the University of Washington and its lessee Wright Runstad & Company, a Seattle-based firm that develops, acquires, manages and leases commercial buildings located primarily in the . The site is within the “Metropolitan Tract,” the original location of the Washington Territorial University established in 1861. The Metropolitan Tract is managed to meet the University of Washington Board of Regents’ primary objective: to generate maximum long-term value and related cash flow to support programs of the university.

1.2 Location of Proposal The project site is in Seattle’s Downtown Urban Center within the Commercial Core Urban Village on a block that is bounded by Union Street on the north, Fifth Avenue on the east, University Street on the south, and Fourth Avenue on the west (see Figures 1-1 and 1-2).

Figure 1-1. Site Location within Downtown Seattle

Proposed Site

Rainier Square Development 1-1 University of Washington Metropolitan Tract Environmental Impact Statement Addendum

1.3 Background Information

1.3.1 Downtown Height and Density Changes EIS The Washington State Environmental Policy Act (SEPA) Revised Code of Washington (RCW) 43.21C.034 and Seattle Municipal Code 25.05.600 encourages the use of “environmental documents that have previously been prepared in order to evaluate proposed actions, alternatives, or environmental impacts. The proposals may be the same as, or different than, those analyzed in the existing documents” (WAC 197-11-600(2)). The City of Seattle Downtown Height and Density Changes (DHDC) Environmental Impact Statement (EIS) prepared between 2003 and 2005 analyzed a variety of height and density increases. The Final EIS identified a Preferred Alternative that would increase densities in the Downtown Office Core (DOC) 1 and much of DOC 2, as well as increase maximum heights with the highest height limits oriented to developments including housing. New controls on building bulk also were addressed. The EIS noted that broad analyses of non-project proposals can facilitate “phased review” by addressing bigger- picture concerns and allowing review of future proposals to focus on a smaller range of more specific concerns. This means that future proposals in the study area could incorporate or refer to portions of this EIS to fulfill their SEPA requirements. This could increase the efficiency of environmental review and expedite permitting processes (DHDC DEIS page ii). Within the DOC 1 zoning district the Floor Area Ratios (FAR) were proposed to be increased to encourage infill development and efficient use of available sites within the portion of Downtown with the densest development pattern. These proposals also intended to enhance the use of development incentives by better integrating permitted development densities with the revisions to the bonus and transfer of development rights (TDR) programs. This envisioned a "grow-from-the-core" future development pattern with expansion of the Office Core resulting in a denser pattern of employment growth. The approach to height limits provided more flexibility to arrange building bulk into taller forms. (DHDC FEIS page 1-5) The approach to bulk controls in the Preferred Alternative was to set higher maximum height limits that would stretch the building envelope vertically, allowing for less bulky structures to accommodate the increases in maximum density. The length of facades that can extend uninterrupted along street edges area was also limited. For residential use, specific limits were set on the size of floors and maximum dimensions of facades, above prescribed elevations, to promote less bulky towers. In general, under the Preferred Alternative, the increased densities proposed in the Office Core zones and higher height limits for residential and mixed-use projects were expected to result in fewer new structures (DHDC FEIS page 1-7).

1-2 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum

Figure 1-2. Site and Downtown Seattle Neighborhoods

Changes to city regulations envisioned by the DHDC EIS were adopted by the City Council by Ordinance Number: 122054 in April 2006, as well as by other code amendments. A major change relevant to this project was the establishment of an unlimited height provision in the DOC 1 zoning district. The maximum Floor Area Ratio (FAR) was increased to 20, subject to a variety of criteria for floor area bonuses. Analysis contained in the DHDC EIS evaluated the direct, indirect, and cumulative impacts on specific elements of the environment found to be significantly impacted. This Addendum summarizes for each relevant element of the environment the applicable analysis in the DHDC EIS, the adopted plans, policies and regulations that were adopted as the result of the planning program addressed by that EIS, as well as relevant pre-existing policies and programs unchanged by the DHDC alternatives that continue to be in effect. Other policies relevant to some elements of the environment include the Washington State Growth Management Act, Puget Sound Regional Council’s Adopted Multi-County Framework Goals and Policies, the King County Countywide Planning Policies, the City of Seattle Comprehensive Plan, and the City of Seattle Land Use Code. This Addendum summarizes the DHDC EIS analysis of environmental impacts associated with proposed alternatives for code modifications for height and density code changes, adds new information about existing conditions, where relevant and adds environmental analysis of the proposed project and discusses how they relate to the DHDC impact analysis. This Addendum also discusses mitigation measures when appropriate, which include relevant potential mitigation

Rainier Square Development 1-3 University of Washington Metropolitan Tract Environmental Impact Statement Addendum strategies discussed in the DHDC EIS that were not considered mandatory, but were identified for potential consideration with future development. Additional mitigation is identified based on specific characteristics of the Rainier Square Development.

1.3.2 Site Vicinity The project site is located in Seattle’s Downtown Urban Center, within the Commercial Core. The site occupies one full block that is bounded by Union Street on the north, Fifth Ave. on the east, University Street on the south, and Fourth Avenue on the west as shown in Figures 1-1 and 1-2. It is within the Metropolitan Tract, the University of Washington’s original campus (Figures 1-3 and 1-4). The pattern of existing land uses immediately surrounding the project site includes a mix of office, retail, residential, lodging, and entertainment uses, including adjacent buildings as shown in Figure 1-3. 1. The Fairmont Olympic Hotel, originally Olympic Hotel, occupies the city block directly south of the project site within the UW Metropolitan Tract. It was constructed in 1924 and is 14 stories high. 2. The Skinner Building occupies the block face to the east on 5th Avenue between University Street and Seneca Street within the UW Metropolitan Tract was built in 1926 and is six to eight stories high. 3. The to the west is a 21-story, 275,000-square-foot office/retail building in the UW Metropolitan Tract built in 1960. 4. The northwest corner of Union Street and Fourth Avenue is occupied by the 1411 Fourth Avenue Building which was built in 1928 and is 15 stories high with 151,000 square feet of floor area. 5. The Financial Center building is located to the southwest of Union Street and Fourth Avenue within the UW Metropolitan Tract. It was built in 1972 and is 28 stories high with 343,000 rentable square feet of floor area. 6. The 11-story Cobb Building on the west side of Fourth Avenue was built in 1907 and is residential. 7. The IBM building is located on the block corner of Fifth Avenue and University Street within the UW Metropolitan Tract. It is 20 stories high and contains 225,000 rentable square feet of floor area. It was completed in 1964. 8. The is a 40-story office building with 29 floors of rentable space over an 11-story base shaped like an inverted pyramid. It has 538,000 rentable square feet of floor area. It was built in 1964.

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Figure 1-3. Existing Site Plan and Vicinity Buildings

1. Olympic Hotel 5. Financial Center building 2. Skinner Building 6. Cobb Building 3. Puget Sound Center 7. IBM Building 4. 1411 Fourth Avenue 8. Rainier Tower

1.3.3 Metropolitan Tract The Metropolitan Tract is the original site of the University of Washington (Figure 1-4). Early in 1861, pioneer families Arthur and Mary Denny, Charles and Mary Terry, and Edward Lander deeded the land to the state for the Territorial University. In 1895, the University's main campus was relocated to its present Montlake site on the shore of Lake Washington. Some years later, the original campus site was leased to the Metropolitan Building Company for a term of 50 years. The Metropolitan Tract was expanded in 1958 in a property exchange with the US Postal Service, as well as the 1962 purchase of the site for the Olympic Hotel garage. The present area is 11 acres and is contains over 1,500,000 rentable square feet of office space, 200,000 rentable square feet of commercial retail space, 450 hotel rooms, 91 residential units, and about 2,000 parking spaces. The Metropolitan Tract is managed by University of Washington Real Estate. Wright Runstad has an 80 year lease on the block containing the Rainier Tower and the proposed Rainier Square development and manages that block. LHCS Hotel Holdings leases and manages the Fairmont Olympic Hotel and garage. Unico Properties, Inc.manages the other commercial office buildings (Financial Center, IBM Building, Puget Sound Plaza, Skinner Building). In guiding Metropolitan Tract policy through the years, the UW Board of Regents has adhered to one primary objective: to generate maximum long-term value and related cash flow through the best possible use of this endowment of land and buildings (UW 2014).

Rainier Square Development 1-5 University of Washington Metropolitan Tract Environmental Impact Statement Addendum

Figure 1-4. University of Washington Metropolitan Tract Metropolitan Tract is shown in yellow

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1.3.4 Existing Site The project site is located in Downtown Seattle’s Commercial Core Neighborhood (Figure 1-2). The following is an overview of current site conditions for this block. Street Configuration – As depicted in Figure 1-2, the site is located in an area were the City’s Downtown street grid is oriented in a southeast to northwest orientation based on the orientation of the Elliot Bay shoreline. For simplification of discussion in this Addendum, streets are described as having and east-west orientation and avenues a north-south orientation. Topography – The block slopes from a high point at the southeast corner at Fifth Avenue and University Street with an elevation of 162 feet down to the northwest corner at Fourth Avenue and Union Street with an elevation of 137 feet. The southeast corner can be regarded as being approximately two stories higher than the northwest corner. Grade level at Fifth Avenue and University Street is at approximately the roof level of the first story at Fourth Avenue and Union Street. Existing On-Site Land Uses – As depicted in Figure 1-3, the site currently contains one office building, the Rainier Tower at the southeast corner, and a one- to three-story shopping center with a central courtyard below grade level. The Rainier Tower contains 538,000 square feet of leasable area in 29 occupied floors above an 11-story inverted pyramid base. The shopping center contains 128,000 square feet and includes retail uses and restaurants.

1.4 Project Proposal

1.4.1 General The proposed development consists of the following features shown in Figures 1-5 to 1-16.  The existing Rainier Tower building on the southeast corner of the block will be retained. This 40-story (514-foot-high) building was designed by Minoru Yamasaki, who designed the original World Trade Center in New York City (destroyed September 11, 2001) as well as the IBM Building which is on the corner across the street from Rainier Tower to the southeast. The building includes an 11-story, 121-foot concrete pedestal base that tapers towards ground level, like an inverted pyramid, with the 29-story office tower balanced above it.  The existing Rainier Square Shopping Center to the north and west of the tower, which provides 128,000 square feet of retail and restaurant use, will be demolished.  On the north side of the block a 59-story office/residential structure is proposed. It is 846 feet high to the top of the parapet (the height as defined by the Land Use Code is 845 feet 9 inches. It has two floors of street-level retail use, 37 floors of office use with a total of about 780,000square feet of floor area, and 18 floors with approximately 178 residential units with about 282,000 square feet of floor area above the office tower. The highest portion of the tower is located at the northwest corner of the block.

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 On the southwest side of the block, a 12-story hotel with 160 to 180 rooms and 120,000 square feet of floor area is located in a separate building along 4th Avenue and is set back from the office/residential tower to the north and University Street to the south.  The base of the project provides retail and lobby uses around the perimeter with a “market” or “hub” space in the interior of the block and accommodates about 74,000 square feet of retail space. A partial glass ceiling introduces natural light and provides a visual connection to Rainier Tower and the rest of the development.  Open space is provided on the second and third floors of the base structure between the proposed buildings.  A below-grade parking garage for 879 vehicles.

Figure 1-5. Proposed Site Plan

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Figure 1-6. Proposed Site Plan Schematic

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1.4.2 Base Structure and Street Frontage The massing composition of the proposed structures builds from a common pedestrian datum, or “plinth,” incorporating a variety of pedestrian-oriented retail uses. This base structure excludes the existing Rainier Tower at the southeast corner of the block and the block frontage immediately beneath (Figures 1-7 through 1-11). A central feature is a glass-ceilinged central atrium market or hub space in the interior of the block. The proposal includes retail frontage along the entire Fifth Avenue street frontage; the Union Street frontage is about half retail with half building lobby and garage access; the Fourth Avenue street frontage includes about three quarters retail frontage, a small entry for the residential tower, a portion of the hotel lobby and restaurants; the University Street frontage contains the hotel lobby and entry, retail use as well as a garage exit (Figure 1-8). Upper floors include retail, office, and open space use (Figures 1-9, 1-10, 1-11). The street frontages are expected to accommodate a mix of retail, restaurants, coffee shops, and lobby spaces that are designed to engage the interest of pedestrians with multiple and varied storefronts, open facades, lighting, merchandising displays, areas for seating, and other activities that would spill out onto the sidewalk to promote pedestrian interaction. Materials and detailing are proposed to enhance the quality of the street-level experience.

Figure 1-7. Proposed Project Base Structure with Hotel and Towers

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Figure 1-8. Proposed Project Base Structure Street Uses Entry/Circulation

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Figure 1-9. Proposed Base Structure Upper Level – 5th Avenue and Union Street

Figure 1-10. Proposed Base Structure Open Space – 5th Avenue and Union Street

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Figure 1-11. Proposed Base Structure – 5th Avenue and Union Street

1.4.3 Office/Residential Tower The proposed office/residential tower includes a curtain wall along the entire Union Street frontage and extends about 550 feet along the Fifth Avenue and Fourth Avenue frontages (Figure 1-12). The façade rises at the northeast corner of the site to the tenth level which is the same elevation as the transition on the existing Rainier Tower between the inverted pyramidal base and the bottom of the office floors (about 139 feet) (Figure 1-13). At that point the tower curves in a series of one-story steps to the 39th level (about 390 feet) to reach a square tower design which continues to the top of the building. The square portion of the tower is 120 feet in height each floor has a gross floor area of 13,800 square feet, which continues to the top of the building for a total residential floor area of about 260,000. The dimensions of the upper portion of the proposed tower are roughly the same as the existing Rainier Tower. The building has a reflective glass façade above the fourth floor with vertical metal prisms extending one to two floors in length scattered on the face of the building with increased density toward the top. The top of the tower is designed to display a unique and distinct identity expressed through a greater concentration of metal prisms and other detailing at the upper levels to form a distinct “top” or “cuff.” The design intent of the tower is to provide a visual landmark for downtown on the skyline, adding to its visual interest and variety. The concave sloping or stepping of the middle floors of the tower from the 10th to the 39th story starts at the same elevation that the adjacent Rainier Tower makes the transition from an inverted pyramidal

Rainier Square Development 1-13 University of Washington Metropolitan Tract Environmental Impact Statement Addendum base to a square tower. The angle of the step-back is roughly the same as the angle of the Rainier Tower pyramidal base, but it becomes narrower as it rises, in what the architect describes as an inverse and complementary relationship between the configuration of the negative space of Rainier Tower base and the street wall of the new development along Fifth Avenue (Figure 1-13). As the proposed tower gradually slopes away from the existing Rainier Tower, it preserves views to the north and culminates in a slim rectangular profile at the top floors in the northwest corner of the block. In this way, the upper levels of the two towers are set in diametric positions on the block, allowing light, air, and views for both of the towers, as well as for the surrounding urban spaces. (Figure 1-14) The corner of the building at Fourth Avenue and Union Street includes a “carved away” section that incorporates a concave curve in the façade that decreases as it ascends to be reminiscent of Rainier Tower’s base (Figure 1-15). 1.4.4 Hotel The hotel is 12 stories (123 feet) high and extends along Fourth Avenue a distance of about 270 feet. Along University Street, the width of the hotel is about 67 feet. The hotel design incorporates materials and detail from the larger project. The façade is faceted to express the rhythm of program and structure, and consists of vision glass, spandrel glass and stone cladding (Figure 1-16). At the upper levels, landscaped terraces provide open space for guests, tenants, and residents. Street frontage of the hotel portion of the development is about 25 percent lobby and 75 percent retail and restaurant space. A loading area is proposed on University Street, adjacent to the hotel lobby.

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Figure 1-12. Proposed Rainier Square Project Office/Residential Tower viewed from the Northeast

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Figure 1-13. Proposed Project Tower Massing in Relation to Existing Rainer Tower

Figure 1-14. Proposed Project Rendering Fifth and Union View to the South

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Figure 1-15. Proposed Project Rendering Fifth and Union View to the South

Figure 1-16. Proposed Hotel Rendering Fourth and University View to the North

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1.4.5 Parking and Service Access The proposal includes a below-grade parking garage for 879 vehicles in up to six levels below grade. Driveway access would be provided on Union Street at approximately the same location as the current garage access. A new garage exit would be provided on University Street. A loading area would be provided adjacent to the Union Street garage entrance. The garage access would serve the existing garage under the existing Rainier Tower. A guest drop-off/pickup area would be provided on University Street adjacent to the hotel lobby.

1.4.6 Construction Timing and Sequencing, Construction would occur over approximately two and a half years with demolition beginning in the first quarter of 2016, occupancy of the lower floors of the office tower in 2018 with occupancy of the upper office floors and residential floors in 2019. Phases of construction include:

Phase I Mobilization  Segregate the construction area from public access with temporary fencing and signage. This may exclude use of portions of the adjacent sidewalks during some phases.  Establish access points to the construction area and install Temporary Erosion and Sediment Control (TESC) measures.  Set up construction administration offices.

Phase II Demolition and Excavation  Demolish existing Rainier Square Shopping Center  Excavate underground parking garage, including shoring

Phase III Building Structure Construction  Install below-grade parking garage  Construct base structure and office/residential tower  Construct hotel

Phase IV Building Interior Construction  Interior construction initiated on lower floors as upper floor structure continues  Includes finishing, electrical, plumbing, HVAC

Phase V Street and Sidewalk Improvement and Landscaping  Install new sidewalks and street trees  Install hardscape and landscaping for rooftop open space

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2 ENVIRONMENTAL IMPACTS

This analysis is based on the Draft and Final Environmental Impact Statements prepared for the Downtown Height and Density Changes (DHDC EIS). That document assessed the following elements of the environment.  Population and Employment  Housing  Land Use  Urban Design: Height, Bulk and Scale  Urban Design: Pedestrian Amenities and Open Space  Views and Aesthetics  Climate  Shadows and Wind  Transportation  Parking  Energy  Water Utility  Sewer and Stormwater Utilities The City of Seattle Department of Planning and Development (DPD) has determined pursuant to WAC 197-11-600 and SMC 25.05.600 that the DHDC EIS adequately assesses the potential impacts of the proposed development and is therefore adopted as the environmental record for the action together with this Addendum. This Addendum adds analyses or information about the proposal but does not substantially change the analysis of significant impacts and alternatives in the existing DHDC EIS. DPD has determined that additional information is appropriate for the following elements:  Land Use  Housing  Urban Design: Height, Bulk and Scale  Urban Design: Pedestrian Amenities and Open Space  Views and Aesthetics  Shadows  Light and Glare  Wind  Transportation and Parking  Energy and Greenhouse Gas Emissions  Construction Impacts

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For each element, this Addendum provides:  A brief summary of the analysis provided in the DHDC EIS as it applies to the specific portion of the Downtown where the proposal is located.  Information on project-specific impacts associated with the Fifth and University Development.1

1 See Scope of Work Proposal Parametrix 2014 and responding email Bruce Rips, Seattle DPD 10/20/ 2014

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2.1 Land Use

2.1.1 Downtown Height and Density Changes EIS The DHDC EIS described The Downtown Office Core 1 (DOC1) zone, located approximately between Second Avenue and Interstate 5 (I-5) south of Union Street, as the Downtown zoning area with the densest pattern of land uses, predominantly consisting of large full- and half-block office buildings and hotels. Retail spaces in this area primarily serve Downtown office tenants. (DHDC DEIS page 3-30) Under all of the alternatives, including the previously existing conditions, some City of Seattle landmarks, some existing housing and some buildings containing human service uses might be demolished. However, those demolitions would be as likely to occur under the previously existing conditions as under any of the alternatives and were not significant adverse impacts of the alternatives. (DHDC FEIS page 4-49) In spite of a lack of significant unavoidable adverse impacts directly resulting from the alternatives considered, the alternatives would have varying effects on the capacity for new development, the concentration and mix of development over 20 years, the potential demolition of residential buildings and human service facilities, and the preservation of landmark and other key community structures. (DHDC DEIS page 3-45) The alternatives for height and density increases were not projected to vary the capacity of commercial and residential growth that can ultimately be accommodated within Downtown under each alternative. The projected demand for housing and commercial floor area in the Downtown area over the 20-year period between 2000 and 2020 was assumed to be constant, regardless of overall zoning capacity, although distribution within different areas would change. Therefore, all alternatives presumed that from 2000 to 2020, the Downtown Urban Center would add 70,000 jobs, as well as housing to accommodate 17,500 households (equivalent to 18,400 dwelling units).(DHDC FEIS page 4- 45) The increased density analyzed in the DHDC EIS of residential and commercial development would significantly transform the downtown and was interpreted to be consistent with the City's Comprehensive Plan and neighborhood plans for the study area, and was not interpreted to be a significant unavoidable adverse impact. (DHDC FEIS page 4-49)

Specific Plans and Policies Assessed in the DHDC EIS

Growth Management Act (RCW 36.70A) The Growth Management Act, first enacted as ESHB 2929 by the 1990 State Legislature, contains a comprehensive framework for managing growth and coordinating land use planning with infrastructure.

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All of the alternatives were found consistent with the primary directive of GMA, which is to discourage sprawl by directing growth to urban areas (DHDC DEIS pages 3-61 to 3-62).

Puget Sound Regional Council Adopted Multicounty Framework Goals and Policies The Multicounty Framework Goals and Policies provide guidance for regional growth consistent with the mandates of the State's Growth Management Act. All of the alternatives considered were found to be consistent with the directive of the Multicounty Framework Goals and Policies to promote concentrated growth in compact, well-defined mixed-use urban centers. (DHDC DEIS page 3-62).

King County Countywide Planning Policies The policies are intended to provide a regional policy framework for local jurisdictions to follow in their planning to implement the Growth Management Act. The Countywide Planning Policies (CPP) also contain development guidelines, standards, and recommended processes to be implemented by individual cities and King County. Policies generally encourage concentrating urban development in a defined urban growth area and phasing the provision of adequate services. All of the alternatives were found to be consistent with Downtown's designation as one of the 12 Urban Centers established by the CPP, and all would accommodate the concentration of employment, housing, and other uses envisioned for Urban Centers (DHDC DEIS pages 3-62 and 3-63).

City of Seattle Comprehensive Plan: Land Use Element At the time of preparation of the DHDC EIS, Seattle's Comprehensive Plan had been adopted in July 1994 and included policies in the Land Use Element that call for concentrating future employment and population growth in Urban Centers, as defined by countywide planning policies, and in existing activity centers. The policies promoted the urban village concept, targeting employment and housing growth to various centers and villages in a balanced manner. Several of the land use policies provided further guidance regarding appropriate locations within the city for different types and amounts of growth. These policies promoted stronger links between the location of job growth and transportation capacity, discouraged population growth in areas not easily served by existing transportation facilities, and encouraged population growth within walking distance of Downtown employment and high capacity transit centers. The DHDC EIS found that all alternatives provided additional development capacity to accommodate further growth with continued growth Downtown being consistent with Downtown's designation as a regional Urban Center (DHDC DEIS pages 3-63 and 3-64).

Downtown Urban Center Goals and Policies The City's goals and policies for the Downtown Urban Center referenced in the DHDC EIS are included the 1999 Neighborhood Planning Element of the Comprehensive Plan. The policies focused on 1) land use, urban design, and open space, 2) economic development, 3) housing, and 4) transportation.

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Overall, the policies identified the desired character and function of the different areas within Downtown, and the various zones intended to achieve these desired conditions. The DHDC EIS found that height and density increases in DOC 1 and DOC 2 zones to be consistent with Downtown Urban Center policies promoting concentrated employment growth in designated Office Core areas with superior access to transit (DHDC DEIS page 3-65).

Other Downtown Neighborhood Goals and Policies In addition to the Downtown Urban Center itself, the Neighborhood Planning Element of the Comprehensive Plan included goals and policies adopted for neighborhoods that comprise the Downtown Urban Center, including the Commercial Core Neighborhood where the proposed Rainer Square project is located. Commercial Core goals and policies called for maintaining the area as a major employment center, tourist and convention attraction, shopping magnet, residential neighborhood, and regional hub of cultural and entertainment activities. Policies also emphasized improved mobility and convenient transit access, an enhanced pedestrian environment, housing affordable to a wide range of income levels, and a unified urban design strategy. The DHDC EIS found that height and density increases in DOC 1 and DOC 2 zones would generate resources for affordable housing and other neighborhood improvements. Increasing height and density limits would further stimulate development and increase the use of bonuses, and TDR incentives would be consistent with the goals and policies of the Commercial Core (DHDC DIES page 3-65).

2.1.2 Addendum Information on Affected Environment This section references City of Seattle policies for this element of the environment and provides an update to existing conditions to the extent they have changed since the DHDC Final EIS in 2005. The State Environmental Policy Act (SEPA) (RCW 43.21C.060) requires that conditions or denial of a proposal pursuant to SEPA be based upon policies identified by the governmental authority. Seattle Municipal Code (SMC) 25.05.675 contains specific environmental policies for elements of the environment. Subsection J. 2. contains land use policies including: a. It is the City's policy to ensure that proposed uses in development projects are reasonably compatible with surrounding uses and are consistent with any applicable, adopted City land use regulations, the goals and policies set forth in Section B of the Land Use Element of the Seattle Comprehensive Plan regarding Land Use Categories, and the shoreline goals and policies set forth in section D-4 of the Land Use Element of the Seattle Comprehensive Plan for the area in which the project is located. b. Subject to the overview policy set forth in SMC Section 25.05.665, the decision maker may condition or deny any project to mitigate adverse land use impacts resulting from a proposed project or to achieve consistency with the applicable City land use regulations, the goals and policies set forth in Section B of the Land Use Element of the Seattle Comprehensive Plan regarding Land Use Categories, the shoreline goals and policies set forth in Section D-4 of the

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Land Use Element of the Seattle Comprehensive Plan, the procedures and locational criteria for shoreline environment re-designations set forth in SMC Sections 23.60.060 and 23.60.220, respectively, and the environmentally critical areas policies. Ordinance 121700 amending SMC 25.05.675 was passed by the City Council in December 2004. The ordinance included reference to the numbering system of the current Comprehensive Plan and limited SEPA authority to Section B of the Land Use Element. The section relating to the downtown is discussed below. Other sections of the Comprehensive Plan are discussed to comply with the mandate in the SEPA Rules WAC 197-11-440(6)(d)(i) to include “A summary of existing plans (for example: Land use and shoreline plans) and zoning regulations applicable to the proposal, and how the proposal is consistent and inconsistent with them.”

Site Conditions

Site The project site is located in Seattle’s Downtown Urban Center, within the Commercial Core as shown in Figure 1-2. More specifically, the site occupies one full block that is bounded by Union Street on the north, Fifth Avenue on the east, Union Street on the south, and Fourth Avenue on the west as shown in Figure 2-1. It is within the Metropolitan Tract, the University of Washington’s original campus as shown in Figure 1-4 (Stein 1999). The project site consists of about three quarters of a full city block. The block contains one office building, the Rainier Tower, and a two- to three-story base structure containing predominantly retail uses and underground parking as shown in Figure 1-3. The Rainier Tower is a 40-story office building with 29 floors of rentable space over an 11-story base shaped like an inverted pyramid. It has 538,000 square feet of rentable floor area. It was designed by architect Minoru Yamasaki (best known for the original World Trade Center in New York, designed in 1965 and destroyed September 11, 2001). The current proposal includes demolition of the Rainier Square Shopping Center to the north and west of the tower which provides 128,000 square feet of retail and restaurant use. The pattern of existing land uses immediately surrounding the project site includes a mix of office, residential, lodging, retail, and entertainment uses, including the following.

South The Fairmont Olympic Hotel, originally Olympic Hotel, occupies the city block directly south of the project site between 4th and 5th Avenues and between University and Seneca Streets. It was built in 1924. It was listed on the National Register of Historic Places in 1979 (ID # 79002538). It is within the Metropolitan Tract, the University of Washington’s original campus (Stein 1999). Southeast: The IBM building is located on the block corner of Fifth Avenue and University Street within the UW Metropolitan Tract. It is 20 stories high and contains 225,000 square feet of rentable floor area. It was completed in 1964 and was also designed by Minoru Yamasaki (Unico 2014).

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Southwest: The Financial Center building is located on the west side of Fourth Avenue between Seneca and University Streets within the UW Metropolitan Tract. It is 28 stories high with 343,000 square feet of rentable floor area. It contains a second-floor public plaza area at the corner of Fourth and University Streets. It was completed in 1972 and designed by the NBBJ Group Architects. (Unico 2014)

East The Skinner Building occupies the block face on 5th Avenue between University and Seneca Streets within the UW Metropolitan Tract and is six to eight stories high. It was constructed in 1925 as part of development of the Metropolitan Tract, and incorporates the 5th Avenue Theater, 20,000 square feet of retail space and 134,000 square feet of office use. (Flom 2012) It was listed on the National Register of Historic Places in 1979 (ID # 78002756 ). The architect R.C. Reamer also designed the Old Faithful Lodge at Yellowstone National Park and Lake Quinault Lodge in Olympic National Park as well as the Great Northern and 1411 Fourth Avenue Buildings in downtown Seattle (Kreisman 2014).

West The 11-story Cobb Building on the south side of the west side of Fourth Avenue between University and Union Streets is the last remaining building within the 1907 Metropolitan Tract master plan developed by the architectural firm Howells and Stokes. It was listed on the National Register of Historic Places in 1984 (ID # 84003485). It is in the Beaux-Arts and commercial styles with terra cotta ornamentation at the top and street levels, and brick in between. The building was initially occupied by medical and dental offices. It was converted to residential use in 2006. (Crowley 2006) The north side of the block is occupied by the Puget Sound Plaza within the Metropolitan Tract, which is a 21-story office/retail building with 275,000 square feet of rentable floor area. It was constructed in 1960 and designed by the NBBJ group. The two-story street frontage was remodeled in 1988 with dark-gray polished granite panels, new windows, and lighted metal awnings with glass skylights. (Unico 2014)

North Northeast of the site is occupied by the Logan Building, a 10-story glass and steel-clad office/retail building constructed in 1959 with 117,311 square feet of rentable floor area (Unico 2014). It is surrounded by the 46-story City Centre building constructed in 1989 which occupies the balance of the block and has 1.5 million square feet of floor area (King Co. Assessor 2014). Immediately north of the site across Union Street, the east side of the block is occupied by a two-story building with 26,000 square feet of floor area originally constructed in 1941 and extensively remodeled in the 1970s. It is occupied by a bank. (King Co. Assessor 2014) The western half of the block is occupied by the four-story Great Northern Building built in 1929. It housed the ticket office for the railroad of the same name. It is designated a City of Seattle Landmark (Ordinance 1147680) and is listed as eligible for the National Register of Historic Places (ID #65006624).

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It was designed by architect R.C. Reamer. The building is noted for its Art Deco detailing at the window mullions and frieze at the top of the building (Kreisman 20014). The northwest corner of Union and Fourth Avenue is occupied by the 1411 Fourth Avenue Building which is 15 stories high with 151,000 square feet of floor area. It is designated a City of Seattle Landmark (Ordinance: 114771) and was listed in the National Register of Historic Places in 1991 (ID # 91000633). It is noted for its Art Deco and Celtic interlacing designs at friezes and panels located on piers, window bays, and bands at the parapet and between floors (Seattle 1988).

2.1.3 Addendum Information on Impacts

Consistency with Plans, Policies and Regulations

City of Seattle Comprehensive Plan The City of Seattle’s Comprehensive Plan – Toward a Sustainable Seattle was originally adopted in 1994, amended each year, and substantially updated in 2005 (Seattle 2005). The City’s current Comprehensive Plan consists of 12 major elements—urban village, land use, transportation, housing, capital facilities, utilities, economic development, neighborhood, human development, cultural resources, environment, and container port. Each element contains goals and policies that are intended to “guide the development of the City.” The Comprehensive Plan meets the requirements of the Washington State Growth Management Act by helping protect our environment, quality of life, and economic development and is designed to be consistent with VISION 2040 and King County’s Countywide Planning Policies. The four core values of Seattle’s Comprehensive Plan are:  Community – developing strong connections between a diverse range of people and places  Environmental Stewardship – protect and improve the quality of our global and local natural environment  Economic Opportunity and Security – a strong economy and a pathway to employment is fundamental to maintaining our quality of life  Social Equity – limited resources and opportunities must be shared, and the inclusion of under- represented communities in decision-making processes is necessary The City is in the process of updating the Comprehensive Plan. The new plan, Seattle 2035, is scheduled to be adopted in June 2015, which is after the application date of this project, which is vested under the existing plan. Therefore the analysis below is based on the existing Comprehensive Plan.

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Urban Village Element The Urban Village Element establishes the City’s urban village strategy for growth by guiding the designation of urban centers, urban villages, and manufacturing industrial centers (all of which are collectively referred to as “urban villages”), as well as by defining the priorities for land use in these areas. General goals and policies for urban villages call for respecting community identity (UVG1); implementing regional growth management strategies (UGV2); promoting densities, mixes of uses, and transportation improvements that support walking use of public transportation, and other transportation demand management(TDM) strategies, especially within urban centers and urban villages (UVG3); directing the greatest share of future development to centers and urban villages and reducing the potential for dispersed growth not conducive to walking, transit use, and cohesive community development (UVG4); accommodating planned levels of household and employment growth (UVG5); accommodating a range of employment activity to ensure employment opportunities are available for the city’s diverse residential population (UVG6); maintaining and creating new residential neighborhoods (UGV7); using limited land resources more efficiently and pursuing a development pattern that is more economically sound by encouraging infill development on vacant and underutilized sites, particularly within urban villages (UVG8); maximizing the benefit of infrastructure and services by focusing investment in areas expecting additional growth (UVG9); encouraging community collaboration (UGV10); increasing public safety by drawing people at all times of the day (UGV11); and promoting physical environments of the highest quality (UVG12). The Urban Village element designates the Rainier Square site as within the Downtown Urban Center (UV15, UV16) with an additional urban center village designation of “Commercial Core” (UV 17) with a functional designation of “Mixed, with an employment emphasis” (UV18). The 20-year growth targets (2004–2024) for the entire Downtown Urban Center is 10,000 new households with most in Belltown and the Denny Triangle. The target for the Downtown Commercial Core is 300 new households in addition to the existing 3,070. (Seattle 2005b) The Seattle DPD estimated that housing in the downtown increased by 7,096 units between 2005 and 2014, an increase of 71 percent. In addition, 2,864 additional housing units have been permitted but not yet built. The total of all these units is 9,960 and is close to meeting the residential growth target for the downtown. (Seattle 2014a) Exceeding the target for residential growth in the downtown is generally consistent with Comprehensive Plan policy LG16 that aims to accommodate the greatest concentration of housing in desirable, pedestrian-oriented urban neighborhoods having convenient access to regional transit stations, where the mix of activity provides convenient access to a full range of residential services and amenities, and opportunities for people to live within walking distance of employment. Accommodating a greater proportion of residential development downtown is likely to result in less environmental impact on both the built and natural environment than developing the same number of lower intensity housing units in other portions of the city and region. The target for the Downtown Urban Center is provision of 29,000 new jobs in addition to the existing 156,960, with 10,000 jobs in the Commercial Core, in addition to the existing 103,790 (Seattle 2005b). The city projects that 8,533 new jobs have been added in the Downtown Urban Center from 2004 to 2013, most of which have been in the Commercial Core. This is 29 percent of the Downtown Urban

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Center target (Seattle 2014e). This compares with a projection of 70,000 new jobs from 2000 to 2024 in the DHDC FEIS (DHDC FEIS page 4-45) The Puget Sound Regional Council “VISION 2040 targets 47 percent of new jobs in King County between 2010 and 2040 (199,000 out of 429,300 new jobs) to the two Metropolitan Cities of Seattle and Bellevue and their combined seven Urban Centers and one Manufacturing Center (PSRC 2009). The King County Comprehensive Plan Countywide Policies target 146,700 net new jobs for Seattle between 2006 and 2031 (King Co. 2012). In the DHDC EIS all alternatives presumed that from 2000 to 2020, the Downtown Urban Center would add 70,000 jobs, as well as housing to accommodate 17,500 households (equivalent to 18,400 dwelling units).(DHDC FEIS page 4-45) The proposed development is located in the Commercial Core Urban Center Village within the Downtown Urban Center. The proposed project would promote increased mixed-use development with an employment emphasis through the proposed office, retail/restaurant, and residential uses. The largest component of the project, approximately 750,000 square feet of office development, would generate about 2,500 to 2,800 jobs while the 160 to 180 room hotel would generate between 300 and 500 jobs. The multiple benefits of focusing development within an Urban Center are fulfilled by the project implementing regional growth management strategies including, supporting walking, use of public transportation, and other transportation demand management strategies; reducing the potential for dispersed growth; accommodating planned levels of household and employment growth; accommodating a diverse range of employment, using limited land resources more efficiently; and pursuing a development pattern that is more economically sound by encouraging infill development on an underutilized site, maximizing the benefit of existing infrastructure and services, increasing public safety by drawing people at all times of the day, and promoting physical environments of the highest quality through meeting the City’s design goals.

Land Use Element The Land Use Element of the City of Seattle Comprehensive Plan fulfills the Growth Management Act requirement for designating the proposed general distribution and general location and extent of the uses of land including population densities, building intensities, and estimates of future population growth (RCW 36.70A.070(1)) in conjunction with the Urban Village Element described above. This element also provides the basis for land use regulations contained in the City’s Land Use Code (Seattle Municipal Code Title 23 [SMC 23]). Citywide land use goals and policies that apply to the Commercial Core include providing for a development pattern consistent with the urban village strategy (LUG1). Policies for which a project can be conditioned or denied under State Environmental Policy Act authority are found in SMC 25.05.675.J(2) (b) and are limited to Section B of the Land Use Element of the Seattle Comprehensive Plan regarding Land Use Categories. The goals and policies in this Comprehensive Plan section describe the different areas that the City has defined in the context of existing conditions and the urban village strategy. Each of the City’s land use categories is intended to lead to a different set of building types and uses.

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The land use designation applicable to the proposed development is addressed in goal LUG30 and policies LU 175–177. Relevant policies support the overall goal: Promote Downtown Seattle as the home to the broadest mix of activities and greatest intensity of development in the region. Promote the continued economic vitality of Downtown Seattle with particular attention to the retail core and the tourism industry (LUG30). Policies include designating as Downtown those areas that are intended to accommodate the densest mixed-use, residential, office and retail development (LU 175); recognize the division of Downtown into areas with one of the following primary land use functions: Office, Retail, Mixed-use commercial, Mixed-use residential, and Harborfront (LU176); and use a range of Downtown land use zones to support the existing character and desired environment of different areas downtown (LU 177). The proposed development involves establishment of new office, hotel, retail/restaurant uses, and residential use at the greatest intensity of development and includes a mix of uses consistent with the Land Use Element as well as the Downtown Urban Center/Commercial Core Urban Village land use designation discussed above. The extent to which the project supports the existing character and desired environment Downtown is discussed below under Land Use Code Regulations which is the mechanism to implement the Comprehensive Plan.

Housing Element The Growth Management Act calls for a housing element to encourage the availability of affordable housing to all economic segments of the population of this state, promote a variety of residential densities and housing types, and encourage preservation of existing housing stock (RCW 36.70A.070(2)). The Housing Element of the Comprehensive Plan contains goals to accommodate 47,000 additional households over the 20 years covered by the Plan (HG1); maintain housing affordability (HG2); achieve greater predictability in project approval timelines, achievable densities and mitigation costs (HG3); encourage housing diversity and quality (HG4–9); and providing affordable housing to low income households (HG12–17). Policies relevant to Downtown include: provide adequate regional development capacity to accommodate expected residential growth and anticipated demand for different types of housing (H1); maintain zoning capacity to accommodate the City’s share of King County household growth (H2); take a leadership role in regional efforts to provide affordable housing preservation and production (H3); encourage residential use in mixed-use development in downtown and neighborhood commercial zones (H4); provide incentives that encourage public agencies, private property owners and developers to build housing that helps fulfill City policy objectives (H8); coordinate housing, land use, human services, urban design, infrastructure and environmental strategies to support pedestrian-friendly communities that are well-served by public transit (H9); strive to make the environment, amenities, and housing attributes in urban villages attractive to all income groups, ages and household types (H11). Policies for affordable housing are found in goals HG12 – 17 and policies H30–49.

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The 20-year growth target (2004–2024) is 10,000 new households in the entire Downtown Urban Center in addition to the 15,700 present in 2004 with 300 new households, in addition to the existing 3,070 for the Downtown Commercial Core. (Seattle 2005b). Permitted residential development in the core totals 622 residences, or more than twice the target with 6,288 permits for residences issued in the entire urban center (Seattle 2014a.) There currently is no housing on the development site. The proposed development includes about 178 residential units. It would contribute to an increase in residential units in Downtown Seattle. The housing is anticipated to all be market rate. The Seattle Land Use code establishes an incentive bonus system which allows a developer to earn additional floor area by contributions to affordable housing. This development proposes to earn incentive floor area through Seattle Municipal Code Section 23.58A.024 for affordable housing by paying a fee-in-lieu.

Economic Development Element The Economic Development Element of the Comprehensive Plan promotes a sound economy through planning for future growth in ways that maintain the city’s high quality of life by directing facilities and services to areas that support jobs and by identifying and encouraging economic sectors that offer the best opportunities for new job creation and future economic growth. Relevant goals and policies seek to add approximately 84,000 jobs in the city over the 20-year period (2004–2024) covered by the Plan (Goal EDG1); recognize that Seattle’s high quality of life is one of its competitive advantages and promote economic growth that maintains and enhances this quality of life (Goal EDG2); support the Urban Village Strategy by encouraging the growth of jobs in Urban Centers and Hub Urban Villages (EDG3); accommodate a broad mix of jobs while actively seeking a greater proportion of living wage jobs that have greater benefits to a broad cross section of the people of the City and region (EDG4). The urban Village Strategy is central to the City’s economic development effort and includes the goals to strive to maintain the economic health and importance of Downtown as the economic center of the city and the region and as home to many of Seattle’s vital professional service firms, high technology companies, regional retail activity, as well as cultural, historic, entertainment, convention and tourist facilities (ED1); strive to provide a wide range of goods and services to residents and businesses in urban centers and villages by encouraging appropriate retail development in these areas (ED3); encourage key sectors of Seattle’s economy that provide opportunities for long-term growth (ED10); and create a local business environment that promotes the establishment, retention, and expansion of high technology industries in the city (ED12).

Neighborhood Planning Element The City of Seattle Comprehensive Plan provides for neighborhoods to develop their own plans to allow growth that relate to the unique character needs and livability. The proposal is located within the Commercial Core neighborhood. Relevant neighborhood goals and policies envision downtown as the pre-eminent regional center, a compactly developed area supporting a diversity of uses meeting the employment, residential, shopping, culture, service and entertainment needs of the broadest range of the region’s population (DTG1.) The plan seeks to encourage economic

2-12 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum development activities consistent with the Comprehensive Plan to attract and retain businesses and to expand employment and training opportunities for Seattle area residents (DTG2.) Policies seek to use regulations in the Land Use Code and other measures to encourage public and private development that contributes positively to the downtown physical environment (DTG4). The office concentration goal seeks to accommodate the needs of a wide range of office and commercial activities by concentrating the densest office activity in a compactly developed core area (DTG5). The proposed project would provide additional high density office space which supports the goal of maintaining the Downtown and Commercial Core as a major employment center. Proposed retail use supports maintaining the area as a shopping magnet. The proposed hotel supports the area as a tourist and convention attraction. Proposed housing units support the Commercial Core as residential neighborhood. The unique design of the proposed building supports variety in architectural character and building scale. The design of street frontages and retail space improves pedestrian qualities of streets and public spaces. Proposed public open space responds to policies for new public open space. The intensity of development supports use of transit and supports regional transit plans through providing ridership. The discussion of Land Use Code regulations below addresses the urban design strategy for development.

Compliance with Seattle Land Use Code Regulations Zoning Designation: The project site is designated Downtown Office Core 1 (DOC1) as indicated in Figure 2-1. Height: The DOC1 zoning district allows buildings with unlimited height (SMC 23.49.008). Floor Area Ratio (FAR): The major development standard that regulates the bulk and scale of development in the DOC1 zone is the “floor area ratio” (FAR) which is the ratio between site area and floor area. The base FAR that is allowed in the DOC 1 zone is 6 and the maximum FAR is 20 as provided by SMC SMC 23.49.011. The area of the project site, for the purpose of FAR calculation, is 208,574 square feet which includes:  The entire block bounded by Fourth Avenue, University Street, Fifth Avenue, and Union Street,  Half of the block to the east of Fifth Avenue containing the Skinner Building, and  The area of Fifth Avenue which is not a dedicated right of way, is therefore under the ownership of the University of Washington, and is used by the public by permission. Based on this site area the base FAR of 6 provides for 1,251,444 square feet of building floor area. The existing buildings on the site to be retained include the Rainier Tower and the Skinner Building with a total of 704,787 chargeable square feet. The proposed development includes 843,473 square feet of floor area chargeable to FAR. The residential floor area of about 281,640 is not charged to FAR in accordance with SMC 23.49.011.B.1.f as are some other categories of land use. Together with existing buildings the total proposed floor area chargeable for FAR is 1,548,260 gross square feet. The difference between the proposed floor area of 1,548,260 square feet and the allowable floor area at

Rainier Square Development 2-13 University of Washington Metropolitan Tract Environmental Impact Statement Addendum base FAR of 6.0 is 296,816 square feet (1,548,260-1,251,444=296,816). This additional floorarea must be earned through the bonus incentive system. Pursuant to SMC 23.49.012.C (Cash Option Payments) the applicant will enter into a volumtary agreement to make a cash payment in-lieu of providing low-income housing to achieve the required bonus amenities for 296,816 square feet over the base FAR of 6.0.

Figure 2-1. Downtown Zoning

Departures from Development Standards The development includes a request for five departures from several development standards. A development standard departure allows a project design to achieve flexibility in the application of most of the prescriptive land use code standards or requirements if an applicant demonstrates that it would result in a development that meets or exceeds the intent of the adopted design guidelines. Departure #1 Development Standard: 23.49.058.B Façade Modulation Requirement Requirements: The maximum length of a facade without modulation is prescribed in Land Use Code Table 23.49.058A. This maximum length shall be measured parallel to each street property line, and shall apply to any portion of a facade, including projections such as balconies, that is located within fifteen (15) feet of street property lines.

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Departure Amount Requested: Above 240 feet the dimensions of the tower are 120 feet by 120 feet. This exceeds the maximum length of un-modulated façade within 15 feet of the property line as prescribed by Table 23.49.058A. Rationale: The proposed design is intended to become a bold, iconic landmark that complements and enhances the entire surrounding area. Its curvilinear geometry and massing is composed in a way that evokes both the neighboring architectural context as well as broader urban and topographical themes. The tower’s position and dimensional configuration at the site’s northwest corner gives the maximum possible buffer of space to Rainier Tower, and the sloping massing ensures that both towers benefit from the sweeping panoramic views afforded by the site’s position, as well as maximizes access to light and air at the street level. Departure #2 Development Standard: 23.54.035.A Quantity of Loading Spaces Requirement: The minimum number of off-street loading berths required for specific uses set forth in Table A, Section 23.54.035, would require 14, 35-foot-long berths. Departure Amount Requested: 4, 35-foot-long berths 1, 35-foot-long berth 8, 35-foot-long berths Rationale: The vertical and horizontal dimensional constraints of the site make it impractical to satisfy the number of required loading berths along with requisite maneuvering and circulation areas. This departure would enable the loading dock to be better sized and more efficiently designed to meet the true loading demands of the building users. Departure #3 Development Standard: 23.54.030.D.3 Driveway Slope Requirement: The maximum driveway slope is 15 percent. Departure Amount Requested: Union Street Access Ramp (Entry/Exit): 17 percent University Street Access Ramp (Exit): 20 percent Portions of internal garage circulation ramps: 20 percent Rationale: The vertical and horizontal dimensional constraints of the urban site require shorter ramping distances in order to design an efficient loading area and underground parking garage. Departure #4 Development Standard: 23.54.030.B.1.b. Parking Requirement: When more than five parking spaces are provided, a minimum of 60 percent of parking spaces shall be striped for medium vehicles. Departure Amount Requested: 34.6 percent of residential stalls are striped for medium vehicles. Rationale: Due to the limited area of the site available for underground parking, a smaller percentage of medium size spaces can be accommodated. Departure #5 Development Standard: 23.49.018 Overhead Weather Protection

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Requirement: a. A continuous overhead weather protection shall be required for new development along the entire street frontage of a lot. d. The lower edge of the overhead weather protection must be a minimum of ten (10) feet and a maximum of fifteen (15) feet above the sidewalk. (Criteria b. and c. are not proposed to be departed from.) Departure Amount Requested: Canopies are not contiguous along all streets. Some areas of canopies shown along Fourth and Fifth Avenues exceed the maximum height requirement (16 feet and 20 feet, respectively). Rationale: Along Union Street, a major canopy is located in front of the lobby area is proposed for the office tower in order to emphasize the building entrance. The land use impacts of the proposal are well within the land use projections and impacts of the adopted Downtown Height and Density Changes EIS and consistent with Comprehensive Plan Policies designating the Downtown as intended to accommodate the densest mixed-use, residential, office and retail development.

2.1.4 Mitigation Measures It is the intent of the State Environmental Policy Act that, if regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts, additional mitigation should not be imposed (RCW 43.21C.240, WAC 197-11-660(1)(g)). Seattle’s Environmental Policies and Procedures (SMC 25.05.660.A.5) directs considering whether local, state, or federal requirements and enforcement would mitigate an identified significant impact before requiring mitigation measures. The project is generally consistent with the goals and policies set forth in Section B of the Land Use Element of the Seattle Comprehensive Plan as provided in SMC 25.05.675.J. 2. The requirements in the City's development regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts of the project action as provided by SMC 25.05.660.7. A project that is approved pursuant to the design review process is presumed to comply with the applicable City land use regulations, as well as the goals and policies set forth in Section B of the Land Use Element of the Seattle Comprehensive Plan regarding Land Use Categories.

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2.2 Housing

2.2.1 Downtown Height and Density EIS The DHDC EIS characterized housing largely based on the 2000 census. The EIS identified three predominant housing types in Downtown Seattle: subsidized apartments, condominiums, and privately owned market-rate rental apartments.  Subsidized units accounted for approximately 45 percent of all Downtown housing units and two-thirds or more of the housing units in the Chinatown/International District, Pioneer Square and Denny Triangle. Over 25 percent of all of Seattle’s subsidized units were located in Downtown, an area with only 5 percent of all units. Buildings with subsidized housing were owned by market-rate owners, non-profit housing agencies or public agencies.  Condominiums accounted for approximately 20 percent of the housing stock. They were most prevalent in the Belltown and Commercial Core neighborhoods, representing 27 percent and 20 percent of the housing units, respectively.  Market rate rentals accounted for 45 percent of the units in the Belltown neighborhood, but represented a much smaller share of the housing stock in other Downtown neighborhoods. The DHDC EIS reported the 2000 census counts of 12,852 residential units in the downtown. Of these, 45 percent were subsidized, 35 percent were market-rate rentals, and 20 percent were condominiums. The Office Core had 2,780 housing units, or 22 percent of the total with 44 percent subsidized, 29 percent market-rate, and 26 percent condominium. The DHDC EIS concluded that all alternatives would result in transformation of housing stock through increased residential densities. This transformation was found to be consistent with the City’s Comprehensive Plan and neighborhood plans for the study area and not an adverse impact. Under all of the alternatives some existing housing might be demolished. Some households with employees in new Downtown Seattle office buildings and hotels would have difficulty finding affordable housing to meet their needs in King County. They would need to live in overcrowded conditions, pay more than 30 percent of their income for rent, or commute from lower priced housing outside of King County. Those few households not able or willing to make these choices could potentially become homeless. However, those demolitions and the difficulties that some households with Downtown employees would face finding appropriate housing would be as likely to occur under the previously existing conditions as under any of the alternatives considered, and were not significant adverse impacts of the alternatives. (DHDC DEIS page 3-17) A positive impact of the alternatives (including the Preferred Alternative) was the projected increase in housing bonus program funds for affordable housing that, if leveraged, could provide for more housing units developed Downtown than under the existing zoning. These funds, when leveraged with other resources, could contribute to the production of between 3,600 units under the previously existing conditions to over 8,000 units, depending upon the alternative. (DHDC FEIS page 3-3)

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In DOC 1 and DOC 2 zones, the DHDC EIS analysis concluded that property owners in the future would seek to maximize development opportunities for both uses, where possible. While commercial development would likely be the primary choice for development in these zones, in situations where the permitted zoning envelope allows additional development potential beyond what is required to accommodate the maximum permitted density of commercial use, the assumption was that developers would increasingly seek to maximize the value of their sites by including other uses, such as housing (DHDC FEIS page 5-8). A variety of Comprehensive Plan Housing Element goals and objectives were assessed including the following:  Goal HG4 – Achieve a mix of housing types attractive and affordable to a diversity of ages, incomes, household types, household sizes, and cultural backgrounds.  Goal HG14 – Preserve existing low-income housing, particularly in urban centers and urban villages where most redevelopment pressure would occur.  Policy H2 – Maintain sufficient zoned development capacity to accommodate Seattle’s projected share of King County household growth over the next 20 years as provided for and described in the Land Use Element.  Policies H8 and H30 – Use regulations and incentives to fulfill housing goals and promote production and preservation of low income housing. The DHDC EIS concluded that all alternatives would assist with the creation of new housing for a range of income groups within Downtown Seattle, consistent with land use and transportation policies and in close proximity to employment. The alternatives considered in the EIS were examples of zoning and regulatory changes intended to further encourage private owners, developers and public agencies to build additional housing and help fulfill City policy objectives for housing. (DHDC DEIS page 3-17 through 3-27)

2.2.2 Addendum Information on Affected Environment This section references City of Seattle policies for this element of the environment and provides an update to existing conditions to the extent they have changed since the DHDC Final EIS in 2005. Seattle Municipal Code (SMC) 25.05.675 contains specific environmental policies for elements of the environment. Subsection I. 2. contains housing policies including: a. It is the City's policy to encourage preservation of housing opportunities, especially for low income persons, and to ensure that persons displaced by redevelopment are relocated. b. Proponents of projects shall disclose the on-site and off-site impacts of the proposed projects upon housing, with particular attention to low-income housing. c. Compliance with legally valid City ordinance provisions relating to housing relocation, demolition and conversion shall constitute compliance with this housing policy.

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d. Housing preservation shall be an important consideration in the development of the City's public projects and programs. The City shall give high priority to limiting demolition of low- income housing in the development of its own facilities.

Site Conditions The site currently contains no housing.

Consistency with Plans, Policies and Regulations The Growth Management Act calls for a housing element to encourage the availability of affordable housing to all economic segments of the population of this state, promote a variety of residential densities and housing types, and encourage preservation of existing housing stock (RCW 36.70A.070(2)). The Housing Element of the Comprehensive Plan contains goals to accommodate 47,000 additional households over the 20 years covered by the Plan (HG1); maintain housing affordability (HG2); achieve greater predictability in project approval timelines, achievable densities and mitigation costs (HG3); encourage housing diversity and quality (HG4–9); and providing affordable housing to low income households (HG12–17). Policies relevant to Downtown include: provide adequate regional development capacity to accommodate expected residential growth and anticipated demand for different types of housing (H1); maintain zoning capacity to accommodate the City’s share of King County household growth (H2); take a leadership role in regional efforts to provide affordable housing preservation and production (H3); encourage residential use in mixed-use development in downtown and neighborhood commercial zones (H4); provide incentives that encourage public agencies, private property owners and developers to build housing that helps fulfill City policy objectives (H8); coordinate housing, land use, human services, urban design, infrastructure and environmental strategies to support pedestrian-friendly communities that are well-served by public transit (H9); strive to make the environment, amenities, and housing attributes in urban villages attractive to all income groups, ages and household types (H11). Policies for affordable housing are found in goals HG12 – 17 and policies H30–49. The Comprehensive Plan 20-year growth target (2004–2024) is for 10,000 new households for the entire Downtown Urban Center with 300 new households, in addition to the existing 3,070 for the Downtown Commercial Core, with a target of (Seattle 2005b). The Seattle DPD estimated that housing in the Downtown urban Core increased by 7,096 units between 2005 and 2014. In addition 2,864 additional housing units have been permitted but not yet built. The total of all these units is 9,960 units and almost meets the residential growth target of 10,000 new households for the Downtown Urban Center (Seattle 2014a). In the Commercial Core, the increase in occupied housing units from the 2000 census to the 2010 census was from 2,377 units to 2,985, a total of 609 units, or more than twice the target of 300 (Seattle 2011). Rental units comprised 78 percent of units and owner-occupied 22 percent of units. Sixty percent of units were occupied by single-person households, 22 percent by two-person households, and the balance of 18 percent by larger households (Seattle 2014b).

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2.2.3 Addendum Information on Impacts

Preservation of Housing Opportunities There is no existing housing on the site and no housing opportunities will be lost for either market rate or for low-income persons. No persons would be displaced by redevelopment and therefore no persons need be relocated.

Additional Housing The project proposes to provide about 170 new market-rate housing units, an increase of about 6 percent over the existing housing units in the downtown core and about 57 percent of the Comprehensive Plan growth target of 300 units, which has already been exceeded. This is consistent with the conclusions of the DHDC EIS that all alternatives would assist with the creation of new housing for a range of income groups within Downtown Seattle, consistent with land use and transportation policies and in close proximity to employment. Exceeding the target for residential growth in the downtown is generally consistent with Comprehensive Plan policy LG16 that aims to accommodate the greatest concentration of housing in desirable, pedestrian-oriented urban neighborhoods having convenient access to regional transit stations, where the mix of activity provides convenient access to a full range of residential services and amenities, and opportunities for people to live within walking distance of employment. Accommodating a greater proportion of residential development downtown is likely to result in less environmental impact on both the built and natural environment than developing the same number of lower intensity housing units in other portions of the city and region. The project will contribute to an increase in the supply of affordable housing by a voluntary agreement to make a cash payment for bonus floor area (SMC 23.49.012.C).

Mitigation Measures It is the intent of the State Environmental Policy Act that, if regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts, additional mitigation should not be imposed (RCW 43.21C.240, WAC 197-11-660(1)(g)). Seattle’s Environmental Policies and Procedures (SMC 25.05.660.A.5) directs considering whether local, state, or federal requirements and enforcement would mitigate an identified significant impact before requiring mitigation measures. The project is generally consistent with the goals and policies set forth in Section B of the Land Use Element of the Seattle Comprehensive Plan as provided in SMC 25.05.675.I.2. and the project does not reduce the existing supply of affordable housing and contributes to the increase in affordable housing through a voluntary payment.

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2.3 Urban Design – Height, Bulk and Scale

2.3.1 Downtown Height and Density EIS The DHDC EIS described impacts on height, bulk and scale in terms of policies in the Comprehensive Plan that permitted height and bulk should achieve the following:  Accommodate desired densities of uses and communicate the intensity and character of development in different parts of Downtown.  Protect the light, air and human-scale qualities of the street environment, particularly in areas of distinctive physical and/or historic character.  Provide transition to the edges of Downtown to complement the physical form, features and landmarks of the areas surrounding Downtown. (DHDC DEIS page 3-73) Policy objectives cited included the following:  A general tapering of height limits is desired from an apex in the Office Core downward to the perimeter of Downtown to provide transitions to the waterfront and neighborhoods adjacent to Downtown.  Development standards are meant to guide the form and arrangement of large buildings to reduce shadow and wind impacts at the street level, promote a human scale, and maintain a strong physical relationship with the pedestrian environment. In areas where consistency of building form is important to maintaining an identifiable character and function, building bulk is to be regulated to integrate new and existing development.  The bulk of tall buildings is to be limited in residential areas to provide for light, air and views at street level and reduce the perceived scale of buildings.  Development standards are to vary by district to reduce the impacts of large-scale buildings consistent with the desired scale and development pattern in the area. (DHDC DEIS page 3-73) Additional policies specifically related to height and scale in affected zones included:  DOC 1 – Allow the highest density of commercial development in Downtown, with development standards regulating building design to reduce adverse impacts, including impacts on sidewalks and other public areas.  DOC 2 – Provide for scale and density transitions to adjacent areas.  DMC – Promote development diversity and compatibility with adjacent areas through a range of height limits. (DHDC DEIS page 3-73) The DHDC DEIS noted that the previous downtown zoning employed a variety of measures to address issues of development scale. While the FAR density limits on commercial use and the height limits

Rainier Square Development 2-21 University of Washington Metropolitan Tract Environmental Impact Statement Addendum help define the overall building envelope for development in these zones, additional measures that control building bulk include:  Property line setback limits and minimum façade heights that address street level conditions.  Building coverage limits and maximum façade widths that apply to the upper level of development.  View corridor setbacks in some DOC 1 and DMC locations. (DHDC DEIS page 3-73) Since residential use was proposed to be exempt from the FAR density limit, the height limit and these development standards would provide the only restrictions on the permitted scale and bulk of residential structures. Consequently, mixed-use and residential projects can be bulkier and potentially taller than commercial only projects subject to the FAR limit. (DHDC DEIS page 3-73) The height and size of structures affect the Downtown environment and the public's perception of that environment, in several ways. Some of these impacts are relatively objective—taller bulkier buildings are more visible, they cast shadows over a larger area, and can contribute to a new scale of development that is considerably different than the established pattern in the area. Other impacts are more subjective and qualitative. Some of these impacts are addressed in City policies which often seek to strike a balance between allowing bigger buildings to accommodate growth and maintaining the positive characteristics that contribute to the existing feel of the Downtown environment. To help achieve this balance, these policies have led to regulations intended to maintain compatibility between new projects and established development in an area, as well as to ensure a compatible relationship between development conditions in adjacent areas.

Height Height was discussed in the DHDC DEIS in terms of the number of projected new buildings by height range and how heights of new buildings relate to the zoning in the alternatives. The number of buildings projected within different zoning districts, and therefore with different height and floor area potential, was based on a model predicting redevelopment of sites that was largely based on existing development intensity. Future building height was compared with the existing 12 buildings that reach or exceed 450 feet, as well as seven of these that also exceed 540 feet and five structures that exceed 585 feet. Based on the model of redeveloped sites, one building was projected to be developed higher than 500 feet, with between 13 and 28 higher than 400 feet, depending on the alternative. The new tall buildings were projected to be dispersed in Commercial Core due to the relative scarcity of sites the land use model predicted for redevelopment. (DHDC DEIS page 3-76) It was noted that site size and FAR limits height, that maximum height can only be attained in the largest lots, and that the residential component of mixed-use development is exempt and can lead to taller buildings (DHDC DEIS page 3-76). The Preferred Alternative discussed in the DHDC FEIS considered a 700-foot maximum non-residential height limit for the Office Core (DHDC FEIS page 1-2). The subsequent adopted code included no height limit for the DOC 1 zoning district. City Council adoption notes pointed out that Federal Aviation Administration (FAA) airspace requirements for aircraft approaching Boeing Field provide

2-22 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum that buildings extending above the height of the (or even somewhat lower heights in some locations) would generally not be permitted (Seattle 2006a). The increases in height limits would allow structures with smaller, less bulky floor sizes to accommodate the additional density proposed. Modified upper-level development standards would also continue to ensure relief in the massing of structures to make them appear less bulky from the street level. (DHDC FEIS page 3-3)

Bulk Bulk was analyzed in the DEIS based on the following criteria:  Development density  Site size

 Height and density relationships in zoning—how allowable bulk relates to allowable height in determining how buildings are designed in different parts of Downtown

 The patterns of massing of bulk in areas of Downtown due to future development The first three parameters were used for a pro-forma prediction of the character of development that would be likely to occur under different sets of zoning options. Consideration of impacts in the DHDC EIS related to a structure’s bulk, which is a function of the structure’s height and coverage of the site from ground level to the top, the spacing between structures, the degree of vertical and horizontal modulation in structures, and the balance of solids and voids in an area. These factors influence the perception of bulk and contribute to the sense of whether an environment is comfortable or not. Furthermore, the bulk of new structures in relation to existing buildings influences perceptions of how well new development fits in with its surroundings. While these perceptions may be subjective, they are influenced by specific impacts attributable to bulk, including shadows and view reduction. (DHDC DEIS pages 3-76 to 80) The conclusion of the DHDC EIS was that Alternative 1 would likely result in the fewest and generally the bulkiest projects. Additional bulk from residential and other “exempt” uses could result in perceptions of excessive bulk that could become more pronounced as more mixed-use and larger residential development occurs. Since residential use is exempt from floor area calculations, the actual FAR achieved in a project could be considerably greater than the maximum FAR limit proposed for commercial uses. (DHDC DEIS pages 3-76 to 80) The discussion of the Preferred Alternative in the DHDC FEIS concluded that the increases in height limits would allow structures with smaller, less bulky floor sizes to accommodate the additional density proposed. Modified upper-level development standards would also continue to ensure relief in the massing of structures to make them appear less bulky from the street level. (DHDC FEIS page 3- 3)

Scale The term “scale” was used in the DHDC DEIS to describe the characteristics of new development in relation to the surrounding development context. The discussion covered both the existing built

Rainier Square Development 2-23 University of Washington Metropolitan Tract Environmental Impact Statement Addendum context—what actually exists on the ground at the time—and the potential built context that could be created by future development. The analysis (DHDC DEIS page 3-83) considered the elements of:  Transition  Development compatibility  Landmark structures  Development diversity  Residential development Transition addressed differences in the scale and intensity of development between the high-density Office Core and adjacent, less-intensive neighborhoods. The previous code provisions and all the alternatives provided varying levels of gradual or abrupt changes in height, bulk and scale. (DHDC DIES page 3-83) The Preferred Alternative included a "grow-from-the-core" future development pattern that foresees expansion of the Office Core northward with a surrounding vicinity oriented to mixed commercial uses. Some areas were rezoned to maintain development intensities similar to previous conditions while providing a transition between the portions of the Office Core where commercial densities are proposed to be increased, and less-intensive adjacent neighborhoods. (DHDC FEIS page 1-5) Development compatibility considered the relationship between new projects and existing development in an area. While previous Downtown zoning allowed new projects to be larger than much of what previously existed, consideration is also given to maintaining compatibility with existing development characteristics of an area. In general, the previously existing zoning allowed a larger scale of development than what existed in many areas, and the difference in this relationship under any of the DHDC alternatives was marginal. The zoning assigned to an area does not necessarily result in every site being developed to the maximum limits allowed. Specific measures, such as landmark preservation, variable-scale TDR, incentives for small lot development, and guidelines for street and alley vacations—to name a few—recognize the importance of integrating new projects into the existing development context. (DHDC DIES page 3-83) Landmark and historic resources impacts included consideration of the physical relationship between future development and adjacent landmark structures, and whether those conditions negatively affect the qualities of the landmark structure. For all alternatives, including development that could occur under the previously existing zoning, new projects on adjacent sites would be substantially greater in scale than the existing landmark structures. Landmark buildings tend to be similar in terms of scale, materials (all brick structures), age, and architectural style—they contrast dramatically with the modern skyscrapers around them. Additional development filling in available sites nearby would intensify this condition. However, in this setting, it is the dramatic contrast in scale and architectural character that contributes to the visual prominence of these landmarks. Under all the alternatives, additional development would further contribute to the architectural variety and diversity of scale in the area. Combined, the landmark structures would continue to

2-24 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum provide an enclave of pedestrian-oriented building scale among the skyscrapers. The historic low- density structures provide a feeling of openness and welcome sunlight. A significantly larger structure located on the same block could create a more incongruous scale relationship, where the new development could appear to overwhelm the abutting smaller landmark structure. (DHDC DIES page 3-85 to 3-90) Under all the alternatives, several sites in the vicinity landmark structures were projected to be likely to be redeveloped. The code changes would allow taller structures than the other alternatives, and if developed as residential or mixed-use projects, these structures could be quite bulky, given the limited bulk restrictions on residential use. Landmark structures would become visually less prominent in comparison to new larger structures on adjacent sites. (DHDC DIES page 3-90) Development diversity addressed the degree to which there is variation in the scale and character of development within an area. The combination of new and old structures, varied uses, and a mix of development scale and building types generally contribute to a more interesting urban environment; these conditions are supported by numerous Downtown development policies. In most Downtown areas, new development allowed by the proposed DHDC amendments were projected to be likely be more dispersed within the existing built environment, contributing to overall development diversity. Furthermore, because fewer sites would be required to accommodate projected growth under this alternative, more existing structures and uses would be expected to remain on sites otherwise likely to be redeveloped under the other alternatives. (DHDC DIES page 3- 90) Residential character included consideration of development scale as a component helping to define an area. The scale of residential buildings reflects their function; they generally have smaller floor sizes and are less bulky to allow natural light into internal living spaces. Design requirements for projects accommodating housing also often result in more open areas and generally less building coverage with increased spacing between structures and landscaping, all of which enhance the residential quality of an area. Details like windows and balconies also contribute to the residential scale of development. (DHDC DIES page 3-90) The Preferred Alternative included refined strategies that would address height, bulk and scale concerns. For commercial development, the proposed increases in height limits in the Preferred Alternative, which in several areas exceed those in the DEIS alternatives, was anticipated to allow structures with smaller, less bulky floor sizes to accommodate the additional density proposed. Modified upper-level development standards also were projected to ensure relief in the massing of structures to make them appear less bulky from the street level. For high-rise residential structures, maximum floor size limits and maximum wall dimensions were anticipated to provide more predictability regarding the allowed bulk of residential towers, and would result in structures that are taller but relatively more slender than what previously allowed.(DHDC FEIS page. 3-3)

2.3.2 Addendum Information on Project Impacts Seattle Municipal Code (SMC) 25.05.675 contains specific environmental policies for elements of the environment. Subsection G.2. contains height, bulk and scale policies including:

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A. It is the City's policy that the height, bulk and scale of development projects should be reasonably compatible with the general character of development anticipated by the goals and policies set forth in Section B of the Land Use Element of the Seattle Comprehensive Plan regarding Land Use Categories, the shoreline goals and policies set forth in Section D-4 of the Land Use Element of the Seattle Comprehensive Plan, the procedures and locational criteria for shoreline environment redesignations set forth in SMC Sections 23.60.060 and 23.60.220, and the adopted land use regulations for the area in which they are located, and to provide for a reasonable transition between areas of less intensive zoning and more intensive zoning. b. Subject to the overview policy set forth in SMC Section 25.05.665, the decision-maker may condition or deny a project to mitigate the adverse impacts of substantially incompatible height, bulk and scale. Mitigating measures may include but are not limited to: i. Limiting the height of the development; ii. Modifying the bulk of the development; iii. Modifying the development's facade including but not limited to color and finish material; iv. Reducing the number or size of accessory structures or relocating accessory structures including but not limited to towers, railings, and antennae; v. Repositioning the development on the site; and vi. Modifying or requiring setbacks, screening, landscaping or other techniques to offset the appearance of incompatible height, bulk and scale. c. The Citywide design guidelines (and any Council-approved, neighborhood design guidelines) are intended to mitigate the same adverse height, bulk and scale impacts addressed in these policies. A project that is approved pursuant to the design review process is presumed to comply with these height, bulk and scale policies. This presumption may be rebutted only by clear and convincing evidence that height, bulk and scale impacts documented through environmental review have not been adequately mitigated. Any additional mitigation imposed by the decision maker pursuant to these height, bulk and scale policies on projects that have undergone design review shall comply with design guidelines applicable to the project.

Compliance with Design Guidelines

Height The height of the non-residential portion of the office/residential tower in the proposed Rainier Square Development is 508 feet at the 39th floor. This would place it within the range of probable height predicted in the DHDC DEIS which predicted 13 to 28 buildings taller than 400 feet. Residential components of buildings were presumed to be subjected to unlimited height, which is consistent with the 846-foot height of the proposed tower.

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Scale The city environmental policies (SMC 25.05.675.G.2.c) provide that a project that is approved pursuant to the design review process as complying with design guidelines is presumed to comply with these height, bulk and scale policies. This presumption may be rebutted only by clear and convincing evidence that height, bulk and scale impacts documented through environmental review have not been adequately mitigated. The following addresses:  City design guidelines through summary of the Master Use Permit (MUP) application, and  Analysis of the following elements assessed in the DHDC DEIS:

o Transition

o Development compatibility

o Landmark structures

o Development diversity

o Residential development

City Downtown Design Guidelines The following City of Seattle Design Guidelines are relevant to the project and are addressed in the Master User Permit application. A-1 Respond to the physical environment. Develop an architectural concept and compose the building’s massing in response to geographic conditions and patterns of urban form found beyond the immediate context of the building site. The proposed tower is designed to communicate and respond to the dynamic geometry of Rainier Tower. The new tower completes the block, creating a holistic composition within which all buildings are part of a greater whole. The geometry of the tower is a nuanced, reciprocal response to Rainier Tower, complementing, balancing, and completing it. A-2 Enhance the skyline. Design the upper portion of the building to promote visual interest and variety in the downtown skyline. The proposal provides a sculpted building massing and façades, along with a palette of materials, textures, and colors that work together and build on and complement Minoru Yamasaki’s existing Rainier Tower and the surrounding urban context. The design provides a sculpted profile, façade articulation, and distinctive materials that add a unique element to the Seattle skyline. B-1 Respond to the neighborhood context. Develop an architectural concept and compose the major building elements to reinforce desirable urban features existing in the surrounding neighborhood. The development provides a mix of commercial, retail, arts and cultural uses. The proposed tower massing responds to the existing Rainier Tower while the massing and articulation of the base responds to opportunities for key retail uses at the corners and infill retail along all street fronts. The

Rainier Square Development 2-27 University of Washington Metropolitan Tract Environmental Impact Statement Addendum hotel is located at the southern portion of the site and steps down to respond to the urban form of adjacent development, B-2 Create a transition in bulk and scale. Compose the massing of the building to create a transition to the height, bulk, and scale of development in neighboring or nearby less intensive zones. The project site is entirely within the DOC 1 zone and is adjacent to the DRC 85/150 zone to the north. Massing modulation and façade articulation have been arranged to respond to the site’s urban design context, the existing street grid, street-level pedestrian uses, and existing surrounding development. B-3 Reinforce the positive urban form and architectural attributes of the immediate area. Consider the predominant attributes of the immediate neighborhood and reinforce desirable siting patterns, massing arrangements, and streetscape characteristics of nearby development. Repetition, variation, and contrast are all used in the proposed design to respond to the massing, scale, and architectural features in the surrounding area. Lighting, landscaping, street furniture, and overhead weather protection at the street level are designed to enhance the pedestrian and retail experience at the site and to complement the positive elements of the existing urban environment. B-4 Design a well-proportioned and unified building. Compose the massing and organize the publicly accessible interior and exterior spaces to create a well-proportioned building that exhibits a coherent architectural concept. Design the architectural elements and finish details to create a unified building, so that all components appear integral to the whole. The proposed design is intended to become a bold, iconic landmark that complements and enhances the entire surrounding area. Its curvilinear geometry and massing is composed in a way that evokes both the neighboring architectural context, as well as broader urban and topographical themes. The tower’s position at the site’s northwest corner gives the maximum possible buffer of space to Rainier Tower. The stepback transition from the 10th to the 39th floor starts at a common horizontal datum struck from the base of Rainier Tower’s transition from an inverted pyramid to the square tower and provides a unique silhouetted and identity. The sloping setback provides both towers with the benefit of views afforded by the site’s position. Curvaceous indentations above the street retail uses offer formal relief and define an iconic character. C-2 Design facades of many scales. Design architectural features, fenestration patterns, and materials compositions that refer to the scale of human activities contained within. Building facades should be composed of elements scaled to promote pedestrian comfort, safety, and orientation. Façades throughout the project will be designed to express the variety of uses within the development, while expressing the overall concept as a cohesive whole. Transparency, lighting, and a mix of retail uses at the street level provide pedestrian interest and activity day and night.

Other Criteria Additional elements of scale assessed in the DHDC DEIS include the following, discussed below:  Transition  Development compatibility

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 Landmark structures  Development diversity  Residential development Transition issues address differences in the scale and intensity of development between the high- density Office Core and adjacent, less-intensive neighborhoods. The location of the proposal near the center of Downtown and separated by several blocks from less intensive neighborhoods renders issues of transition of limited applicability. The location of the proposed tower is consistent with the grow-from-the-core future development pattern that maintains lower intensity development around the central core. Transition is currently provided to the First Hill neighborhoods to the east by one to three blocks of downtown development, by I-5, and by the tall residential towers on First Hill. First Hill is up to 150 feet higher than Downtown adding an equivalent of 10 to 15 stories. In addition, transition is provided by intervening buildings in the downtown, including the 46-story City Centre building, the 56-story Two , the 40-story Rainier Tower, the 20-story IBM Building, the 25- story Hilton Hotel, and the 18-story Crown Plaza hotel. Areas to the south, west and north are within high-intensity downtown Seattle neighborhoods and do not require transition. Development compatibility considers the relationship between new projects and existing development in an area. The 59-story, 846-foot height of the proposed building is generally consistent with existing buildings and other recent buildings proposed or approved in the Commercial Core. The largest building in Downtown is the 76-story, 943-foot-high Columbia Center five blocks to the south. The 56-story, 741-foot-high Two Union Square is two blocks to the east, with the 44-story, 581-foot- high City Centre building one block to the east. two blocks to the southwest is 55 stories and 772 feet high. Plaza, three blocks to the southwest, is 50 stories and 630 feet high. These buildings all provide a context of large-scale buildings into which the proposed building, at a height of 846 feet, fits with a consistent height and building bulk. Compatibility with the intent of the downtown design guidelines is discussed above. The building follows the intent of the guidelines in providing reduced building floor plates on upper floors which results in taller, more slender towers as compared with existing development. Landmark and historic resources in the vicinity include two City of Seattle landmarks to the north of the site, the four-story Great Northern Building on the northeast corner of Fourth Avenue and Union Street, and the 15-story 1411 Fourth Avenue Building on the northeast corner of the same intersection. The six- to eight-story Skinner Building occupies the block face on 5th Avenue between University and Seneca Streets directly east of the project site and is listed on the National Register of Historic Places. The 11-story Cobb Building is located west of the site on the south side of the west side of Fourth Avenue. The Fairmont Olympic Hotel, originally the Olympic Hotel, occupies the city block directly south of the project site and is listed on the National Register of Historic Places. The Great Northern Building was built in 1929 and housed the ticket office for the railroad of the same name. It is designated a City of Seattle Landmark (Ordinance 1147680) and is listed as eligible for the National Register of Historic Places (ID #65006624). It was designed by architect R.C. Reamer who

Rainier Square Development 2-29 University of Washington Metropolitan Tract Environmental Impact Statement Addendum designed the 1411 Fourth Avenue Building across Fourth Avenue, the Skinner Building, the Seattle Times building on Fairview Avenue, as well as other Seattle buildings. He is best known for the design of the Old Faithful Lodge at Yellowstone National Park and Lake Quinault Lodge in Olympic National Park (Kreisman 20014). The four-story building is noted for its Art Deco detailing at the window mullions and as a frieze at the top of the building. The balance of the block on Union Street to the west of the site is occupied by a two-story bank building. The northeast corner of Union and Fourth Avenue is occupied by the 15-story 1411 Fourth Avenue. It is designated a City of Seattle Landmark (Ordinance: 114771) and is listed in the National Register of Historic Places (ID # 91000633). The landmark designation identifies as features to be preserved: the roof, the entrance vestibule including the associated tobacco shop storefront, and the first floor elevator lobby of the interior. (Seattle 1988) The façade is native gray sandstone. It is noted for its strong vertical piers which taper into spires at the roofline that emphasize the vertical. Just above the ground floor retail space, Art Deco reliefs (interlaced Celtic knots capturing noble bestiary animals are an unusual feature among Seattle buildings) soften the austere piers. Additional detailing is located at friezes and panels located on piers, window bays, and bands at the parapet and between floors. (Kezmis 2009) The balance of the block is occupied by a 10-story office building to the west on Union Street, several two- to three-story retail buildings, and a 10-story office building to the north on Fourth Avenue. Across the street is the 21-story Puget Sound Plaza constructed in 1960 (Unico 2014). The highest portion of the proposed 59-story office/residential building is located across the street from these two landmark buildings and would provide a dominant skyline feature, but would have little effect on the integrity of the buildings as landmarks or the distinctive features for which they were designated. The new building would be about four times the height of the 1411 Fourth Avenue building and about 15 times the height of the Great Northern building. As such, it would likely be viewed as an entirely different type and scale of building. The existing newer buildings in the vicinity, such as the 21-story Puget Sound Plaza, and the 40-story Rainier Tower currently provide a context in which buildings of a larger scale and substantially different materials dominate the immediate area. The existing landmark buildings are designated for their individual features, including the Art Deco motifs that characterize their era. They are not part of, and do not depend on similar buildings in the area (as would a landmark district), for appreciation of the features which make them a landmark. The new office tower and retail use will further add variety of scale and design to the immediate area with existing buildings of greater height and modern facades. The proposed Rainier Square project will add to the diversity of the downtown, but will not change the unique character of these landmark buildings. The east side of Fifth Avenue facing the proposed building is occupied by the six- to eight-story Skinner Building listed on the National Register of Historic Places in 1979 (ID # 78002756)It also was designed by architect R.C. Reamer who designed the Great Northern and 1411 Fourth Avenue Buildings discussed above. The façade is of Wilkenson sandstone with metal detailing around exterior show windows and shop entrances. The building mass is broken up along the two uppermost stories by a recess section. Hipped parapets of red mission tile and a projecting cornice at the seventh- story define the roof of the building. The Fifth Avenue Theater entrance includes an imitation of Chinese wood temple design that starts at the recessed entry and continues into the lobby and auditorium.

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The Fifth Avenue Theater has been described as Seattle’s most extravagant and unique eclectic fantasy and the largest and most authentic example of traditional Chinese timber architectural style outside Asia. (Lentz 1978) The easterly portion of the block on which the building is located is occupied by the 24-story Hilton Hotel built in 1969 and the 20-story built in 1930 and added to in 1969. To the north, across Union Street, is located the 10-story Logan Building built in 1959 and the 46-story City Centre building constructed in 1989. To the south across University Street is the 20-story IBM Building built in 1964 (King County 2014). The 10-story base structure of the proposed building with the curved step back from the tenth to the 37th floor is located across the street from the Skinner Building. The highest portion of the proposed tower is set back slightly more than half the distance of the Union Street block. The base structure of the new building will be slightly higher than the Skinner Building with the tower about seven times the height. Because of the great differences in scale, the new tower would be perceived as an entirely different type and scale of building. The existing newer buildings in the immediate vicinity, which range from 19 to 46 stories in height with largely steel and glass facades, already provide a context in which the Skinner Building is a unique element. The Skinner Building is recognized largely because of the presence of the unique design of the Fifth Avenue Theater. It is not part of and does not depend on similar buildings in the area for appreciation of the features which make it “Seattle’s most extravagant and unique eclectic fantasy.” (Lentz 1978) The new office tower and retail use will further add to buildings of greater height with modern facades in the immediate area. The new buildings will add to the diversity of the downtown, and of this already diverse area, but will not change the character of either the exterior of the building or its unique theater. The 11-story Cobb Building on the south side of the west side of Fourth Avenue across from the project site is the last remaining building, within the 1907 Metropolitan Tract master plan, developed by the architectural firm Howells and Stokes. The three buildings with coordinated facades facing it on the east side of Fourth Avenue (the White, Henry, and Stuart Buildings) were demolished in the 1970s. (Crowley 2006) It is listed on the National Register of Historic Places (ID # 84003485). The building is L- shaped with almost identical street facades on University Street and Fourth Avenue. The first and second floors are clad entirely in ivory terra cotta, simulating cut stone, with clusters of vegetable forms in sculptured relief atop the second floor piers. Above the second story, six floors of offices are expressed very simply on the exterior by regularly spaced paired windows with terra cotta sills. The brick facing of the office levels is punctuated by dark-glazed headers. The ninth and tenth floors are distinguished from those below by the use of diamond-patterned tapestry brick in three colors and ornamented in terra cotta derived from the Beaux Arts catalogue of classical forms and from a more unusual group that resembles the popular image of a Plains Indian chief. (Sutermeister 1984, Walter 2006) The building was initially occupied by medical and dental offices and was converted to residential use in 2006 (Crowley 2006). The northern two-thirds of the Fourth Avenue block adjacent to the Cobb Building block is occupied by the 21-story Puget Sound Plaza built in 1960 with a marble facade punctuated by a grid of windows. Adjacent to the Cobb Building on University Street is a seven-story concrete parking garage constructed in 1966. Across the street from the Cobb Building on the south side of University Street is the 28-story Financial Center building built in 1972 with a concrete grid façade with pierced windows.

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The proposed 12-story hotel building is located across the street from the Cobb Building. The highest portion of the tower is located further north. The new hotel building will be slightly taller than the Cobb Building with the tower about six times taller. The hotel will be similar in scale to the Cobb Building, although with a largely glass façade it will contrast with the brick façade of the older building. The new hotel and office tower will further add to buildings of greater height with modern exteriors that are distinct in scale and materials from the Cobb Building. Because the Cobb Building is the unique example of its type in the downtown, and because it already contrasts in scale and design with other buildings in the immediate area, such as the adjacent 21-story Puget Sound Center, the proposed Rainier Square development will not appreciably change the status of the Cobb Building as a unique design enclave from another era of building design. The 12-story Fairmont Olympic Hotel occupies the city block directly south of the project site between 4th and 5th Avenues and between University and Seneca Streets. It was built in 1924 by a local company with 4,500 local stockholders. It is listed on the National Register of Historic Places (ID # 79002538). The nomination to the National Register states that it “has a number of claims to outstanding significance. It is located on an historic site. It was designed by an internationally famous firm whose founder was one of only forty architects in history to receive the A.I.A. Gold Medal. It is the only work by that firm known to exist in the Pacific Northwest. Its design is of intrinsically distinguished quality, an excellent example of the tradition of the Ecole des Beaux-Arts. It is a symbol of the unprecedented civic energy and spirit of the time, marking an epochal event in the civic and social development of the city. And it serves today in an urban design sense as an outstanding example of a traditional architecture complemented by other and later developments which surround it. Today the juxtaposition of the old and new structures enhances the Olympic's architectural qualities. The layering of eras with their varying qualities is essential to a rich urban environment. Around the intersection of Fifth Avenue and University Street, the urban design composition is delicately balanced with the old and new diametrically opposed. The Olympic is vital to the maintenance of that equilibrium. The Olympic offers an alternative to the late 20th century; the contrast is necessary for a mature and sensitive urban environment.” (Sutermeister 1979) Development on adjacent blocks includes the 20-story IBM Building built in 1964 to the east, the 40- story Rainier Tower with its unique 11-story inverted pyramid base to the north, the 28-story Financial Center building built in 1972 to the north, and the 25-story W Hotel and nine-story parking garage to the south. The proposed 12-story hotel building is located across the street from the Olympic Hotel. The highest portion of the tower is located further north. The new hotel building would be similar in elevation to the Olympic Hotel with the office/residential tower about six times higher. The narrow end of the proposed hotel would face the Olympic Hotel and present a smaller scale element along University Street. The proposed tower would be at the opposite end of the block and would be a secondary element in the composition of the character of University Street where the existing 40-story Rainier

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Tower, with its unique inverted pyramid base, contrasts with the Olympic Hotel’s traditional design elements. The new hotel and office tower will further add to buildings of greater height with modern exteriors that are distinct in scale and materials from the Olympic Hotel and add to the layering of architectural eras that contribute to the rich urban environment. The Olympic Hotel, occupying an entire city block, will continue to assert its rich architectural heritage within a varied urban context. The existing Rainier Tower is neither a City of Seattle designated landmark, nor eligible for the National Register of Historic Places because of its age. It is, however, a distinctive building that contributes to the identity of the immediate vicinity. The sculptural presence of the Rainier Tower inverted pyramidal base provides a distinctive signature defined where the buildings meets the ground. The proposal responds to this feature by providing a design that mirrors, or is the inverse, of the base of the Rainier Tower. The large curved, concave wall of the office/residential tower begins at the 10th floor at the elevation where the curved inverted pyramid of the Rainier Tower ends and carries the curved form upward to the 39th floor where it terminates in a square tower similar in dimensions to the Rainier Tower. The proposed office/residential tower terminates in a flat roof that provides an analogue to the roof of the Rainier Tower. Residential character as discussed in the DHDC EIS observed that the scale of residential buildings reflects their function; they generally have smaller floor sizes and are less bulky to allow natural light into internal living spaces. For high-rise residential structures, maximum floor size limits and maximum wall dimensions were anticipated to result in structures that are taller but relatively more slender than what was previously allowed. The office/residential building design with residential use at the top of a slender tower meets the residential character expectations that were the basis for the present zoning. (DHDC FEIS page 3-3) Impacts of the proposal is consistent with impacts on transition, development compatibility, landmark structures, development diversity and residential development considered in the adopted Downtown Height and Density Changes EIS.

2.3.3 Mitigation Measures It is the intent of the State Environmental Policy Act that if regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts additional mitigation should not be imposed (RCW 43.21C.240, WAC 197-11-660(1)(g)). Seattle’s Environmental Policies and Procedures (SMC 25.05.660.A.5) directs considering whether local, state, or federal requirements and enforcement would mitigate an identified significant impact before requiring mitigation measures. Compliance with Seattle design guidelines are intended to mitigate the same adverse height, bulk and scale impacts addressed in environmental policies in SMC 25.05.675.G.2. A project that is approved pursuant to the design review process is presumed to comply with these height, bulk and scale policies. The Master Use Permit process will address compliance with all standards and guidelines. The design is also reviewed by the Downtown Design Review Board. Height, bulk and scale impacts are addressed in the design guidelines that apply to the project.

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2.4 Urban Design – Pedestrian Amenities and Open Space

2.4.1 Downtown Height and Density EIS The DHDC EIS described impacts on pedestrian amenities and open space for the Commercial Core in the context of anticipated future development being dispersed and including commercial as well as public projects. Positive Impacts identified (DHDC DEIS page 3-114) included:  Improved pedestrian facilities – Given Pedestrian Street designations and requirements for street-level uses, new development was expected to contribute to an integrated, active streetscape. Development on vacant land abutting 5th Avenue near Yesler Way would also likely strengthen pedestrian connections between this part of the Office Core and the International District to the south.  Existing setback requirements were projected to aid in scale and bulk control – Along the western edge of the Office Core, upper level setback requirements along view corridors would help maintain a pedestrian scale and offset the bulky presence of towers by requiring lower heights for portions of the structure abutting these view streets.  New public open space in developments should benefit pedestrians – Several projects were projected to include some amount of public open space, especially public projects, which should provide pedestrians with some relief from the overall intensity of development in the area. Adverse impacts identified in the DHDC EIS included possible loss of older structures that may diminish variety and pedestrian orientation at street level. Larger projects are expected to replace many remaining, smaller-scale structures over time. These older, smaller-scale structures often add architectural interest and diversity and tend to have a stronger pedestrian orientation at street level. Their loss would likely result in less variety and interest in the streetscape. (DHDC DEIS page 3-114) Future development under any alternative was anticipated to result in increases to Downtown employment and residential populations, creating more demand for the use of existing open space resources. Through zoning requirements and incentives, as well as common development practices, some of this demand was anticipated to be met by development providing required open space to meet the needs of building occupants, as well as public open space to help augment existing public open space resources. Since the projected amount of office development was essentially the same for all alternatives, there was no significant difference between the alternatives in terms of the amount of open The DHDC EIS anticipated that a minimum of 5 percent of gross floor area would be requird as common recreation area for new development of more than 20 dwelling units with up to 50 percent of the recreation area enclosed. As a result of this requirement, the DHDC EIS anticipated that with

2-34 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum projected development over 20 years, available open space in the Commercial Core would total approximately 18.6 acres. This amount was anticipated to be the same across the alternatives. This amount did not account for any potential future public investments in open space. With projected residential growth and open space, the Commercial Core would far exceed the 1 acre of open space per 1,000 households goal, with 1 acre per about 150 households. (DHDC DEIS page 3-117)

2.4.2 Addendum Information on Project Impacts Pedestrian amenities and open space proposed to be provided by the proposal includes pedestrian sidewalks on the streets adjacent to the site. Existing pedestrian connections, such as the tunnel under 5th Avenue, will be maintained. Along the street frontages, a carefully curated mix of retail, restaurants, coffee shops, and lobby spaces are designed to engage the interest of pedestrians with multiple and varied storefronts, open façades, lighting, merchandising displays, areas for seating, and other activities that spill out onto the sidewalk to promote interaction. The open space for the proposed project has been configured to provide visual relief around the base of Rainier Tower, giving it “breathing room” and providing dramatic views of the base from the surrounding streets as well as from the common interior spaces of the new development. The massing composition of the proposed structures builds from a common pedestrian datum, or “plinth,” incorporating a variety of vibrant, pedestrian-oriented retail uses. This creates a “lifted urban garden” space that consists of a series of open spaces envisioned. A retail-oriented, central atrium space provides a market or hub space in the interior of the block, with a glass ceiling to introduce natural light and visual connection to Rainier Tower and the rest of the development. The project includes 15,000 square feet of open space pursuant to SMC 23.49.016 which requires 20 square feet of open space for each 1,000 square feet of office floor area. Open space for residential use is not required pursuant to SMC 23.49.010 because the project provides a voluntary agreement to provide funds for low income housing. Open Space is provided through an outdoor roof terrace of 7,914 square feet located on the third level on the south side of the office/residential tower and 6,470 square feet is provided on the east and south sides of the hotel. A 679-square-foot terrace and shared swimming pool is provided on the second hotel level. A 1,408-square-foot roof terrace is located on the 10th level on the east face of the office/residential building where the curved stepback begins. An additional residential amenity sky lobby and open space area is provided on the 39th and 40th floor. None of the open space is proposed to earn floor areas as part of the Floor Area Amenity system in the zoning code. The following City of Seattle Design Guidelines are relevant to the project and are addressed in the Master User Permit application. C-1 Promote pedestrian interaction. Spaces for street level uses should be designed to engage pedestrians with the activities occurring within them. Sidewalk-related spaces should be open to the general public and appear safe and welcoming. The proposed design goal is to create a pedestrian experience that complements and enhances the neighborhood as a retail, commercial, and cultural destination. Anchor retail space as well as smaller

Rainier Square Development 2-35 University of Washington Metropolitan Tract Environmental Impact Statement Addendum retail and restaurant uses occupy the majority of street-level frontage. Existing pedestrian connections, such as the tunnel under 5th Avenue, is proposed to be maintained and enhanced. Multiple building entries are proposed to serve the office, residential, and amenity spaces in the development. Pedestrian-scaled pattern and texture with high-quality urban detailing are proposed at all street-level façades and storefronts. C-2 Design facades of many scales. Design architectural features, fenestration patterns, and materials compositions that refer to the scale of human activities contained within. Building facades should be composed of elements scaled to promote pedestrian comfort, safety, and orientation. Façades throughout the project are designed to express the variety of uses within the development while expressing the overall concept as a cohesive whole. Transparency, lighting, and a mix of retail uses at the street level provide pedestrian interest and activity day and night. C-3 Provide active—not blank— facades. Buildings should not have large blank walls facing the street, especially near sidewalks The proposed development does not anticipate any blank walls facing the street. The project takes advantage of its prime urban location to create vibrant, attractive street-level façades that mesh with the surrounding urban retail and commercial context. C-4 Reinforce building entries. To promote pedestrian comfort, safety, and orientation, reinforce the building’s entry. Entries to the building are proposed to express the unique nature of their program uses. Materials and detailing are proposed to reflect the quality of the overall development and its place in the urban fabric. Entries are proposed to be clearly visible and identifiable from the street, as well as inviting and easily accessible with weather protection and integrated lighting. C- 5 Encourage overhead weather protection. Encourage project applicants to provide continuous, well- lit, overhead weather protection to improve pedestrian comfort and safety along major pedestrian routes. Weather protection is proposed at all street frontages, integrated with the overall design concept of the project and with relevant adjacent architectural features in the surrounding area. D- 1 Provide inviting & usable open space. Design public open spaces to promote a visually pleasing, safe, and active environment for workers, residents, and visitors. Views and solar access from the principal area of the open space should be especially emphasized. Because of the dense urban character of the site, the primary public open spaces occur on the surrounding sidewalks and at the major building entrances. Lighting, landscaping, adjacent retail, pedestrian-scaled signage, site furniture and other amenities are proposed to enhance the public urban experience. D- 2 Enhance the building with landscaping. Enhance the building and site with substantial landscaping—which includes special pavements, trellises, screen walls, planters, and site furniture, as well as living plant material. The landscape design incorporates a thoughtful and integrated approach to enhance the site, the urban experience, and the overall concept of the project.

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D- 3 Provide elements that define the place. Provide special elements on the facades, within public open spaces, or on the sidewalk to create a distinct, attractive, and memorable “sense of place” associated with the building. Distinctive architectural features and façade treatments, as well as integrated urban landscaping create an attractive sense of place for the entire development. D-4 Provide appropriate signage. Design signage appropriate for the scale and character of the project and immediate neighborhood. All signs should be oriented to pedestrians and/or persons in vehicles on streets within the immediate neighborhood. The project incorporates a unified, integrated approach to building and tenant signage and pedestrian wayfinding that complements and enhances the overall design concept for the development and works in concert with the broader neighborhood. D-5 Provide adequate lighting. To promote a sense of security for people downtown during nighttime hours, provide appropriate levels of lighting on the building facade, on the underside of overhead weather protection, on and around street furniture, in merchandising display windows, and on signage The project employs an integrated approach to lighting that enhances the design concept and distinctive features of the building, illuminates the adjacent sidewalks, and minimizes glare within the public right-of-way. D- 6 Design for personal safety & security. Design the building and site to enhance the real and perceived feeling of personal safety and security in the immediate area. The project is designed to promote a safe, secure environment for tenants, residents, shoppers, visitors and the general public. Impacts are consistent with the conclusions of the adopted Downtown Height and Density Changes EIS that future development would result in increases to Downtown employment and residential populations, creating more demand for the use of existing open space resources. The EIS concluded that some of this demand would be met by new development providing required open space to meet the needs of building occupants, as well as public open space.

2.4.3 Mitigation Measures It is the intent of the State Environmental Policy Act that if regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts additional mitigation should not be imposed (RCW 43.21C.240, WAC 197-11-660(1)(g)). SMC 25.05.660.A.5 directs considering whether local, state, or federal requirements and enforcement would mitigate an identified significant impact before requiring mitigation measures. Compliance with the zoning code and design guidelines is intended to mitigate impacts on pedestrians and open space. A project that is approved pursuant to the design review process is presumed to comply with policies relating to the pedestrian environment. The Master Use Permit process will address compliance with all standards and guidelines. The design is also reviewed by the Downtown Design Review Board.

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2.5 Views and Aesthetics

2.5.1 Downtown Height and Density EIS The DHDC EIS described impacts on views and aesthetics in terms of the policies in Seattle Municipal Code (SMC) 25.05.675.P. 2., Public View Protection, that address protection of views from public viewpoints, skyline views, views from scenic routes, and views of landmarks. The discussion also recognized other City objectives pertaining to urban design, and aesthetics as it relates to future development. The analysis recognized that the City’s zoning regulations in effect at the time accommodated a level of future development that would affect views from some locations, over time.

Public Viewpoints The City’s SEPA rules identify 87 locations where project impacts on views of natural and built features are to be addressed (SMC Section 25.05.675 P.2.a.i., Attachment 1). The DHDC DEIS identified approximately 26 locations have views of the Downtown skyline and/or views across Downtown toward natural features like Mt. Rainier, the Olympic Mountains or Elliott Bay. From some viewpoints, Downtown is just one of several observable features and may or may not be the most significant. Some of the views of Downtown are quite distant, and changes of the magnitude studied in the EIS analysis would be imperceptible. (DHDC DEIS page 3-126) A limited number of viewpoints were identified as having greater significance because of the prominence of Downtown buildings in the view. These included Kerry Park, Bhy Kracke Park, Belvedere Viewpoint, Jose Rizal Park, Four Columns Park, Hamilton Viewpoint, Harbor Vista Park, Alki Beach Park, Pac-Med Building (US Public Health Service Hospital) Viewpoint, Harborview Hospital Viewpoint, Victor Steinbrueck Park, Waterfront Park, Myrtle Edwards Park, and Gasworks Park. (DHDC DEIS page 3-126) These viewpoints provide several of the postcard views of Seattle’s Downtown and in many cases also offer views toward Puget Sound, Lake Union, Mt. Rainier or the Olympics. Harborview Hospital Viewpoint and Four Columns Park are the viewpoints nearest Downtown’s central Office Core, featuring both nearby cityscape and territorial views. Victor Steinbrueck Park offers attractive views east and south toward the Pike Place Market vicinity and the office/retail core, south toward Mt. Rainier, and west toward Puget Sound and the Olympics. Because of their greater significance and potential for negative outcomes, the EIS analysis focused on these viewpoints. (DHDC DEIS page 3- 126) Of the approximately 30 identified locations with viewpoints or view protection status, approximately 11 were identified as experiencing minimal or no impacts, due to their distance from Downtown and absence of any potential impairment of view features. Of the remaining 19 viewpoints, most would experience change only in the sense that the number and arrangement of buildings composing the Downtown skyline would be different from what is observable today due to changes over time. This

2-38 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum type of change was concluded to not vary substantially among the alternatives and was not considered a significant adverse impact. (DHDC DEIS page 3-126) Two viewpoints—Four Columns Park (Pike-Pine) and Harborview (First Hill)—were singled out in the DHDC EIS as examples of typical impacts. Four Columns Park, located just east of I-5 at Pike and Boren, is one of the closest viewpoints to the Downtown office/retail core. Its viewshed includes the portion of the study area that was likely to experience the greatest change from the proposed height and density changes. This viewpoint was not the location of the view impact study in the DHDC DEIS Figure 30 which was located farther to the north at I-5 and Republican Street. At the time of the DEIS analysis, views included the nearest buildings across I-5, such as the Convention Center with its canopy over Pike Street, Metropolitan Park Towers, Paramount Theater and Camlin Hotel, the larger Office Core buildings in the western middle ground, and Queen Anne Hill and a segment of Olympic Mountains in the background to the northwest. Vacant or underdeveloped lots and the Convention Place transit tunnel station at that time provided relatively large open expanses allowing views toward the west and northwest. Some building projects identified as already approved or under construction at that time were recognized as reducing views toward the northwest over time. This viewpoint was identified as most affected by projected future development in the Denny Triangle under any alternative, as well as by continued development outside the study area in Belltown, resulting in views from Four Columns Park toward the Olympic Mountains and Queen Anne (including the Queen Anne High School landmark) being gradually obscured. The impact attributable to increased height and bulk allowed for commercial development in the nearby DOC 2 and DMC zones was not expected to cause different types of visual impairment than already possible under previously existing regulations. (DHDC DEIS page 3-136) Harborview Viewpoint is a park/plaza approximately one block in length between Jefferson and Terrace Streets, plus a smaller elevated plaza on a newer structure to the south perched above and east of I-5, with views toward the Office Core, the southern portion of Elliott Bay, the Olympic Mountains, Duwamish lowlands and even Mount Rainier to the south. Views identified in the DHDC EIS toward the Office Core encompassed buildings nearest I-5 from the King County Jail north to approximately Two Union Square, as well as other buildings farther west within the Office Core. Only a couple of narrow gaps between buildings allowed views through to Puget Sound. Future development with or without zoning changes was not projected to generate significant adverse impacts on views toward the central Office Core because future development would contribute to the skyline without adversely impairing existing views. (DHDC DEIS page 3-136) The increase in permitted commercial density could result in taller, bulkier buildings within the identified block, with a greater total amount of visual impairment. However, under either height limit, the views of the south end of Elliott Bay and West Seattle would be similarly impaired. Views further to the south would not be affected. (DHDC DEIS page 3-137) Views from Kerry Park, Bhy Kracke Park, Belvedere Viewpoint, Jose Rizal Park, Four Columns Park, Hamilton Viewpoint, Harbor Vista Park, Alki Beach Park, Pac-Med Building (U.S. Public Health Service Hospital) Viewpoint, Harborview Hospital Viewpoint, Victor Steinbrueck Park, Waterfront Park, Myrtle Edwards Park, and Gasworks Park were all considered cases where the number and arrangement of

Rainier Square Development 2-39 University of Washington Metropolitan Tract Environmental Impact Statement Addendum buildings composing the Downtown skyline would be different but were not considered a significant adverse impact. (DHDC DEIS page 3-137) Views from the north illustrated by Kerry Park were projected to be largely affected by future development in Denny Triangle that would affect views to the southeast. Views of the Downtown core to the south were not considered to be substantially affected. From this viewpoint, Mt. Rainier continues to be visible to the east. None of the view impacts to Kerry Park’s viewpoint were interpreted to be significant adverse impacts. (DHDC DEIS page 3-138) Views from the west across Elliott Bay from the Belvedere and Hamilton viewpoints were primarily affected by future development in the Denny Triangle that extends the skyline further north. None of the view impacts to either the Belvedere or Hamilton viewpoints were interpreted to be significant adverse impacts. (DHDC DEIS page 3-138) Skyline views from the south were projected to experience less change than views from other directions. Nearly all future development north of the office core would not be visible from the south under any alternative. (DHDC DEIS page 3-138) Views from the east were projected to depend upon the viewer’s position with relatively little change from the southerly portion of First Hill because large buildings near I-5 already strongly define the skyline. Locations in Pike/Pine and the western slopes of Capitol Hill were projected to experience a change in views from future development in the Denny Triangle area which would extend the taller buildings of the skyline further north. (DHDC DEIS page 3-138)

View Protected Landmarks The City’s SEPA policies specify "it is the City's policy to protect public views of historic landmarks designated by the Landmarks Preservation Board which, because of their prominence of location or contrasts of siting, age, or scale, are easily identifiable visual features of their neighborhood or the City and contribute to the distinctive quality or identity of their neighborhood or the City." Twenty-three designated landmarks within (or visible from) the study area are identified for public view protection, based on this designation criterion used by the Landmarks Board. Eight of these are located within the study area, seven are within the retail core or Belltown, and eight are outside the study area but visible from portions of Downtown. Of the 23 view-protected landmarks identified, 11 were identified as subject to some level of potential impact from future development in the study area. Those without impact potential are located in areas where zoning would not change. (DHDC DEIS page 3-135) Some of the landmarks were identified as visible due to their height and/or prominent physical setting. Pacific Medical Center and Queen Anne High School were identified as noticeable skyline features outside the study area, visible from several locations due to their location on Beacon Hill and the ridge of Queen Anne Hill. A few church steeples, such as those of the Trinity Parish Church and Immanuel Lutheran Church, are also were identified as locally visible from portions of the study area. Several structures located outside of Downtown were identified as visible from limited locations within Downtown; however, the visual enjoyment of these structures was found to be primarily of interest to the neighborhood in which they are located, making visibility from adjacent areas like Downtown less of a priority. (DHDC DEIS page 3-127)

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The DHDC EIS observed that the city’s SEPA policy is not specific about the nature of protection provided for views of landmarks. There is little guidance about where the view of a particular landmark should be protected from, or the amount or particular aspects of the view that warrant protection. (DHDC DEIS page 3-127) The DHDC EIS stated that potential adverse impacts of all alternatives on view-protected landmarks would be generally similar because similar physical factors are relevant to all alternatives. Most of the landmark sites and structures specified for view protection are relatively small compared to potential future development allowed by land use regulations. The visual prominence of these structures would diminish as bigger buildings occupy adjacent sites under any alternative. In analysis of the Rainier Club as an example, the additional height and bulk of new structures were concluded to have little added impact on the character and relationship already established between these landmark structures and surrounding high-rise development. In many respects, the presence of these buildings would be even more dramatic because of the contrasts they provide in scale and architectural style. (DHDC DEIS page 3-135)

Scenic Routes The City’s SEPA policies address the protection of public views from City streets designated as scenic routes. “It is the City’s policy to protect public views of significant natural and human-made features: Mount Rainier, the Olympic and Cascade Mountains, the downtown skyline, and major bodies of water including Puget Sound, Lake Washington, Lake Union and the Ship Canal, from public places consisting of the specified viewpoints, parks, scenic routes, and view corridors identified in Attachment 1.” (SMC Section 25.05.675 P.2.a.i. and Attachment 1). The City’s designated SEPA scenic routes are identified on a map as Exhibit 1 to the City's SEPA policies (SMC 25.05.675, Exhibit 1). Since SEPA does not identify where view locations occur along these routes or specify the object of view, it is difficult to assess which characteristics of these scenic routes are to be protected under SEPA policies. Some scenic routes are oriented toward the aesthetic qualities of the immediate surroundings (such as green boulevards, neighborhood commercial streets or adjoining parks), while others have more distant views of natural features (mountains and major water bodies) and the city skyline. There is great variety in visual character along the routes—some portions do not have any appreciable scenic qualities. (DHDC DEIS page 3-128) The DHDC EIS noted that assessing view conditions on scenic routes also needs to consider the intended observer and direction of travel in relation to the view. Many of these routes, such as Aurora Avenue, the Alaskan Way Viaduct, and I-5, accommodate high volumes of traffic traveling at high speeds. While certain view features may be visible from these routes, the fact that the observer is traveling at high speed may limit the duration of specific views to brief glimpses. Some routes, such as 5th Avenue, are one-way streets, limiting the direction of views for motorists and transit riders. Other scenic routes may be traveled by slower traffic, including pedestrians and bicyclists, potentially expanding the scope and direction of views, as well as the length of time that features remain visible to the observer. (DHDC DEIS page 3-128)

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Scenic routes were reviewed in the DHDC EIS to determine the route segments that provide views of the Downtown study area and that were potentially affected by proposed changes to height and density limits. The DHDC EIS observed that changes to height and density limits in Downtown would affect specific scenic routes differently, depending upon how close the routes are to the study area. In many cases, the changes would affect only the general composition of the skyline as viewed from a distant location. This type of impact was addressed in the public viewpoint and skyline view impact discussions, and was not considered a significant adverse impact. Several scenic routes approach and enter Downtown. View changes along these routes would primarily involve changes in the skyline and greater presence of denser buildings in the middle ground or background of views. Once in Downtown, the views become more confined to adjacent development and whatever outward views may be possible down intersecting streets. (DHDC DEIS page 3-136) Of these routes, the scenic qualities of Dexter, Westlake and Fairview Avenues, Olive Way, southbound SR 99 and northbound I-5 would not be adversely impacted by future development in the study area. The DHDC EIS focused attention on Yesler Way as a scenic route providing views of the Downtown study area from the east and south. Future development could obscure some of the foreground views toward the King County Administration Building and King County Jail, but would not block views toward natural features or generate significant adverse impacts on this scenic route. Similarly, the alternatives would not result in further blocking of views toward Elliott Bay, the or view elements to the south. I-5 southbound from Lakeview Boulevard to Olive Way was identified as a route that approaches and passes along the eastern edge of the Denny Triangle, the portion of the study area where the greatest amount of redevelopment was expected to occur. The EIS concluded that the best territorial and skyline views from this route segment north of Denny Way would remain, even if future development occurs in the Denny Triangle., but identified no impacts of development within the Commercial Core. (DHDC DEIS page 3-137) Scenic routes through Downtown were assessed for three scenic routes, 5th Avenue, Westlake Avenue and the Alaskan Way Viaduct. The route along Fifth Avenue would experience modest changes due to potential redevelopment on adjacent sites. Views along portions of this route were found to be already impaired by the existing monorail structure. The other scenic routes had no identified impacts in the Commercial Core.

Other Non-Protected Views The DHDC EIS noted that areas adjacent to Downtown including Queen Anne Hill, Capitol Hill, First Hill and Beacon Hill provide numerous views of the Downtown skyline, and, in many cases to other features beyond. Though somewhat more distant, the east and northeast facing slopes of West Seattle and portions of Magnolia bluff further expand the viewshed that includes the Downtown skyline, as well as other natural features. With the growth of Downtown, the skyline has become increasingly more prominent in the public and private views from these surrounding areas. As development has occurred over time under allowable height limits, some of the gaps that previously existed in the skyline have been filled in, reducing opportunities for views over or through the Downtown skyline to

2-42 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum features beyond, such as Elliott Bay and the Olympic and Cascade Mountains. In some cases, the skyline itself has emerged as the principal object of view. (DHDC DEIS page 3-131) The DHDC EIS concluded that City policy, as reflected in the zoning that applies to areas adjacent to Downtown, recognizes that the loss of some views is an unavoidable consequence of development in dense urban environments. However, the zoned height limits help provide a balance between objectives for accommodating desired levels of development while maintaining reasonable view opportunities. Additional height allowed would further restrict views through the downtown of natural features beyond to street corridors while emphasizing the downtown skyline. (DHDC DEIS page 3-142)

2.5.2 Addendum Information on Impacts Seattle Municipal Code (SMC) 25.05.675 contains specific environmental policies for elements of the environment. Subsection P. 2. contains the following policies for public view protection. a.i. It is the City's policy to protect public views of significant natural and human-made features: Mount Rainer, the Olympic and Cascade Mountains, the downtown skyline, and major bodies of water including Puget Sound, Lake Washington, Lake Union and the Ship Canal, from public places consisting of the specified viewpoints, parks, scenic routes, and view corridors, identified in Attachment 1. (Attachment 1 is located at the end of this Section 25.05.675.) This subsection does not apply to the , which is governed by subsection P2c of this section. ii. The decisionmaker may condition or deny a proposal to eliminate or reduce its adverse impacts on designated public views, whether or not the project meets the criteria of the Overview Policy set forth in SMC Section 25.05.665; provided that downtown projects may be conditioned or denied only when public views from outside of downtown would be blocked as a result of a change in the street grid pattern. b.i It is the City's policy to protect public views of historic landmarks designated by the Landmarks Preservation Board which, because of their prominence of location or contrasts of siting, age, or scale, are easily identifiable visual features of their neighborhood or the City and contribute to the distinctive quality or identity of their neighborhood or the City. This subsection does not apply to the Space Needle, which is governed by subsection P2c of this section. ii. A proposed project may be conditioned or denied to mitigate view impacts on historic landmarks, whether or not the project meets the criteria of the Overview Policy set forth in SMC Section 25.05.665 c. It is the City's policy to protect public views of the Space Needle from the following public places. A proposed project may be conditioned or denied to protect such views, whether or not the project meets the criteria of the Overview Policy set forth in SMC Section 25.05.665 i. Alki Beach Park (Duwamish Head) ii. Bhy Kracke Park iii. Gasworks Park iv. Hamilton View Point v. Kerry Park vi. Myrtle Edwards Park vii. Olympic Sculpture Park viii. Seacrest Park ix. Seattle Center x. Volunteer Park

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d. Mitigating measures may include, but are not limited to: i. Requiring a change in the height of the development; ii. Requiring a change in the bulk of the development; iii. Requiring a redesign of the profile of the development; iv. Requiring on-site view corridors or requiring enhancements to off-site view corridors; v. Relocating the project on the site; vi. Requiring a reduction or rearrangement of walls, fences or plant material; and vii. Requiring a reduction or rearrangement of accessory structures including, but not limited to towers, railings and antennae.

Public Viewpoints Of the 87 locations identified in the City’s SEPA policies where project impacts on views of natural and built features are to be addressed (SMC Section 25.05.675 P.2.a.i., Attachment 1), approximately 30 were identified in the DHDC EIS as relevant to the downtown. Of these, 11 were identified as experiencing minimal or no impacts due to their distance from Downtown and absence of any potential impairment of view features. Of the remaining 19 viewpoints, most would experience change only in the sense that the number and arrangement of buildings composing the Downtown skyline would be different from what is observable today due to changes over time. Seven viewpoints were identified that were most impacted and are discussed below. An overall perspective of views from the east is provided by Figure 2-2, which is taken from the observation level of the Volunteer Park Water Tower on Capitol Hill. This provides a perspective on how the proposed office/residential building fits into the skyline as an addition to the highest current buildings. This viewpoint was selected rather than Capitol Hill Viewpoint in the DHDC DEIS, located just east of I-5 at Republican Street Pike and Boren, because the proposed site is generally out of the view from that location. It provides a clearer overall perspective than the view from the Four Columns Park because the line of sight to the proposed office/residential tower from that location is substantially constrained by a number of existing buildings including a nine-story hotel building: the Washington State Convention Center. The upper portion of the proposed tower would be visible framed by the 56-story Two Union Square and 46-story City Centre Buildings. The visual impact of the proposal from Four Columns is similar to the more panoramic view from the water tower. The addition of the 59-story proposal provides an additional skyline element that is likely to enhance the view by providing an additional focus. The relative size of the building is likely to be similar to the Two Union Square Building which is shorter, but closer to the viewpoint. The DHDC EIS concluded that future development would not generate significant adverse impacts on views from the Harborview Viewpoint toward the central Office Core because future development would contribute to the skyline without adversely impairing existing views. The line of sight to the site of the proposal is slightly east of the 76-story Columbia Tower and the 62-story Municipal Tower. The proposed 59-story office/residential tower of Rainier Square adds to the skyline to the east of these

2-44 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum buildings, but would appear less prominent because these taller buildings are also much closer to the viewpoint. The addition of the proposed development to skyline views observed from the west across Elliott Bay is depicted in Figure 2-3 and is similar to the views from Belvedere and Hamilton Viewpoints discussed in the DHDC DEIS. That analysis concluded that future development would alter the shape, character and extent of the Downtown skyline over time with taller buildings in areas currently dominated by lower-height development. In this view, however, the office/residential tower is only slightly taller than existing buildings in the immediate area and provides an element that balances the height of the Columbia Center to the south. Views from the north, including viewpoints at Kerry Park on Queen Anne Hill, were described in the DHDC EIS as largely affected by taller development in the Denny Triangle. The tallest towers would remain in Downtown to the south with views of Mount Rainier in the distance to the west of Downtown. The proposed office/residential tower, when viewed from these more distant locations, would be one of many downtown buildings in the distance. The Space Needle is generally a more vivid focus of these views because it is closer and appears taller, despite its shorter height. Views from the south would include the proposal as one of many office towers in the distance and would continue to be dominated by the Columbia Center which is both taller and closer. Views of the proposed office/residential tower from the waterfront and Victor Steinbrueck Park are largely blocked by the first tier of buildings east of the waterfront, or the proposed tower would appear about the same height as closer somewhat shorter buildings such as the 42-story Russell Investments Center and the 55-story 1201 Third Avenue buildings.

View Protected Landmarks The City’s SEPA policies specify "it is the City's policy to protect public views of historic landmarks designated by the Landmarks Preservation Board which, because of their prominence of location or contrasts of siting, age, or scale, are easily identifiable visual features of their neighborhood or the City and contribute to the distinctive quality or identity of their neighborhood or the City." Twenty-three designated landmarks within (or visible from) the study area are identified for public view protection, based on this designation criterion used by the Landmarks Board. Eight of these are located within the study area, seven are within the retail core or Belltown, and eight are outside the study area but visible from portions of Downtown. The DHDC EIS observed that the city’s SEPA policy is not specific about the nature of protection provided for views of landmarks. There is little guidance about where the view of a particular landmark should be protected from, or the amount or particular aspects of the view that warrant protection. (DHDC DEIS page 3-135) The analysis of landmarks and historic buildings in Section 2.3, Urban Design – Height, Bulk and Scale, confirms the DHDC EIS conclusion that the additional height and bulk of new structures would have little added impact on the relationship already established between these landmark structures and surrounding high-rise development. In many respects, the presence of the landmark buildings is even more dramatic because of the contrasts they provide in scale and architectural style.

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Figure 2-2. View of the Project from the Northeast, Volunteer Park Water Tower.

Figure 2-3. View of the Project from the Southwest, Hamilton Viewpoint West Seattle

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Scenic Routes The only scenic route designated in the City’s SEPA policies potentially affected by the proposal is Fifth Avenue. Fifth Avenue through the Commercial Core offers occasional views of Elliott Bay at street intersections where views are available to the west. These views would not be changed by the proposal. The DHDC EIS observed that view changes in the downtown would primarily involve changes in the skyline and greater presence of denser buildings in the middle ground or background of views. Fifth Avenue is a one-way street southbound. As one approaches the project site from the north, the street is bounded on the east by the three-story base structure of the City Centre and the 10-story street wall of the Logan Building. On the south it is bounded by a six-story bank building, the plaza in front of a 19-story hotel, and a two-story bank building. The view down the street includes the unique features of the inverted pyramidal base of the Rainier Tower and the 29-story fluted square tower above. The Rainier Tower achieves a dynamism, urban character, and free ground plane with its daring, sweeping vertical base balancing the tower above. The proposal provides a 10-story base structure at the corner of Fifth and Union Streets, facing the six- story Skinner Building across the street. The bulk of massing of the 59-story tower is located to the west to allow the Rainier Tower to remain a separate design expression. Location of the new tower at the northwest corner provides a buffer space between the two towers. The new tower is conceived of as creating a holistic composition that relates to the form of the existing Rainier Tower. The proposed massing geometry is a nuanced, reciprocal response to Rainier Tower, complementing, balancing, and completing it. A horizontal datum at the elevation where the inverted pyramidal base of Rainier Tower transitions to the square office tower above is the point in the new building of the initiation of the reciprocal curve that steps back in an inverse to the angle of the base of the existing building to the tower of the new building. A person in a vehicle or a pedestrian would continue to have a visual experience moving or looking south along Fifth Avenue along the site similar to the three-story retail structure at the northeast corner and the base of the Rainier Tower at the southeast corner. The 10-story base structure is likely to be perceived as similar to the street walls of other buildings common in the downtown and along the Fifth Avenue corridor. The experience of a viewer on Fifth Avenue further south would continue to be the similar to the existing Rainier Square with considerably more visual interest provided by retail uses on the site as compared with the IBM Building plaza on the east and the street wall of The Fairmont Olympic Hotel on the west.

Other Non-Protected Views The C proposal would continue the trend noted in the DHDC EIS of emphasizing the skyline as more prominent in views than the natural features beyond. The contribution of the tower with an area of about 15,000 square feet is a small contribution given the 496 acres of land within parcels in the downtown. The prominence of the tower may further emphasize the downtown skyline, but the area is very small in terms of potential view blockage. The project does not change the street grid pattern. Views from outside of downtown would continue to have the same views down street corridors.

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The visual impacts of the proposal are consistent with the findings in the DHDC EIS that recognized that the loss of some views is an unavoidable consequence of development and that all alternatives considered, as well as the zoning regulations in effect at the time accommodated a level of future development that would affect views from some locations, over time.

2.5.3 Mitigation Measures It is the intent of the State Environmental Policy Act that if regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts additional mitigation should not be imposed (RCW 43.21C.240, WAC 197-11-660(1)(g)). Seattle’s Environmental Policies and Procedures (SMC 25.05.660.A.5) directs considering whether local, state, or federal requirements and enforcement would mitigate an identified significant impact before requiring mitigation measures. Compliance with design guidelines is intended to mitigate the aesthetic and view impacts. The Master Use Permit process will address compliance with all standards and guidelines. The design is also reviewed by the Downtown Design Review Board. The project would not block public views from outside of downtown as a result of a change in the street grid pattern as specified in SMC25.05.675.P. 2.a.ii.

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2.6 Shadows

2.6.1 Downtown Height and Density EIS The analysis in the DHDC EIS noted that the relative amount of shadow and sun available at the pedestrian level depends upon the landform, climate, vegetation, surrounding buildings, signs and bridges. In Downtown the changing orientation of the street grid is also a consideration that divides Downtown into three sectors. During daylight savings time, the heavily pedestrian-traveled avenues in the intensely developed central sector are exposed to full sunlight for a brief period around noon, while the east/west-oriented streets receive full sunlight later in the afternoon. These same changes occur roughly an hour earlier in the northern sector, and later in the southern sector. At other times of the day, both streets and avenues are affected, to varying degrees, by shadows from buildings. Building heights and widths are the primary factors affecting the amount of shadow, but other characteristics such as street level or upper level setbacks, locations of towers within a block, gaps between buildings, recessed plazas, roof overhangs, and marquees can modify the total amount and pattern of sun and shadow on the streetscape. Very generally, higher building heights extend the length of the shadow cast, and increased bulk (or cross-section width) widens the shadow cast by a building. While the longer shadows may mean they are noticed farther from a building, their effects on more distant locations are briefer, because the sun’s motion translates into faster movement of the shadow over the ground. Buildings with increasing amounts of bulk would generally result in wider shadows and an increased amount of shadowed area. The amount and impact of shadows cast by a group of buildings depends upon the spacing, orientation and relative locations of those buildings. (DHDC DEIS page 3-148) Shadow impacts in the DHDC EIS were assessed in accordance with the City’s SEPA policies which limited consideration to certain open space resources in Downtown, as well as certain other locations such as schoolyards. The analysis in the DHDC EIS was entirely qualitative and addressed adverse effects on the comfort of the urban setting. The general conclusion was that future developments in the DOC 1 Office Core may add to the total extent of shading of city streets, although existing buildings already result in considerable shading. Additional shading of Downtown SEPA-identified parks was not projected to be likely to occur. None of the alternatives considered was expected to generate significant adverse shadowing or wind impacts. (DHDC DEIS page 3-150)

2.6.2 Addendum Information on Affected Environment Seattle Municipal Code (SMC) 25.05.675 Q. 2. contains specific environmental policies for shadows on open spaces. It is the City's policy to minimize or prevent light blockage and the creation of shadows on open spaces most used by the public. b. Areas in downtown where shadow impacts may be mitigated are: i. Freeway Park;

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ii. Westlake Park and Plaza; iii. Market (Steinbrueck) Park; iv. Convention Center Park; and v. Kobe Terrace Park and the publicly owned portions of the International District Community Garden. c. The decision maker shall assess the extent of adverse impacts and the need for mitigation. The analysis of sunlight blockage and shadow impacts shall include an assessment of the extent of shadows, including times of the year, hours of the day, anticipated seasonal use of open spaces, availability of other open spaces in the area, and the number of people affected. d. When the decision maker finds that a proposed project would substantially block sunlight from open spaces listed in subsections Q2a and Q2b above at a time when the public most frequently uses that space, the decision maker may condition or deny the project to mitigate the adverse impacts of sunlight blockage, whether or not the project meets the criteria of the Overview Policy set forth in SMC Section 25.05.665. e. Mitigating measures may include, but are not limited to: i. Limiting the height of the development; ii. Limiting the bulk of the development; iii. Redesigning the profile of the development; iv. Limiting or rearranging walls, fences, or plant material; v. Limiting or rearranging accessory structures, i.e., towers, railing, antennae; and vi. Relocating the project on the site. Relevant public open spaces potentially affected by the project include three parks located to the north and east of the proposal within a distance that shadows may reach the parks. Figure 2-4 shows the location of these parks.  Freeway Park is a linear park located largely above I-5 between Seneca Street and Union Street. The park is bisected by Eighth Avenue. The park has a variety of features that attract different users and have different patterns of use. The park also serves as a pedestrian circulation feature as it connects the downtown core to the west with First Hill to the east at Seneca, University Union and Pike Streets. The Washington State Convention and Trade Center abuts the park to the north and provides large groups of pedestrians who use the park. Major features include: o A fountain and seating area along Sixth Avenue south of Seneca Street with landscaping east of the seating area. This area is small and attracts a relatively small population of passers-by who likely stop for rest and relaxation. It may also be used to some extent by visitors and staff of the hotel across the street. Use is likely weather-dependent with greater use during warmer months.

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o North of Seneca street a lower-level hardscape plaza below the major fountains is a high-use area in which activities and programs are provided by the Seattle Parks Department, primarily in the summer. In addition to persons attracted to activities, it is used extensively by downtown workers who use it for rest, relaxation and picnicking. It is also used by residents of First Hill to the east, particularly by elderly residents of Horizon House to the east, which is a population with limited access to transportation that therefore tends to use facilities within easy walking distance. o North of Seneca Street and east of and above the fountains a promenade and lawn area is likely used extensively by downtown workers, local residents and as a resting and recreation area. o Immediately west of Union Street is corridor parallel to and west of Eighth Avenue that connects to the Convention Center and connects to Union Street by a stairway. This corridor serves primarily for pedestrian circulation. o To the east of Eighth Avenue is a promenade bounded by lawn and landscape areas. It has benches along the promenade. It is used throughout the year with the highest levels of use, particularly of lawn areas, during warmer months. o The Piggott Corridor extends east from this promenade area to First Hill and consists of a series of stairs and handicapped accessible ramps connecting to Ninth Avenue and University Street. It is used as a primary access to the park for residences on First Hill, in particular an elderly population of the Horizon House on University Street. o The Convention Center Plaza is located directly south of the Convention Center and contains hardscape areas, seating and public art. This area was constructed by the Washington State Convention and Trade Center in 1996. It is used extensively by visitors to the Convention Center as well as by other users of the park.

o A walkway extends along the east side of the convention center and connects to Pike Street at Terry Street. o Walkways through the park are used year-round as an element of pedestrian circulation between downtown and neighborhoods to the east as well as for recreational exercise and diversion. Walkways are likely used to a greater extent on warmer sunnier days which tend to occur more in the spring, summer and autumn. Plaza and open space areas are used by scheduled summertime events and causally by visitors to the park. All plazas are used year round, with highest levels of use on warmer days. Precipitation and temperature are likely the factors that limit use the most. All portions of the park are used during moderate weather during the winter when it is not raining heavily. (Seattle 2005c, Seattle 2014f)  Convention Center Park is the portion of Freeway Park developed by the Washington State Convention Center in 1996 is and managed as part of Freeway Park (Seattle 1985).  Westlake Park and Plaza is designed to be a central gathering space in the heart of the retail core, a “piazza for all ages” and Seattle’s Town Square. It provides tables, chairs, and benches that encourages resting, reading and people-watching. Special events are scheduled in the

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summer and during the peak holiday shopping season (Seattle 2006b). A temporary playground has been added recently. Use is determined largely by its location in the Commercial Core and the large volumes of shoppers and others who frequent the area. The use is believed to be fairly constant through the year (Seattle 2014f), which is confirmed by pedestrian counts in the area that indicate little seasonal variation (DSA 2013).

Extent of Shadows Building shadows are determined by the location of the sun at different times of day. Because of the inclination of the earth in relation to the sun in different seasons, the length of shadows varies considerably, as well as the north, south orientation. Shadows produced by existing buildings are shown in Figure 2-4. The extent of shadow depicted at four times a year provides an overall perspective of the patterns experienced. The winter solstice produces the maximum potential shadows while the summer solstice produces the minimum shadows. The median condition is experienced at the spring and autumnal equinoxes. Shadows can be interpolated for the time periods in between. In terms of assessing potential impacts, the period from early May to early August (or more precisely May 9 to August 9) can generally be presumed to be similar to the summer solstice conditions generally around on June 21, but with greater extent of shadows extending into the equinox conditions. The equinox conditions generally can be considered most applicable to early February to early May (February 9 to May 9) and early August to early November (August 9 to November 9). Winter solstice conditions are most applicable to November 9 to February 9. Shadows are shortest during the summer because the sun is farther north and traces a path across the horizon which is more nearly vertical. Summer shadows, however, are present during longer periods. Sunrise is about 4 a.m. standard time or 5 a.m. daylight savings time with sunset at about 8 p.m. and 9 p.m. standard/daylight savings time. The maximum elevation of the sun is about 66 degrees at noon which casts a shadow about half (44 percent) the building height. Morning and evening shadows extend to the southwest and southeast because the sun rises and sets north of true east and west (about 34 degrees north of east or west). At low sun angles in the early morning and late evening, shadows are very long with overlapping shadows from trees, and even short buildings overlap and are almost continuous at the ground surface. At 9 a.m. and 3 p.m. shadow length is about equal to building height. Due to the topography of Seattle with First Hill to the east rising higher than downtown, the shadows of the hill and buildings on the hill result in longer shadows than would be present in a flat plane. Existing building shadows are shown on Figure 2-4. The extent of shadow depicted at four times a year provides an overall perspective of the patterns experienced. The winter solstice produces the maximum potential shadows while the summer solstice produces the minimum shadows. The median condition is experienced at the spring and autumnal equinoxes. Shadows can be interpolated for the time periods in between. In terms of assessing potential impacts, the period from early May to early August (or more precisely May 9 to August 9) can generally be presumed to be similar to the summer solstice conditions generally around on June 21, but with greater extent of shadows extending into the equinox conditions. The equinox conditions

2-52 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum generally can be considered most applicable to early February to early May (February 9 to May 9) and early August to early November (August 9 to November 9). Winter solstice conditions are most applicable to November 9 to February 9. Shadows are shortest during the summer because the sun is farther north and traces a path across the horizon which is more nearly vertical. Summer shadows, however, are present during longer periods. Sunrise is about 4 a.m. standard time or 5 a.m. daylight savings time with sunset at about 8 p.m. and 9 p.m. standard/daylight savings time. The maximum elevation of the sun is about 66 degrees at noon which casts a shadow about half (44 percent) the building height. Morning and evening shadows extend to the southwest and southeast because the sun rises and sets north of true east and west (about 34 degrees north of east or west). At low sun angles in the early morning and late evening, shadows are very long with overlapping shadows from trees, and even short buildings overlap and are almost continuous at the ground surface. At 9 a.m. and 3 p.m. shadow length is about equal to building height. Due to the topography of Seattle with First Hill to the east rising higher than downtown, the shadows of the hill and buildings on the hill result in longer shadows than would be present in a flat plane. Existing building shadows are shown on Figure 2-4. Spring and autumn shadows, particularly at the equinoxes (generally March 21 and September 21) provide the median case for the extent of shadows. Days are approximately equal with sunrise and sunset at about 6 a.m. and p.m. The maximum angle of the sun at noon is about 43 degrees, which produces moderately long shadows about equal to the height of a building. The sun rises at almost due east and west. Shadows are about twice the building height at about 9 am and 3 p.m. The sun rises at almost due east and west. Existing building shadows for 9 a.m., noon and 3 p.m. are shown on Figure 2-4. This represents mid-morning, noon and mid-afternoon in a day with 12-hours of daylight. Winter shadows are the longest, days are shortest. The winter equinox (generally December 21) has a sunrise around 8 a.m. with a sunset around 4:30 p.m. The maximum angle of the sun at noon is about 19 degrees. Shadows at noon are about three times the height of the building and four times the height at 10 a.m. and 2 p.m. Existing winter equinox shadows for 10 a.m., noon and 2 p.m. are shown on Figure 2-4. This represents midmorning, noon, and mid-afternoon in an 8-hour day (NOAA 2014).

Pedestrian Comfort The significance of shadows on public open space is part of the general issue of pedestrian comfort, specifically thermal comfort, for persons using those spaces. In general, the elements of thermal comfort in an outdoor environment include natural and built environment conditions (air temperature, humidity, radiant heat, and wind) and human factors (clothing and metabolism). The effects of natural and built environment conditions can be affected by the willingness of pedestrians to compensate both by individual toleration of specific conditions and by clothing and activity. The conditions that persons find comfortable vary by location and season, activity and personal tolerance. A person walking briskly generates considerable body heat which produces a different level of comfort under the same environmental conditions as someone seated and inactive. (Arlens 1977; Herrington 1977; Honjo 2009)

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Shadows affect one component of thermal comfort, radiant heat, and must be considered in reference to other conditions. A variety of seasonal meteorological conditions are summarized in Table 2-1 below. Where data are available, the Seattle urban site is reported rather than SeaTac Airport. Downtown weather conditions can be substantially different; for example, Downtown has 71 clear days per year whereas SeaTac Airport has 58. An important factor directly related to shadows is cloud cover, since shadows will not occur when the sun is obscured. In the table below, both clear days and partially cloudy days are reported. The most generally applicable measure is the mean monthly percent of possible sunshine which is a measured solar radiation that excludes some types of high cloud cover that does not materially intercept sunlight. Solar radiation is most significant as a positive factor in pedestrian comfort in autumn, winter and spring seasons when even brief periods of sunlight can improve pedestrian conditions and lead persons to change their behavior to include more sedentary activities such as sitting. The average or mean conditions are the records most commonly reported but are limited in application since half the cases are higher and lower. In general, radiant solar heat is a positive influence on pedestrian comfort in the cooler months. Radiant heat is least common in the winter months and most common in the summer months. In the summer months, radiant solar heat may be a negative component when temperatures are higher than 65 degrees and shadows, whether from trees or buildings may be a positive contributor to comfort. In winter months, the potential contribution is limited by limited opportunities due to cloud cover. In general, the maximum positive influence of solar radiation is experienced in the spring and autumn months where it can be a more positive contribution to pedestrian comfort on days when temperature is marginally comfortable and solar radiation directly adds to comfort. Solar radiation also can contribute to pedestrian comfort by increasing the rate at which rain dries out and in conjunction with hardscape areas can lead to microclimate conditions in which areas are locally warmer because of absorbed solar radiation. In these months, shadows on public open space are likely to have the greatest effect on whether and how persons use the space.

The Downtown Urban Center has a wide array of existing office buildings, hotels, high-rise residential complexes, retail facilities and parking structures. These buildings all have shadow impacts that affect the designated parks as indicated in Figure 2-4. Vegetation, particularly trees, also affects shadows and pedestrian comfort.  Freeway Park (and the associated Convention Center Park) is substantially impacted by shadows from existing buildings to the southwest and southeast. The 56-story Two Union Square, the 35-story One Union Square. and the 21-story Park Place building at Seneca and Sixth Avenue all shade substantial portions of the park in the afternoon and evening from the autumn equinox through the winter months. The extents of shadows decrease during the spring equinox through the summer solstice to the autumn equinox, but the portions of the park shaded in the summer are still substantial. Morning shadows are cast by buildings to the east including the 19-story Horizon House, the 10-story Exeter, the 10-story Cambridge, and the 32-story 802 Seneca building, under construction. The park also has substantial mature tree cover that provides extensive shadows of all but the larger plaza areas through the summer months.

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 Westlake Park and Plaza is surrounded by buildings that substantially shadow the relatively small area. The 30-story Century Square building to the southeast of the park casts substantial afternoon shadows over the park in all seasons. The 10-story Joshua Green and 10-story Fourth and Pike Buildings located on the south side of Pike Street cast noon and early afternoon shadows over portions of the park. The 10-story Seaboard, the 1516 Fourth Avenue and the 5- story Fifth and Pine buildings on the east side of the park cast afternoon shadows over much of the park that cover most of the park in the late afternoon in all seasons. The 8-story Macy’s (Bon Marche) and the 10-story Nordstrom (Fredrick and Nelson) buildings to the northwest and northeast cast mid-summer morning and evening shadows, respectively. The plaza has a continuous row of mature street trees along Fourth Avenue and a mass of mature trees in planters in the central portion of the site. The large plaza area with a fountain in the northeast corner of the site is the least shaded by mature trees.

Table 2-1. Meteorological Factors Relevant to Pedestrian Comfort

Winter Spring Summer Autumn

Parameter Nov Dec Jan Feb Mar Apr May June July Aug Sept Oct

Clear days 3 3 3 3 4 5 7 7 12 10 9 5

Partially clear days 7 5 5 6 8 9 10 8 10 10 8 8

Cloudy days 21 23 23 19 19 16 14 15 9 11 13 18 Mean percent 28 23 28 34 42 47 52 49 63 56 53 37 possible sunshine Mean hours of 77 62 74 99 154 201 247 234 304 248 197 122 sunshine (ST) Average high 51 47 45 48 52 58 64 69 75 76 67 59 temperature Average low 41 38 35 38 39 42 47 52 54 55 52 47 temperature Record high 74 64 64 70 75 85 93 96 103 99 98 89 temperature Record low 6 6 O 1 11 29 28 38 43 44 35 26 temperature Source: WRCC 2014 Western Regional Climate Center Historic Tables, http://www.wrcc.dri.edu/climatedata/tables/ A clear day denotes zero to 3/10 average sky cover. Partly cloudy is 4/10 to 7/10 tenths. Cloudy is 8/10 to 10/10 tenths.

2.6.3 Addendum Information on Impacts

Extent of Shadows Shadows cast by the proposal are shown in Figure 2-5. Impacts of the proposal in conjunction with existing buildings can be assessed in conjunction with Figure 2-4.

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In general, the shadow impacts of the proposed office/residential tower reaches the public open space at Freeway Park (and Convention Center Park) but has little or no additional impact because of shadow cover from existing buildings.  Summer shadows are limited to the very late afternoon when the shadows from the proposed buildings overlap with long afternoon shadows from a number of buildings nearer the park. The proposal has essentially no additional shadow impacts.  Spring and autumn shadows are generally outside of the park to the north because of the angle of the sun. Very late afternoon shadows reach the park but overlap shadows of existing buildings. The proposal has essentially no additional shadow impacts.  Winter shadows do reach the park and extend far beyond it due to low sun angles. The park, however, does not experience additional impacts from the proposal because it is extensively shadowed by other buildings. Westlake Park is shadowed by the proposed office/residential building only during the autumn and winter, but the development has little or no additional impact given shadow cover from existing buildings.  Summer shadows do not reach the park because of high sun angles at midday.  Spring and autumn shadows move across the entire park, but all shadows over the park are in areas already shadowed by existing buildings.  Winter shadows extend over the park and some distance to the north; however, winter shadows are at an extremely low angle with extensive shadows from existing buildings. The proposal does not increase shadow cover.

Impacts on Pedestrian Comfort in Designated Open Space The extent of shadows that can potentially be cast by a building, or cumulatively by a group of buildings, must be considered in terms of the likelihood of weather conditions that would allow shadows to be cast. As indicated in Table 2-1, the number of days with full sun or partial clouds is highest in the winter, somewhat greater in the spring, at the greatest in summer, and continuing relatively high through September. The greatest extent of potential shadows are in seasons that have the lowest incidence of sunny days. In the summer, shadows are not only less extensive, but also least likely to affect comfort or the use of outdoor spaces because temperatures are higher. It is unlikely that the shadows from the proposed office/residential tower would affect the use of Freeway Park both because shadows from the development add little to the extent of shadows already cast by existing buildings and because most use of the park is little affected by shadows. Walkways through Freeway Park are used year-round as an element of pedestrian circulation between downtown and neighborhoods to the east as well as for recreational exercise and diversion. These walkways are likely used at higher levels in better weather, but the presence or absence of shadows is unlikely to change patters of use. Pedestrians adjust their clothing for the season and are not likely to depend on solar radiation as a major element of comfort. Pedestrian comfort in the late autumn, winter and early spring is affected primarily by

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Figure 2-4. Shadows Produced by Existing Buildings

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Figure 2-5. Shadows Produced by the Proposal

2-58 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum precipitation and temperature. Sunlight on the park is largely provided from the midday sun which is oriented over I-5 where there is no blockage from buildings. Plaza and open space areas that are used by scheduled summertime events are unlikely to be regarded as adversely affected by shadows since the ambient summer temperature and rainfall are the greatest determinants of pedestrian comfort. Casual use of plaza, lawn and seating are likely affected most by precipitation and temperature. Shadows are likely to be a minor factor in late spring to early autumn use. Regardless of use patterns, the proposal is unlikely to affect shadow cover and unlikely to change any impacts shadows might have. Westlake Plaza is used extensively year-round because of its location in an area with very high pedestrian volumes. Sunlight is a positive factor in the amount of time persons spend in the park, but precipitation, rather than cloud cover or shadows, is likely to be the most important factor. The shadows from the proposed development would have little effect on the extent of shadows of pedestrian comfort in this park because because of the extent of shadows cast by existing buildings. Shadow impacts of the proposal are consistent with the conclusions of the DHDC EIS that future developments in the DOC 1 Office Core may add to the total extent of shading of city streets, although existing buildings already result in considerable shading.

2.6.4 Mitigation Measures It is the intent of the State Environmental Policy Act that if regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts additional mitigation should not be imposed (RCW 43.21C.240, WAC 197-11-660(1)(g)). Seattle’s Environmental Policies and Procedures (SMC 25.05.660.A.5) directs considering whether local, state, or federal requirements and enforcement would mitigate an identified significant impact before requiring mitigation measures. The project contributes to cumulative impacts on Freeway Park and Westlake Park and Plaza due to extensive shadows produced by existing buildings but does not shade portions of the open spaces designated by SMC 25.05.675 Q. 2. that are not currently shadowed and is not likely to affect public use of the space.

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2.7 Light and Glare

2.7.1 Downtown Height and Density EIS Light and glare impacts were not assessed in the DHDC EIS.

2.7.2 Addendum Information on Affected Environment Seattle Municipal Code (SMC) 25.05.675 contains specific environmental policies that address light and glare are found in Section 25.05.675.K.2 and include: a. It is the City's policy to minimize or prevent hazards and other adverse impacts created by light and glare. b. If a proposed project may create adverse impacts due to light and glare the decision maker shall assess the impacts and the need for mitigation. c. Subject to the Overview Policy set forth in SMC Section 25.05.665, the decision maker may condition or deny a proposed project to mitigate its adverse impacts due to light and glare. d. Mitigating measures may include, but are not limited to: i. Limiting the reflective qualities of surface materials that can be used in the development; ii. Limiting the area and intensity of illumination; iii. Limiting the location or angle of illumination; iv. Limiting the hours of illumination; and v. Providing landscaping. Buildings containing glass on their surface reflect light, both natural sunlight and artificial illumination. This is the case whether individual windows are set into other materials or whether large portions of the curtain wall are glass. Normal vision glass reflects glare as well as glass with reflective surfaces, although the extent of reflectivity varies. For the drivers, pedestrians and building occupants in the vicinity, the reflected sunlight from glazing may become a bright spot in their view which may result visual discomfort or impairment. Reflective glare can also increase solar exposure in adjacent buildings and affect heating and air conditioning demand. Reflected glare in open space and sidewalks can change local microclimate conditions and result in hot-spots where glare is concentrated. Factors that influence the incidence of reflective solar glare include weather (e.g., cloud cover); the height, width and orientation of the building façade; percentage of the façade that is glazed or composed of specular material; reflectivity of the glass or specular surfaces; design relationship between the glazed and non-glazed portions of the façade (e.g., glass inset from the sash, horizontal and vertical modulation); the color and texture of building materials that comprise the façade; the

2-60 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum proximity of other intervening structures or landscaping, and the relationship of the glare to the person experiencing it. Effects of glare can be generally divided into discomfort glare and disability glare. Discomfort glare results in an instinctive desire to look away from a bright light source or difficulty in seeing a task. Disability glare impairs the vision of objects and is generally caused by the inter-reflection of light within the eyeball, reducing the contrast between task and glare source to the point where the task cannot be distinguished (Vos 2003). Glare impacts in Downtown Seattle are a concern particularly for drivers and pedestrians. Drivers can be blinded by disability glare, causing an interruption in comfortable driving patterns. Discomfort glare can cause drivers to avert their gaze from key elements of the view, such as traffic signals or pedestrians, resulting in potential hazards. Pedestrians can experience the same impacts, but since they are not moving quickly or maneuvering a heavy vehicle, the consequences are generally much less. Pedestrians usually can move out of the path of glare fairly readily. An additional concern for sidewalks and pedestrian open space is concentration of heat from reflected glare which can make a location uncomfortable, particularly in summer. Two important considerations for impacts on motorists is the angle of the glare source in relation to the line of sight and the complexity of tasks performed. Other factors include the intensity of the light source and the age and quality of vision of the observer. An angle of less than 20 degrees from the line of sight is often used as the boundary of the most critical effects based on studies of headlight glare, the choice of the 20-degree parameter for design of glare barriers on highways (Mace 2001) and the observation that the roof of typical passenger cars typically cuts off views above 20 degrees from the horizontal (O’Flaherty 1996). The complexity of driving tasks performed during a period of impairment due to glare is a potential determinant of potential outcomes. Since most incidents of glare either cause an observer to look away or produce a temporary blindness, the lack of visual cues during that period generally prevent a driver from making changes in behavior to respond to changes in circumstances. Consequences on a straight road with vehicles moving at constant speeds with wide separations may have minimal impacts. Consequences in stop and go traffic may include more serious consequences of not seeing slowing or stopped traffic ahead. In busy urban streets a variety of rapid responses may be needed for changes in conditions which can lead to serious car-to-car or car-to- pedestrian crashes (Mace 2001). Structures and vegetation can mitigate adverse impacts of reflected solar glare to the extent that they block the glare path. The effects of buildings depend on their location, height and width. The effect of trees depends on size and type of foliage (deciduous or evergreen) and for deciduous trees the season of leafage which typically is April through October. The orientation of the street grid in this portion of downtown (32 degrees west of north) affects potential reflected solar glare impacts because a smaller set of low elevation sun angles is oriented to the street system. The one-way street system affects motorists potentially affected by reflected solar glare. Fifth Avenue, which is one-way southbound, generally is subject to low angle direct glare except in the late autumn through winter and early spring months and is not subject to reflected glare. On University Street, which is one-way eastbound, motorists face reflected solar glare only in the evening.

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On Union Street, which is one-way westbound, motorists will face reflected solar glare only in the morning. The topography to the east of First Hill with an elevation of 350 feet and Capitol Hill with an elevation of 420 feet limits low morning sun angles. Sources of artificial light that presently occur near the project site include streetlights, light from headlights of vehicles operating on streets, and building interior and exterior lighting. Streetlights in the vicinity are installed on standard City of Seattle arterial lighting supports approximately 30 feet tall with cobra-style lamps.

2.7.3 Addendum Information on Impacts The proposed 59-story office/retail building that extends to a height of feet at the northwest corner of the site has a reflective glass façade above the fourth floor with vertical metal prisms extending one to two floors in length scattered on the face of the building with increased density toward the top. This glass proposed for the building façade would reflect about 30 percent of solar glare. The upper portion of the hotel façade is similar materials. The analysis of potential impacts on pedestrian’s on sidewalks and open space areas and on motorists travelling on local streets was assessed by determining key observation points from which glare impacts would be potentially adverse and determining the geometry of reflected glare and using the National Oceanographic and Atmospheric Administration (NOAA) Solar Calculator to determine the time periods that potential observation points would be subject to glare. Glare angles greater than 20 degrees or more above horizontal were not analyzed for motorists because they generally are outside the field of vision that results in adverse impacts. Because the sun’s rays as they fall on the earth change on a season basis, the timing and duration of impacts changes constantly. Low angle impacts are most likely to occur in the late autumn, winter and early spring and will gradually occur closer to noon as the angle of the sun decreases as it approaches the winter solstice. In most cases, the experience of reflective glare at a specific location will generally be limited to a few minutes for a stationary observer to a second or two for a mobile viewer, except with a vehicle is stopped at a traffic signal. The cloud cover is also an important factor determining the likelihood of reflective glare. As Table 2-1 in the shadow analysis indicates, in the autumn, winter and spring when low angle solar radiation is more prevalent, the number of cloudy days is higher and the potential for sunshine is lower. Fourth Avenue is a one-way street northbound that forms the westerly boundary of the site and would be subject to glare reflected off the southerly face of the building. Because of the orientation of the street grid, the south wall is oriented 32 degrees north of east (or an azimuth of 58). Locations analyzed include the south side of intersections along the street where motorists would stop at signals and encounter other motorists on perpendicular streets and pedestrians crossing the street. Reflected glare along the orientation of the street at an azimuth of 148 degrees with reflected glare at less than 20 degrees would occur for a short period of time daily from mid-September to Mid-March between 9 am and 10:30am. At the intersection of Fourth Avenue and University Street reflected glare from the central and easterly potion of the building would be at about 170 degrees (ten degrees east of south) and incoming solar rays would be at an orientation of about 126 degrees. This solar orientation could

2-62 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum occur daily between 8 and 10 from and would be at a reflected angle of less than 20 degrees from the autumn through the winter to the spring from about August 9 to May 9. The potential incidence of reflective glare below an angle of 20 degrees would be limited to the lower portion of the proposed office/resident building. At this location incoming solar rays would reflect from the portion of the office tower about 100 feet above grade. The proposed hotel would block reflected glare at this location for all vehicular lanes except the far westerly travel lane. In addition, the majority of incoming solar rays at this orientation would be blocked by large buildings to the south including the 42-story and 62-story Seattle Municipal Tower buildings For the solar glare that did occur in the far westerly lane, drivers would have views of traffic lights at the northeast corner of the intersection below the angle or reflected glare and because University Street is one-way eastbound, drivers on Fourth Avenue would not be engaging in making a left turn or other complex maneuvers. Therefore it is unlikely that reflected glare would be an adversely impact drivers at this intersection. Further south, at the intersection of Fourth Avenue and Seneca Street, the orientation of reflected glare from the central and easterly portion of the façade would be at about 160 degrees (20 degrees east of south) and incoming solar rays would be at an orientation of 136 degrees. At this location reflected rays of 20 degrees or less would also be blocked by the proposed hotel and the existing Fairmont Olympic Hotel, except for far westerly lanes. The majority of incoming solar rays at this orientation would be blocked by large buildings to the south including the 42-story building and the 76-story Columbia Center. Reflected glare would be blocked for all lanes except the extreme portion of the westerly parking and left turn lane. Drivers making a left turn would look away from the glare and would have a clear view of their maneuver and of pedestrians crossing the street and would be able to avoid conflict without substantial interference from glare. Therefore it is unlikely that reflected glare would be an adverse impact at this intersection. Yet further south, at the intersection of Fourth Avenue and Spring Street, reflected glare from the central and easterly portion of the building would have an orientation of about 150 degrees with an orientation of incoming solar rays of 146 degrees. The path of reflected solar glare to Fourth Avenue would be blocked by buildings along Fourth Avenue such as the W Hotel and the 901 Fifth Avenue Building. Incoming sunlight also would also be substantially blocked by the 901 Fifth Avenue building and the 76-story Columbia Center. Drivers would have views of traffic lights at the northeast corner of the intersection and would not be engaged in making a left turn or other complex maneuvers. South of Marion Street a portion of the southerly wall of the proposed office residential tower above the elevation of the Rainier Tower, would not be blocked due to its higher elevation, and incoming glare would be above the potential path of tall buildings to the south, but the orientation of the glare along Fourth Avenue would generally not interfere with driver attention and would not interfere with views of signals or other features generally below the angle of reflected glare. Northbound traffic on I-5 between Main Street and Yesler Way would be in the potential line of sight of reflective glare from the upper floors of the proposed building, however the path of reflected glare would be blocked by multiple buildings including Rainier Tower, the 42-story 800 Fifth Avenue building, and the 62-story Seattle Municipal Tower building. North of Jefferson Street the orientation

Rainier Square Development 2-63 University of Washington Metropolitan Tract Environmental Impact Statement Addendum of I-5 changes to a more easterly orientation and the glare from the building is no longer directly in the line of sight of drivers. Other north-south streets downtown with northbound traffic, such as Third Avenue would not be impacted because the glare path would not be in the line of sight of drivers and intervening buildings would intercept reflected glare. At a 20-degree elevation, a two-to three-story building would block reflected glare oriented from the side. The southbound one way streets downtown north of the site have little potential for adverse impacts to drivers from reflected glare because there is not a direct line of sight at an angle of less than 20 degrees above horizontal because of existing buildings. At a greater distance north of Stewart Street where the street orientation shifts to 49 degrees west of north, southbound traffic on Third Avenue would be in a line of sight with potential paths of reflected glare, but the path of the sun would allow that to occur only during very early morning hours near the summer solstice and the horizontal angle of the sun is so low that incoming rays at a 20 degree elevation or less would be blocked by Capitol Hill. East-west streets such as Union Street may be impacted in the morning and evening by reflected glare approximately perpendicular to the east and west facades of the buildings. The sun angle that would allow reflected glare to the east in the morning would occur for about 20 days in the summer between 4:30 and 5:00 am and would be at a horizontal angle such that the topography and intervening buildings would not allow sunlight to reach the lower portions of the tower required to reflect to the portion of the street between Fifth Avenue and the crest of First Hill near Summit Avenue. The upper portions of the tower would reflect glare further to the east, but since the orientation of streets changes at Minor Street to an east-west orientation, reflected glare would not be in the line of sight of drivers. Reflected glare to the west at an azimuth of about 238 would be below a horizontal angle of 20 degrees from about 5 pm in mid-January to about 4 pm in mid-March. After that, the time of day at which reflected glare affected the corridor would become progressively later and the angle higher until the summer solstice when it would occur at about 2:30 pm at an angle above horizontal of about 55 degrees. Glare on the portion of the street west of the project wouldn’t make a difference to drivers’ performance because the street is one-way westbound and drivers are not facing the glare. University Street which is one-way eastbound could be affected by glare reflected to the west during afternoons. Intersections at Third, Second and First Avenues could be impacted. The impacts are reduced because the glare would be at an angle to the orientation of the street and most low angle reflected glare would be blocked by intervening buildings including the 21-story Puget Sound Plaza on Fourth Street and other buildings lining the street. If reflected glare were not blocked, it is still at an oblique angle to the drivers’ line of sight and would not be likely to interfere with visibility of traffic signals at intersections or pedestrians and other features The same pattern would hold true for east-west streets further south, but the angle from the driver’s line of sight and glare would increase and additional layers of blocking buildings would be present further reducing the potential for interference with driving activities. Where glare impacts occur, they are generally related to the image of the sun on a single pane of the building. The duration of effect would be very brief at larger angles of view and limited to one to a few

2-64 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum seconds at lower angles. The most serious impact would occur when the angle was approximately level with the grade of the street, which could occur on east-west streets in downtown Seattle that angle upward to the east. In those cases, the impact could be over a distance of a block or more. The eastbound one-way streets where this is possible, however, don’t experience glare because intervening building block low angle glare. Where the impact does occur at other locations, the distance traveled would depend on vehicle speed and would vary from about 30 to 60 feet for a vehicle traveling at 20 mph (30 fps) to 40 to 80 feet at 30 mph (44 fps) Concave building facades have a history of concentrating light similar to a parabolic mirror and leading to heat levels at the ground where the focal point of the walls concentrates glare (CCE 2013). The concave façade at the northwest corner of the proposed office/retail tower illustrated in Figure 1- 15, however, is oriented to the northwest at an azimuth of 328 degrees and is generally away from the orientation of the sun. The sun angle at this latitude never is far enough north to be perpendicular to the entire concave surface. The maximum sun angle at sunset at the summer solstice is 302 degrees. Earlier in the day, at 5 pm at the summer solstice the sun is almost due west with an azimuth of 270 degrees and an elevation of about 30 degrees. Portions of the concave surface can reflect sunlight from about 4:40 in the afternoon to sunset, but glare would not be reflected off both concave surfaces and would not be reflected into a focal point near ground level (NOAA 2014). Pedestrians would experience glare impacts on the corridors discussed above, but with less potential impact since they are not driving vehicles and are not moving rapidly. In most cases, glare impacts are localized to a single image of the sun reflecting off a single pane of glass. In most cases a pedestrian can avoid the impact by moving a few feet. Pedestrians also may experience glare in open space areas. The two existing open space areas south of the proposal and in the immediate vicinity include the second floor plaza at the southwest corner of Fourth Avenue and University Street and the plaza in front of the IBM building at the southeast corner of Fifth Avenue and University Street. Potential glare impacts at this location are likely to from a high angle of reflection and are likely to be noticeably largely because of increased heat. This may be a welcome effect during the winter, spring and autumn an cooler days in summer. The open space areas proposed as part of the project may also experience solar glare during periods close to noon and close to the June 21 Summer Solstice when solar angles are very high. Much of this is likely to be intercepted by trees, when present. A person also can generally avoid the isolated heat island my moving a few feet. The project also would produce building interior and exterior lighting and would attract additional vehicles entering and exiting the project site, with localized increase in light and glare from headlights. Ambient light levels would not be noticeably different as the result of the project. Glare impacts of the proposal are not considered significant as they do not create hazards to drivers and pedestrian impacts are moderate.

2.7.4 Mitigation Measures It is the intent of the State Environmental Policy Act that if regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts additional mitigation should not be imposed (RCW 43.21C.240, WAC 197-11-660(1)(g)). The Seattle environmental Policies (SMC

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25.05.660.A.5) directs considering whether local, state, or federal requirements and enforcement would mitigate an identified significant impact before requiring mitigation measures. The project is subject to review for conformance with City of Seattle Design Guidelines that provide in Section DC4.C:  Functions: Use lighting both to increase site safety in all locations used by pedestrians and to highlight architectural or landscape details and features such as entries, signs, canopies, plantings, and art.  Avoiding Glare: Design project lighting based upon the uses on and off site, taking care to provide illumination to serve building needs while avoiding off-site night glare and light pollution. Limiting the reflective qualities of surface materials in the development is always a potential mitigating measure. However, since existing vision glass has reflectivity sufficient to produce solar glare, it is unlikely to substantially change impacts. The decision maker will need to balance the design goals of the proposed building façade with limited benefits of a reduction in the reflective surface in the context of a driving environment with relatively few complex movements subject to interference by momentary glare. Measures to reduce lighting levels from artificial illumination or limiting hours of illumination do not appear justified in an environment such as downtown Seattle where ambient light levels from artificial light are already high and are not likely to change as a result of the project. Providing landscaping will not change light impacts from the interior of the building or substantially change the impacts of standard street lighting.

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2.8 Wind

2.8.1 Downtown Height and Density EIS The DHDC EIS described potential wind impacts based on meteorological conditions and a general qualitative description of potential impacts. The DEIS observed that prevailing winds in Downtown Seattle blow from the south and south- southwest (about 22 percent of the time). In the summer months, prevailing winds are also experienced from the northwest (about 20 percent of the time). (DHDC DEIS page 3-148) At the pedestrian level, the building form, planting, and contours of the site often affect winds. Three general types of wind patterns affect wind flows at pedestrian levels: downwash wind flows from exterior walls to the base of a building; abrupt changes in wind speeds caused by differences in pressure between exposed and sheltered areas; and winds concentrated through openings such as passageways or arcades. (DHDC DEIS page 3-148) Tall buildings and structures can notably affect the wind environment for pedestrians. In cities, groups of structures tend to slow the winds near ground level, due to the friction and drag of the structures themselves. However, buildings that are much taller than the surrounding buildings intercept and redirect winds that might otherwise flow overhead, and bring them down the vertical faces of the building to ground level, where they can create ground-level wind and turbulence. These redirected winds can be incompatible with the intended uses of nearby ground-level spaces, or even hazardous. (DHDC DEIS page 3-149) Generally, the taller the high-rise building, the stronger the winds it encounters. If, in addition, the building provides a wide face to the wind, more wind will be directed down that face of the building toward ground level. However, these wind effects on the ground level usually can be controlled by design features that redirect those winds away from pedestrian areas. Typically, it is sufficient to provide a horizontal deflecting structure near the base of a building so that winds coming down the building face are redirected horizontally above the ground level. This is an effective design strategy for both taller towers and lower, bulkier buildings. (DHDC DEIS page 3-150) The DHDC EIS concluded that future new buildings in the Office Core and some peripheral areas would create the potential for additional wind effects near street level. However, interspersing of new buildings with existing buildings may help protect them from some wind exposure. None of the alternatives were projected to have specific impacts and no SEPA mitigation measures were identified beyond potentially addressing the issue in design guidelines or regulatory requirements. (DHDC DEIS page 3-150)

2.8.2 Addendum Information on Affected Environment For this project, Rowan Williams Davies & Irwin Inc. (RWDI) was retained by Wright Runstad & Company to consult on the pedestrian wind conditions. The results of the wind study are presented in Appendix B.

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As a basis for determining impacts pedestrian wind comfort criteria have been developed by RWDI to deal with both pedestrian safety and comfort, as they relate to the force of the wind. Thermal effects (e.g., temperature, humidity, sun/shade, etc.) are not considered in these comfort criteria. These criteria have been developed by RWDI through research and consulting since 1974. They have also been widely accepted by municipal authorities as well as by the building design and city planning community. The pedestrian wind comfort criteria utilize a Gust Equivalent Mean (GEM) speed. Both mean and gust speeds can affect pedestrian comfort and their combined effect is typically quantified by a gust factor of 1.85. Comfort categories are summarized as follows:  Sitting: GEM speeds less than 6 mph. Low wind speeds during which one can read a newspaper without having it blown away. These wind speeds are appropriate for outdoor cafes and other amenity spaces that promote long term sitting.  Standing: GEM speeds less than 8 mph. Slightly higher wind speeds that are strong enough to rustle leaves. These wind speeds are appropriate at major building entrances, bus stops or other areas where people may linger but not necessarily sit for extended periods of time.  Strolling: GEM speeds less than 10 mph. Moderate winds that would be appropriate for window shopping and strolling along a downtown street, plaza or park.  Walking: GEM speeds less than 12 mph. Relatively high speeds that can be tolerated if one’s objective is to walk, run or cycle without lingering.  Uncomfortable. GEM speeds greater than 12 mph. Strong winds of this magnitude are considered a nuisance for most activities, and wind mitigation is typically recommended The following are important in understanding these criteria and their application:  Instead of standard four seasons, two periods of summer (May to October) and winter (November to April) are adopted in the wind analysis, because in a moderate climate such as that found in Seattle, there are distinct differences in pedestrian outdoor behaviors between these two time periods.  Nightly hours between midnight and 5 o’clock in the morning are excluded from the wind analysis for wind comfort since limited usage of outdoor spaces is anticipated.  A 20 percent exceedance is used in these criteria to determine the comfort category, which suggests that wind speeds would be comfortable for the corresponding activity at least 80 percent of the time or four out of five days.  Only gust winds need to be considered in the wind safety criterion. These are usually rare events, but deserve special attention in city planning and building design due to their potential safety impact on pedestrians.  These criteria for wind forces represent average wind tolerance. They are sometimes subjective and regional differences in wind climate and thermal conditions as well as variations in age, health, clothing, etc. can also affect people's perception of the wind climate. Comparisons of

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wind speeds for different building configurations are the most objective way in assessing local pedestrian wind conditions. Existing wind patterns in the Seattle area are summarized by the wind roses in Figure 2-6 that show wind directions and speeds for summer and winter conditions and are based on wind statistics recorded at the Seattle-Tacoma International Airport between 1982 and 2012. Winds from the south through southwest, north and northeast directions are predominant in both the summer and winter as indicated by the wind roses. Strong winds of a mean speed greater than 20 mph measured at the airport (at an anemometer height of 33 ft) occur more often in the winter (2.4%) than the summer (less than 1% of the time). To assess the wind environment around the development in terms of pedestrian wind comfort and safety wind tunnel testing of a 1:400 scale model of the proposed development was performed for the following configurations:  Configuration A - Existing: existing and in-construction surroundings; and,  Configuration B - Proposed: existing and in-construction surroundings with the proposed development included. Appendix B includes figures illustrating the wind tunnel model included the proposed development and all relevant surrounding buildings and topography within a 1600 ft radius of the study site. The model was instrumented with 71 wind speed sensors to measure mean and gust wind speeds at a full- scale height of approximately 5 ft as shown in Figure 2-7. These measurements were recorded for 36 equally incremented wind directions.

2.8.3 Addendum Information on Potential Impacts The existing wind conditions around the Rainier Tower and surrounding sidewalks are generally appropriate for sitting or standing throughout the year with strolling conditions predicated at at the locations shown in Figure 2-7 as indicated in Table 2-3. With the addition of the proposed development, wind conditions are anticipated to remain generally unchanged. Wind conditions comfortable for sitting in both seasons are predicted at all entrances to the Rainier Tower (Locations 17, 19, 20 in Figure 2-7). The wind conditions at the entrances and sidewalks around the new mixed-use tower and hotel are predicted to be comfortable for sitting and standing during both seasons which are considered appropriate. Overall, the predicted wind conditions are considered appropriate for the intended use of therespective spaces. Impacts are consistent with the range of potential impacts discussed in the DHDC EIS.

2.8.4 Mitigation Measures It is the intent of the State Environmental Policy Act that if regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts additional mitigation should not be imposed (RCW 43.21C.240, WAC 197-11-660(1)(g)). Seattle’s Environmental Policies and Procedures

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(SMC 25.05.660.A.5) directs considering whether local, state, or federal requirements and enforcement would mitigate an identified significant impact before requiring mitigation measures.The project is subject to review for conformance with City of Seattle Design Guidelines in Section DC3.B.2. The wind analysis above indicates that the project meets these criteria and additional mitigation is not needed.

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Figure 2-6. Seattle Wind Roses for Summer and Winter

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Figure 2-7. Locations Modeled for Pedestrian Wind Comfort

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Table 2-2. Pedestrian Comfort and Safety Wind Modeling Results

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Table 2-2. Pedestrian Comfort and Safety Wind Modeling Results (cont’d)

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Table 2-2. Pedestrian Comfort and Safety Wind Modeling Results (cont’d)

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Table 2-2. Pedestrian Comfort and Safety Wind Modeling Results (cont’d)

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Table 2-2. Pedestrian Comfort and Safety Wind Modeling Results (cont’d)

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2.9 Transportation

2.9.1 Downtown Height and Density EIS The transportation impact modeling in the DHDC EIS was based on: the high-end growth assumptions forecasts from the City of Seattle’s travel demand forecasting model; and travel “mode share” information from the Puget Sound Regional Council’s travel demand model and included:  A forecasted 58% increase in the number of person-trips to or from Downtown (including internal trips);  An increase in the share of person-trips made by transit from 20% to 33%, translating to considerably more transit ridership;  A 5.5% increase in average auto occupancy to 1.33 persons per vehicle; and  An approximate 13% decrease in the share of person-trips made by automobiles. Analysis was based on the change from the baseline for nine traffic screenlines:  S. King St.  Seneca St.  Blanchard St.  1st Ave/Office Core  9th Ave./D. Triangle  6th Ave./Off. Core  NE Denny Triangle  Yesler/Jackson

2020 Baseline Future conditions were analyzed for the 2020 conditions under the No Action, or continuation of existing zoning. Conclusions were:  On an aggregate basis, volumes across all screenlines were projected to increase by 9.4% in the AM peak hour, and by 19.4% in the PM peak hour. This level of increase would be generally consistent with overall regional growth.  Some individual screenlines were predicted to experience more significant percentage traffic growth, including Screenlines 6 and 8 measuring east-west traffic and I-5 accessing traffic in the Denny Triangle, and Screenline 5 measuring east-west traffic near 1st Avenue in Belltown. For example, PM peak hour traffic volumes across Screenline 6 was projected to increase almost 70

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percent, across Screenline 8 was projected to increase 47 percent, and across Screenline 5 was projected to increase 33 percent by 2020.  PM peak hour traffic volumes across Screenline 7 (including access to/from I-5 at the Commercial Core) were projected to increase approximately 18 percent by 2020.  Three screenlines were forecasted to experience modest decreases in peak hour volumes by 2020, including Screenline 1 measuring north-south traffic near S. King Street, Screenline 4 measuring east west traffic for Downtown areas near 1st Avenue between Pine Street and Pioneer Square, and Screenline 9 measuring east-west traffic near 6th Avenue between Yesler Way and Jackson Street. These decreases were attributed to the addition of the SR 519 connection between I-5 and the Alaskan Way viaduct by 2020, which may alter traffic flow patterns measured by these screenlines.  For the 2020 AM peak hour, probable increases in housing supply in the study area were anticipated to result in more traffic departing Downtown. This outbound traffic will likely account for 48 percent of AM peak hour screenline volumes rather than the current 44 percent. This pattern will be most evident in the Denny Triangle area, where the two screenlines show large percentage increases in this AM peak hour outbound traffic.  The directional split in the PM peak hour traffic was projected to stay about the same, with outbound traffic representing 58 percent of the total screenline volumes, and inbound representing 42 percent.  PM peak hour traffic was expected to grow at a faster rate than AM peak hour traffic. By 2020, PM peak hour traffic is projected to be over 22 percent greater than AM peak hour traffic, when summing up volumes across all screenlines.  By 2020, four screenlines (two more than existing conditions) were anticipated to have v/c ratios of 0.80 or higher, indicating potentially congested operations:

o Screenline 2, north of Seneca St., both directions in the PM peak hour o Screenline 6, east of 9th Avenue, eastbound in the PM peak hour o Screenline 7, east of 6th Avenue, eastbound in the PM peak hour o Screenline 8, north of Minor Avenue, both directions in the AM and PM peak hours. These results are consistent with expected traffic growth patterns and orientation of a large portion of traffic either to/from the east (e.g., Interstate 5) or to/from the north via surface streets.  None of the screenlines were projected to exceed a v/c ratio of 1.20. At Screenline 8 east of Minor Avenue, eastbound volumes were expected to reach a v/c ratio of 1.01 in the AM peak hour and 1.11 in the PM peak hour. These ratios in excess of 1.0 indicate a projected high level of congestion in both peak hours.

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Alternative 1 High End Height and Density Increase  The High End alternatives was closest to the zoning adopted as part of the current code. However, while substantial changes from existing conditions were projected for the 2020 Baseline Condition, there were relatively limited differences between Alternatives 1, 2 and 3 and the Baseline Condition. Essentially all screenlines except Screenline 8 (East of Minor Avenue, Denny Way to Olive Way) were projected to experience the same relative capacity conditions, as the baseline.  At Screenline 8, eastbound PM peak hour traffic was projected to be approximately 8 percent greater than projected for the 2020 Baseline Condition This additional traffic was attributed to slightly greater concentration of future development in the Denny Triangle vicinity as compared to the Baseline/No Action Alternative. With this additional traffic, the predicted v/c ratio at Screenline 8 for eastbound PM peak hour traffic would reach 1.20 by 2020. This would be right at the 1.20 threshold defined as the City’s maximum arterial level of service standard. This screenline covers a relatively small number  Other screenlines anticipated to experience v/c ratios of 0.80 or higher for one or both travel directions include Screenlines 2, 6 and 7, in a manner similar to them Baseline/No Action Alternative.  AM Peak Hour conditions included 14 of 38 intersections operating at LOS E or worse in 2020, 3 more than the Baseline Condition.

o Operational levels would decline along Stewart Street and Denny Way, but improve somewhat along Howell Street.

o Five intersections would decrease in level of service by two or more LOS levels compared to the Baseline Condition, and two would improve by that amount.

o Queuing impacts: generally similar to the Baseline Condition, with several noted problem areas.  PM Peak Hour conditions included 19 of 38 intersections projected to operating at LOS E or worse in 2020, 2 more than the Baseline Condition.

o Operational levels would decline along Stewart Street and Denny Way. o Seven intersections would decrease in level of service by two or more LOS levels compared to the Baseline Condition.

o Queuing impacts: generally similar to the Baseline Condition, with additional queuing impacts predicted at two locations westbound on Stewart Street (at 8th and at Terry), and in multiple directions at Boren Avenue/Howell Street. Mitigation strategies identified included:  Transportation demand management (TDM) strategies including continuing and strengthening the then current TDM programs:

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o Requiring transportation management plans (TMPs) for new development o Greater implementation of TDM strategies, coordinated through worksites including discounted transit passes (e.g., Flex Pass), promotion of other alternative modes (walking, biking), increased telecommuting, business use of vans, carsharing, preferential parking for carpools/vanpools, guaranteed ride home, enhanced computerized ridematching database and mapping services, parking cashout (discontinuing parking subsidies and providing incentives for alternative modes), enhanced real-time transit information via Internet and on-street kiosks.  Residential-oriented TDM programs to reduce vehicle trip generation by encouraging alternatives to automobile ownership such as FlexCar and bus pass incentives.  Transportation Management Association (TMA) including should promote formation of a TMA by downtown stakeholders to aid in future TDM planning activities.

2.9.2 Addendum Information on Affected Environment

Traffic Volumes Existing weekday turning movement counts were collected at the study intersections in September 2014 between 7:00 and 9:00 AM and 4:00 and 6:00 PM. Existing traffic volumes are shown in Appendix C.

Traffic Operations A level of service (LOS) analysis was conducted for the study intersections to determine existing operating conditions. LOS is an estimate of the quality and performance of the transportation system. The primary industry standard for evaluating traffic congestion at intersections is based on the Transportation Research Board’s methodology outlined in the Highway Capacity Manual (HCM), with the letter “A” to describe the least amount of congestion and the best operations and the letter “F” for the highest amount of congestion and worst operations. Although the City of Seattle does not have an adopted intersection LOS standard, project-related intersection delay that causes an intersection to operate at LOS E or F, or increases delay at an intersection that is projected to operate at LOS E or F without the project, may be considered an impact. The existing AM and PM peak hour LOS for the 18 intersections evaluated are shown in Table 2-4. As shown in the table, the 6th Avenue / Seneca Street intersection currently operates at LOS F in the AM peak hour with over 120 seconds of delay. During the PM peak hour, the 6th Avenue / Spring Street intersection operates at LOS F with approximately 116 seconds delay.

Safety Collision data was obtained from Seattle Department of Transportation for the intersections within the study area (Table 4) for a four year period, between January 1, 2010 and December 31, 2013. The data was reviewed to identify which, if any, of the study area intersections, consistently had high collision rates and/or safety concerns.

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During the four-year study period, there were 347 reported collisions, with one fatality at the 6th Avenue / Union Street intersection. The predominant type of collision at the intersections was right- angle, which typically result from red light violations, or vehicles not clearing an intersection when the opposing movement signal turns from red to green.

Table 2-3. Existing AM and PM Peak Hour LOS

AM Peak Hour PM Peak Hour

(#) Intersection Delay Delay LOS (seconds / LOS (seconds / vehicle) vehicle) (1) SR 99 / Denny Way / 7th Avenue C 26 C 23 (2) 5th Avenue /Stewart Street B 20 B 16 (3) 5th Avenue /Olive Street B 10 B 12 (4) 7th Avenue /Union Street B 14 B 17 (5) 6th Avenue /Union Street B 19 B 19 (6) 6th Avenue /University Street B 13 B 15 (7) 6th Avenue /Seneca Street F >120 D 43 (8) 6th Avenue /Spring Street C 30 F 116 (9) 5th Avenue /Union Street B 13 B 13 (10) 5th Avenue /University Street B 20 C 27 (11) 5th Avenue /Seneca Street A 6 A 7 (12) 5th Avenue /Spring Street A 8 B 11 (13) 4th Avenue /Union Street A 8 A 8 (14) 4th Avenue /University Street A 8 B 16 (15) 4th Avenue /Seneca Street C 20 C 21 (16) 4th Avenue /Madison Street B 19 B 12 (17) 2nd Avenue /Madison Street B 12 B 14 (18) 2nd Avenue /Marion Street B 17 D 36

Pedestrian and bicycle facilities All roadways near the site location have sidewalks on both sides of the street, and include marked crosswalks and pedestrian signals at the intersections. Additionally, there are two mid-block roadway crossings, one located on 5th Avenue (between Union Street and University Street), and the other on University Street (between 4th Avenue and 5th Avenue). The crossing on 5th Avenue includes a traffic light and pedestrian signal, while the University crossing does not have a traffic signal or other feature to stop traffic. There are no dedicated bicycle lanes within the immediate study area. However, 4th Avenue includes a sharrow. The City’s adopted Bicycle Master Plan indicates future cycle tracks (protected bicycle lanes) could be located on 4th Avenue and Union Street. In-street bicycle lanes (with minor separation) is recommended for 5th Avenue. Transit

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A variety of transit options are available within the project study area, including bus and light rail. Primary transit providers include King County Metro and Sound Transit. There are two bus stops located adjacent to the project site, located along 4th Avenue between Union Street and University Street. Additionally, there are over 10 bus stops within two blocks of the site. These buses provide service to and from a variety of locations including areas around Downtown Seattle, Federal Way, Auburn, Kent, Renton, Mercer Island, SeaTac, Shoreline, and Kenmore. There is a dedicated Bus Only lane on 4th Avenue, between 6-9 AM and 3-7 PM daily. Future 2020 No- build conditions Appendix C includes a detailed description of conditions of the project study area in the future (2020) without the proposed development. The findings are summarized below.

Roadway network There are no planned modifications that would change the configuration of any of the 18 intersections evaluated in this study. However, the Alaskan Way Viaduct (SR 99) Replacement Program project that will change access to and from the study area from SR 99 with the primary routes to and from the south Spring Street and Marion Street, and primary routes out via Madison Street and Columbia Street.

Traffic volumes Year 2020 No-Build traffic volumes were forecasted using growth rates consistent with the Downtown EIS and pipeline project trips and are available in Appendix C.

Level of Service The 2020 No-Build AM and PM peak hour LOS for the 18 intersections evaluated in this analysis are shown in Table 2-5. As shown, the same intersections as the 2014 existing conditions are expected to operate at LOS F: 6th Avenue / Seneca Street in the AM Peak Hour and 6th Avenue / Spring Street in the PM Peak Hour. The remaining intersections are forecasted to operate at LOS D or better.

Table 2-4. 2020 No-Build AM and PM Peak Hour LOS

AM Peak Hour PM Peak Hour

Intersection Delay Delay LOS (seconds / LOS (seconds / vehicle) vehicle) (1) SR 99 / Denny Way / 7th Avenue C 27 C 24 (2) 5th Avenue /Stewart Street B 20 B 17 (3) 5th Avenue /Olive Street B 10 B 14 (4) 7th Avenue /Union Street B 14 B 18 (5) 6th Avenue /Union Street C 20 C 22 (6) 6th Avenue /University Street B 13 B 17 (7) 6th Avenue /Seneca Street F >120 D 51

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Table 2-4. 2020 No-Build AM and PM Peak Hour LOS

AM Peak Hour PM Peak Hour Intersection Delay Delay LOS (seconds / LOS (seconds / vehicle) vehicle) (8) 6th Avenue /Spring Street C 33 F >120 (9) 5th Avenue /Union Street B 13 B 15 (10) 5th Avenue /University Street C 21 C 31 (11) 5th Avenue /Seneca Street A 6 A 8 (12) 5th Avenue /Spring Street A 9 B 12 (13) 4th Avenue /Union Street B 10 A 9 (14) 4th Avenue /University Street A 8 B 19 (15) 4th Avenue /Seneca Street C 22 C 23 (16) 4th Avenue /Madison Street C 20 B 13 (17) 2nd Avenue /Madison Street B 12 B 15 (18) 2nd Avenue /Marion Street B 17 D 54

2.9.3 Addendum Information on Impacts

Project trip generation To determine new vehicle trips associated with the project, the total number of trips generated from the existing development and the total number of trips generated from the proposed development were calculated. Trip generation for both existing conditions and the proposed development was determined using rates and equations from ITE’s Trip Generation Manual. The total trip generation calculations included reductions for pass-by trip calculations (for the existing Quality Restaurant and Bank land uses), and reductions due to the availability of other modes of transportation including transit, bike, and walking. A detailed description of the mode split assumptions applied to the proposed development based on the Commute Seattle’s 2012 Center City Commuter Mode Split Survey Results Report (referred to as Mode Split Survey) is provided in Appendix C. Results are provided in the following tables.

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Table 2-5. Mode of Travel (Weekday)

ITE Trip Generation Manual Land Use (#) Vehicle Transit/Rail/Ferry Bike Walk General Office Building (710) 45% 45% 3% 7% Specialty Retail (826) 45% 45% 3% 7% Hotel (310) 100% 0% 0% 0% High-Rise Apartment (822) 100% 0% 0% 0%

To determine the net new vehicle trips associated with the proposed project, the total number of trips generated from the existing development were subtracted from the total number of trips generated by the proposed development. The proposed development is expected to increase traffic by 4,216 trips per day, with 657 of those occurring in the AM peak hour and 554 in the PM peak hour, as shown in Table 2-7.

Table 2-6 Vehicle Trips Generated by Proposed Development

AM Peak Hour PM Peak Hour ITE Trip Generation Manual Daily Land Use (#) Size Trips In Out Total In Out Total Existing Development Specialty Retail (826) 89,700 sf 1,790 13 15 28 48 61 109 Health/Fitness Club (492) 13,400 sf 200 5 4 9 12 9 21 Quality Restaurant (931) 20,200 sf 460 2 2 4 25 13 38 General Office Building (710) 15,700 sf 80 10 1 11 2 8 10 Walk-in Bank (911) 2,00 sf 50 2 2 4 4 4 8 Total 2,580 32 24 56 91 95 186 Proposed Development General Office Building (710) 790,000 sf 3922 488 66 554 90 440 530 Specialty Retail (826) 32,000 sf 640 5 5 10 17 22 39 Hotel (310) 180 rooms 1472 56 39 95 55 53 108 High-Rise Apartment (822) 181 dwu 762 14 40 54 38 25 63 Total 6,796 563 150 713 200 540 740 Net New Trips 4,216 531 126 657 109 445 554 * Trip generation calculation shown in this table include an adjustment to the ITE trip generation rates to account for higher transit usage where applicable.

Project trip distribution and Assignment The net new project trips were distributed onto the roadway network based on the City of Seattle Directors Rule 5-2009, and within the region based on local knowledge. Trip distributions were developed for the General Office Building and Specialty Retail land uses, and separate distributions for the Hotel, and High-Rise Apartment land uses. General Office Building and Specialty Retail land uses were combined as the patterns identified were similar. The resulting trip distributions are illustrated in Appendix C.

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Traffic operations Future 2020 levels of service were determined with the project and compared to conditions without the project (as well as existing conditions). The 2020 Build AM and PM peak hour LOS for the 18 intersections evaluated in this analysis are shown in Table 2-8. In addition, increases in LOS on screenlines analyzed in the DHDC EIS are shown in Table 2-9. The City’s transportation policies focus on meeting the current and future mobility needs of residents, businesses, and visitors with a balanced transportation system (Goal TG8). The City generally avoids increases in capacity except when needed to achieve system mobility goals and will not attempt to meet latent demand for travel by car (Policy T15). The City uses a system-wide method as a basis to assess the performance of the transportation system. The performance of the arterial system, is evaluated by comparing the calculated volume/capacity (vc) ratio for each screenline with the standard established for that screenline (Policy T-65). To evaluate transportation concurrency, the estimated vehicle trips generated by the project and background traffic volumes are compared to the capacity for the screenline. This comparison develops a volume-to-capacity ratio (v/c ratio). If the project’s v/c ratio is lower than or equal to the LOS v/c ratio standard for the screenline, the project passes concurrency. The three screenlines evaluated for this project were those in the DHDC EIS that are closest to the project and most likely to be affected:  North Seneca Street  1st Avenue / Office Core, East of 1st  6th Avenue / Office Core, East of 6th Overall, the screenline v/c ratios with the 5th & Union Project are similar to those identified in the Downtown EIS. The 5th & Union Project v/c ratios range from 1 percent lower to up to 7 percent higher than the Downtown EIS Build condition. The project v/c ratios are still under the City’s maximum screenline threshold of a v/c ratio of 1.00 to 1.20. Therefore transportation concurrency for the project is met and significant adverse impacts are avoided. Three of the study intersections were included in the Downtown EIS traffic analysis. These include 5th Avenue / Stewart Street, 5th Avenue / Olive, and SR 99 / Denny Way / 7th Avenue. The analysis shows that intersection operations with the 5th & Union Project operate at a better LOS than identified in the DHDC EIS as shown in Table 2-10. The SR 99 /Denny Way/7th Avenue intersection was projected to operate at LOS F in the PM Peak the year 2020 No Action condition and LOS E in the DHDC EIS Alternative 1 condition. Based on current count data and annual growth forecasted in the Downtown EIS, this intersection is forecasted to operate at LOS C or better in the year 2020 with or without the 5th & Union Project. Similarly the 5th Avenue/Stewart Street intersection was forecasted to operate at LOS F and 5th Avenue / Olive Street at LOS C in the DHDC EIS. Based on current count data and annual

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Table 2-7 Existing, 2020 No-Build and 2020 Build AM and PM Peak Hour LOS

AM Peak Hour PM Peak Hour

Intersection 2014 Existing 2020 No Build 2020 Build 2014 Existing 2020 No Build 2020 Build Delay Delay Delay Delay Delay Delay LOS LOS LOS LOS LOS LOS (seconds) (seconds) (seconds) (seconds) (seconds) (seconds) (1) SR 99 / Denny Way / 7th Avenue C 26 C 27 C 28 C 23 C 24 C 25 (2) 5th Avenue /Stewart Street C 20 C 20 C 20 B 16 B 17 B 17 (3) 5th Avenue /Olive Street B 10 B 10 B 11 B 12 B 14 B 15 (4) 7th Avenue /Union Street B 14 B 14 B 14 B 17 B 18 B 18 (5) 6th Avenue /Union Street B 19 C 20 D 38 B 19 C 22 C 23 (6) 6th Avenue /University Street B 13 B 13 B 16 B 15 B 17 C 21 (7) 6th Avenue /Seneca Street F >120 F >120 F >120 D 43 D 51 E 75 (8) 6th Avenue /Spring Street C 30 C 33 D 44 F 116 F >120 F >120 (9) 5th Avenue /Union Street B 13 B 13 B 14 B 13 B 15 B 15 (10) 5th Avenue /University Street C 20 C 21 C 28 C 27 C 31 F >120 (11) 5th Avenue /Seneca Street A 6 A 6 A 6 A 7 A 8 A 9 (12) 5th Avenue /Spring Street A 8 A 9 A 9 B 11 B 12 D 35 (13) 4th Avenue /Union Street A 8 B 10 B 10 A 8 A 9 B 11 (14) 4th Avenue /University Street A 8 A 8 A 9 B 16 B 19 B 19 (15) 4th Avenue /Seneca Street C 20 C 22 C 22 C 21 C 23 C 26 (16) 4th Avenue /Madison Street B 19 C 20 C 20 B 12 B 13 B 13 (17) 2nd Avenue /Madison Street B 12 B 12 B 12 B 14 B 15 B 15 (18) 2nd Avenue /Marion Street B 17 B 17 B 17 D 36 D 54 D 55

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Table 2-8. LOS Screenlines with Proposed Development

Screenline 2: North of Seneca Screenline 4: 1st Avenue / Screenline 7: 6th Avenue /

Street Office Core, East of 1st Office Core, East of 6th Direction NB SB WB EB WB EB Capacity 7,800 6,600 9,500 10,700 9,600 9,600 2020 No- Action Volume (Downtown EIS) Volume 4,950 3,760 2,560 2,820 6,740 6,250 5th & Union Project Project Trips 354 101 11 37 436 110 Volumes with Project 5,304 3,861 2,571 2,857 7,176 6,360 v/c Ratio 0.68 0.59 0.27 0.27 0.75 0.66 2020 Build, Alt 1 Volume (Downtown EIS)

AM Peak Hour Volume 4,980 3,790 2,530 2,820 6,700 6,310 v/c Ratio 0.64 0.57 0.27 0.26 0.70 0.66 Comparison (5th & Union Project / 2020 +7% +2% +2% +1% +7% +1% Build Alt 1) 2020 No-Action Volume (Downtown EIS) Volume 6,220 5,450 3,520 3,460 5,600 8,970 5th & Union Project Project Trips 105 313 32 13 121 362 Volumes with Project 6,325 5,763 3,552 3,473 5,721 9,332 v/c Ratio 0.81 0.87 0.37 0.32 0.60 0.97 2020 Build, Alt 1 Volume (Downtown EIS)

PM Peak Hour Volume 6,290 5,520 3,570 3,350 5,620 8,930 v/c Ratio 0.81 0.84 0.38 0.31 0.59 0.93 Comparison (5th & Union Project / 2020 +1% +4% -1% +4% +2% +5% Build Alt 1)

2-88 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum growth forecasted in the Downtown EIS, these intersections are forecasted to operate at LOS C or LOS B better in the year 2020 with or without the 5th & Union Project. All of these intersections fall within or below the range of impacts assessed in the DHDC EIS. As shown in Table 2-8, two intersections are expected to operate at LOS E or F in the future, with or without the project: 6th Avenue/Seneca Street (in the AM Peak Hour) and 6th Avenue/ Spring Street (in the PM Peak Hour). Additionally, two intersections are likely to experience LOS E or F with the project during the PM Peak Hour: 5th Avenue/University Street and 6th Avenue/Seneca Street. These individual intersection operations are not subject to the city’s impact assessment or concurrency criteria because the city relies on screenline v/c ratios which measures system performance rather than individual intersection performance. Individual intersections may operate at LOS E or F while the system as a whole continues to operate at acceptable level as measured by screenline v/c ratios. Nevertheless, in abundance of analysis, otential mitigation options for both intersections that would improve intersection operations to LOS D is described in Section 2.9.4 Mitigation.

Table 2-9. Intersection LOS Comparison to Downtown EIS

AM Peak Hour PM Peak Hour DHDC 2020 w/ DHDC 2020 w/ EIS 5th & EIS 5th & 2020 No 2020 Alt Union 2020 No 2020 Union (#) Location Existing* Action* 1* Project** Existing* Action* Alt 1* Project** (1) SR 99 / Denny B C C C C F E C Way / 7th Avenue (2) 5th Avenue F F F C B C C B /Stewart Street (3) 5th Avenue D C C B C D C B /Olive Street * Downtown EIS ** 5th & Union Project

Site Access Two driveways into the underground garage will be provided. An ingress/egress driveway will be located off of Union Street on the north side of the development. The egress movement will be left turn only as Union Street operates one-way westbound. On the south side, an egress driveway will be provided onto University Street. University Street is one-way eastbound, so the driveway will only allow left turns out.

Table 2-10. Driveway Level of Service

AM Peak Hour PM Peak Hour Intersection Delay (seconds Delay (seconds LOS LOS / vehicle) / vehicle) Union Street Driveway (egress movement) E 49 C 25 University Street Driveway (egress movement) B 11 C 19

Both driveways will be unsignalized and operate at LOS E or better in the year 2020 with the proposed development during the AM and PM peak hours. The delay would be experienced for the vehicles

Rainier Square Development 2-89 University of Washington Metropolitan Tract Environmental Impact Statement Addendum exiting the garage. The through traffic on Union or University would operate free flow. The driveway LOS operations are shown in Table 2-11.

Safety Typically as traffic or pedestrian volumes increase, so do the frequency of collisions. The increase in traffic associated with the development would inherently increase the frequency of collisions. However, the project development is not anticipated to worsen an existing geometric or roadway condition, thereby not creating an adverse impact. A warning sign at the top of the driveway exit onto University Street would help to increase awareness of pedestrians in the midblock crosswalk and minimize the potential for collisions. Additional discussion of the pedestrian crosswalks are included in Appendix C.

Parking The development would reconstruct the existing underground parking garage to include a total of 879 parking spaces. Occupants of the existing Rainier Tower will be reserved approximately 200 stalls. The remaining 679 parking spaces will support the office, specialty retail, hotel, and high-rise apartment land uses. The parking utilization throughout the day was estimated based on the ITE’s Parking Generation manual (4th edition, 2010). The peak use was calculated and the distribution of demand through the day was applied. The parking garage is forecasted to be fully utilized during the peak office hours (or 8 AM to 5 PM) based on the analysis in Appendix C. For eight hours, the demand could exceed the capacity by over 100 vehicles. The excess parking demand could be accommodated in other nearby parking facilities, or transit use by occupants of the building could be much higher resulting in lower parking demand from the project.

Pedestrian and Bicycle facilities The project area is served by a complete sidewalk network and two midblock crossings, located on University Street between 4th Avenue and 5th Avenue, and on 5th Avenue between Union Street and University Street. The mid-block crossing on 5th Avenue is signalized today. There are no anticipated changes to this condition with the 5th & Union Project. Directly east of the University Street driveway is a crosswalk which is currently unsignalized. Sight lines to the crosswalk from vehicle drivers exiting the garage would need to be maintained. There are a few options in how to operate and sign the crosswalk to improve safety.  Maintain conditions similar to existing - The crosswalk would be restriped and ramps will be improved to meet ADA requirements.  Full signalization – Full signalization of the crosswalk would stop University Street traffic when a pedestrian activates the signal. In addition, a warning system or stop control could be activated to stop the garage egress movement when the light is red to allow pedestrians to cross.

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 Rapid Rectangular Flashing Beacon (RRFB) mounted on the pedestrian crossing warning sign – RRFBs are amber LEDs that are activated by the pedestrian. The LED lights provide a warning system to vehicular traffic that a pedestrian is present. The advantage of RRFB’s over a full signal is the flashing LED lights are very visible in a wide variety of weather conditions. They are mounted at the driver’s eye height and have proven to be an effective way to catch a driver’s attention. The disadvantage of RRFB’s is it would be pedestrian activated and would not be timed to maintain signal progression on University Street. Bicycle-parking facility requirements, per the City of Seattle’s Land Use Code, are 1 space per 5,000 sf per the first 50,000 sf of office use, then 1 space per 10,000 sf after that. The project will provide adequate bicycle facilities to meeting the City code. Transit The DHDC EIS reported travel times for bus routes through the downtown CBD. The 5th & Union Project would likely increase transit ridership for routes serving the area. It is estimated that 45 percent of the Office Building and Specialty Retail trips would utilize transit. This is equal to 650 AM and 700 PM peak hour person trips. Given the transit service levels in the area, including Link light rail extensions to Lynnwood and Bellevue, there would be adequate capacity to serve this increase in demand. Transit travel times and reliability are dependent on a well-functioning transportation system. The operations analysis indicated that two of the study intersections that are within the transit corridors would operate at LOS F if no changes to signal timings or capacity changes were provided. However, signal timing changes and rechannelization has been identified that would improve these intersection operatation to LOS D or better, or similar to the No Build condition.

Transportation Concurrency The City of Seattle established a Transportation Concurrency policy under the Washington State Growth Management Act. The City uses a screenline approach to monitor transportation concurrency. The City has defined 30 screenlines, each of which encompass one or more arterials in the City, and has an established LOS standard. Three screenlines were evaluated for this project with results presented in Table 2-9 above. Screenline v/c ratios with the project are under the City’s thresholds of 1.00 to 1.20. Therefore transportation concurrency for the project is met.

Construction Impacts Construction impacts on Transportation is addressed in Section 2.11.6 Addendum Information on Construction Impacts on Transportation.

2.9.4 Mitigation Measures It is the intent of the State Environmental Policy Act that if regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts additional mitigation should not be

Rainier Square Development 2-91 University of Washington Metropolitan Tract Environmental Impact Statement Addendum imposed (RCW 43.21C.240, WAC 197-11-660(1)(g)). Seattle’s Environmental Policies and Procedures (SMC 25.05.660.A.5) directs considering whether local, state, or federal requirements and enforcement would mitigate an identified significant impact before requiring mitigation measures. Seattle Municipal Code (SMC) 25.05.675 R. 2. contains specific environmental policies for Traffic and Transportation. a. It is the City's policy to minimize or prevent adverse traffic impacts which would undermine the stability, safety and/or character of a neighborhood or surrounding areas. b. In determining the necessary traffic and transportation impact mitigation, the decisionmaker shall examine the expected peak traffic and circulation pattern of the proposed project weighed against such factors as the availability of public transit; existing vehicular and pedestrian traffic conditions; accident history; the trend in local area development; parking characteristics of the immediate area; the use of the street as determined by the Seattle Department of Transportation's Seattle Comprehensive Transportation Plan; and the availability of goods, services and recreation within reasonable walking distance. c. Mitigation of traffic and transportation impacts shall be permitted whether or not the project meets the criteria of the Overview Policy set forth in SMCError! Hyperlink reference not valid. d. Mitigation measures which may be applied to residential projects in downtown are limited to the following: i. Signage; ii. Provision of information on transit and ride-sharing programs; and iii. Bicycle parking. e. Mitigating measures which may be applied to nonresidential projects in downtown are limited to the following: i. Provision of transit incentives including transit pass subsidies; ii. Signage; iii. Improvements to pedestrian and vehicular traffic operations, signalization, turn channelization, right-of-way dedication, street widening, or other improvements proportionate to the impact of the project; and iv. Transportation management plans. As described above, two of the study intersections are likely to experience LOS E or F conditions with the project compared to conditions without the project during the PM Peak Hour. Mitigation of individual intersection LOS is not required by the city since the city’s impact assessment and concurrency criteria relies on screenline v/c ratios which measures system performance rather than

2-92 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum individual intersection performance. Potential mitigation options for both intersections would improve intersection operations to LOS D. The intersection of 5th Avenue/University Street is projected to experience LOS F conditions with the project compared to LOS C without the project. The intersection currently includes three through lanes and an exclusive right turn lane. Converting an eastbound through lane to an eastbound through/right and retiming the signal to move up to ten seconds of green time from the southbound movement to the eastbound movements could improve the signal operations to LOS D. Downtown traffic operations, however are affected by queues between intersections that will back up and affect operations at nearby intersections as noted in the DHDC EIS. Under congested conditions, individual intersection impacts and mitigation are less applicable. The intersection at 6th Avenue / Seneca Street is projected to experience LOS E conditions with the project compared to LOS D without. Reducing the northbound pedestrian walk time from 10 seconds to 5, and reallocating green time to the off ramp movement would improve the signal operations from LOS E to LOS D. The Seattle Municipal Code 23.52.004 requirement to meet transportation concurrency level-of- service standards provides that non-exempt development must demonstrate that the traffic forecasted to be generated by the use or development will not cause the transportation concurrency level-of-service (LOS) at an applicable screenline, measured as the volume-to-capacity ratio (v/c), to exceed the LOS standard for that screenline. Screenlines are shown in Exhibit 23.52.004 A. LOS standards for those screenlines are shown in Exhibit 23.52.004 B. "Applicable screenlines" means up to four (4) of the screenlines shown in Exhibit 23.52.004 A as specified for a particular proposed use or development by the Director. Of the screenlines analyzed,  Screenline 2: North of Seneca Street provides a measure of north-south traffic flow that is roughly equivalent to the Exhibit 23.52.004 A & B Screenline 10.11 South of S Jackson St. Alaskan Way S to 4th Ave. S. The Screenline LOS standard is a v/c ratio of 1.00. The calculated v/c ratio of 0.68 Northbound and 0.59 Southbound is well below the DHDC EIS projected v/c ratio of 0.80 and well below the standard.  Screenline 7: 6th Avenue / Office Core, East of 6th provides a measure of east-west traffic flow that is roughly equivalent to the Exhibit 23.52.004 A & B Screenline 12.12 East of CBD. The Screenline LOS standard is a v/c ratio of 1.20. The calculated v/c ratio of 0.70 Westbound and 0.66 Eastbound is below the DHDC EIS projection of 0.76 and well below the standard. Seattle Municipal Code (SMC) 23.52.008.C provides for impact mitigation. Based upon the results of the transportation impact analysis the Director may condition permit approval, as a Type I decision, to mitigate or prevent transportation impacts. 1. Except as provided by subsection 23.52.008.C.2, required mitigation may include, but is not limited to: a. changes in access;

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b. changes in the location, number and size of curb cuts and driveways; c. provision of transit incentives, including transit pass subsidies; d. bicycle parking, and shower facilities for bicycle commuters; e. signage, including wayfinding; f. improvements to vehicular, pedestrian and bicycle traffic facilities or operations including signalization, turn channelization, right-of-way dedication, street widening, pedestrian and bicycle facilities improvements, and lighting; g. transportation management plans; h. parking management strategies including, but not limited to, unbundling parking from building-space leases, reserved parking spaces for vanpools, and reduction in the amount of parking to be provided; and i. participation in a transportation mitigation payment program or transportation management association, where available. 2. Mitigation that may be required for residential projects in downtown zones or the residential portion of mixed use projects in downtown zones is limited to: a. signage, including wayfinding; b. provision of information on transit and ride-sharing programs; and c. bicycle parking.

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2.10 Energy/Greenhouse Gas Emissions

2.10.1 Downtown Height and Density EIS The analysis in the DHDC EIS addressed energy but did not address greenhouse gas emissions, except as it related to City Light mitigation of greenhouse gas emissions associated with energy production. The EIS analysis focused on the need for electrical energy to serve new development in the downtown. The analysis assumed the same amount of growth among all alternatives, but with differences in distribution. The analysis noted that if several new large projects with significant energy demands are located in a concentrated area, this could challenge available electrical infrastructure capacity. Such limitations and needed improvements would be closely monitored on an ongoing basis and addressed in City Light’s Capacity Plan. The analysis projected the need for a new substation to be energized by 2012, and significant planning and construction over 7-8 years.

2.10.2 Addendum Information on Affected Environment

2.10.2.1 Energy Energy demand in the downtown is generally consistent with the analysis in the DHDC EIS, although the growth in demand was delayed by the economic slowdown during the Great Recession of December 2007 to June 2009, and the extended period of slow economic growth that lasted until 2011 in the Seattle Metropolitan Area and continues in some parts of the country. Energy demand for the proposed C project is well within the load planning parameters of Seattle City Light and other utilities and is consistent with analysis in the DHDC EIS.

2.10.2.2 Greenhouse Gasses Greenhouse gases are gases in the atmosphere that absorb and emit radiation, which is the fundamental cause of the greenhouse effect. Common greenhouse gases in the earth’s atmosphere include water vapor, carbon dioxide, methane, nitrous oxide, ozone, and chlorofluorocarbons. Greenhouse gases, mainly water vapor, are essential to helping determine the temperature of the earth; without these gases, this planet would likely be so cold as to be uninhabitable. Although many factors, such as the sun and the water cycle, are responsible for the earth’s weather and energy balance, if all else was held equal and stable, the planet’s average temperature would be considerably lower without greenhouse gases. There is a growing scientific consensus that global temperature increases of more than 2 degrees Celsius (°C) above pre-industrial levels would lead to devastating global impacts. Leading scientists have projected that stabilization of atmospheric carbon dioxide emissions to avoid temperature increases greater than 2° C will require a reduction of greenhouse gas emissions to approximately 80 percent below current levels by the year 2050.

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Greenhouse gas emissions associated with development originate from multiple sources:  Extraction, processing, transportation, construction, and disposal of building materials;  Landscape disturbance;  Energy demands created by a development after it is completed; and  Transportation demand created by a development after the development is complete.

2.10.2.3 Policy Framework

Western Climate Initiative The Western Climate Initiative (WCI) began in February 2007 when the Governors of Arizona, California, New Mexico, Oregon, and Washington signed an agreement directing their respective states to develop a regional target for reducing greenhouse gas emissions, participate in a multi-state registry to track and manage greenhouse gas emissions in the region, and develop a market-based program to reach the target. The WCI built on existing greenhouse gas reduction efforts in the individual states as well as two existing regional efforts. In 2003, California, Oregon and Washington created the West Coast Global Warming Initiative, and in 2006, Arizona and New Mexico launched the Southwest Climate Change Initiative. During 2007 and 2008, the Premiers of British Columbia, Manitoba, Ontario, and Quebec, and the Governors of Montana and Utah joined the original five states in committing to tackle climate change at a regional level. All 11 jurisdictions collaborated in the development of the Design for the WCI Regional Program, which was released in July 2010. In November, 2011, the Western Climate Initiative formed Western Climate Initiative, Inc. (WCI, Inc.), a non-profit corporation that will provide administrative and technical services to support the implementation of state and provincial greenhouse gas emissions trading programs.

State of Washington In February of 2007 the Governor issued Executive Order No. 07-02 establishing goals for reductions in emissions, increases in jobs, and reductions in expenditures on imported fuel. This Order established the following goals for reducing greenhouse gas emission: to reach 1990 levels by 2020, 25 percent below 1990 levels by 2035, and 50 percent below 1990 levels by 2050. This order was intended to address climate change, encourage a clean energy economy and move the state toward energy independence. In 2009, Executive Order 09-05 was signed ordering Washington State agencies to reduce climate-changing greenhouse gas emissions, to increase transportation and fuel-conservation options for Washington residents, and protect the State’s water supplies and coastal areas. The Washington Legislature in 2007 passed SB 6001, which adopted the Executive Order No. 07-02 goals into statute. In 2008, the Washington Legislature passed E2SHB 2815, the Greenhouse Gas Emissions Bill that made targets a state-wide requirement (RCW 70.235.020) and directed the state to

2-96 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum submit a comprehensive greenhouse gas reduction plan to the Legislature by December 1, 2008. As part of the plan, the Department of Ecology was mandated to develop a system for reporting and monitoring greenhouse gas emissions within the state. In 2013 the legislature passed SB 5802 that requires that the state hire a contractor to come up with the best strategy to reduce greenhouse gas emissions. That will involve studying what other states and provinces are doing to cut theirs. In 2008 the Department of Ecology issued a memorandum stating that climate change and greenhouse gas emissions should be included in all State Environmental Policy Act (SEPA) analyses and on December 1, 2010 revised the SEPA Rules to add WAC 173-441 Reporting of Emission of Greenhouse Gases. This rule aligns the State’s greenhouse gas reporting requirements with EPA regulations, and requires facilities and transportation fuel suppliers that emit 10,000 metric tons carbon dioxide equivalents or more per year, to report their GHG emissions to Ecology.

City of Seattle In 2007, the Seattle City Council adopted Comprehensive Plan goals and policies for achieving reductions in greenhouse gas (GHG). Later that year, the City Council adopted Ordinance No. 122574, which requires City departments that perform environmental review under SEPA to evaluate GHG emissions when reviewing applications for development permits. In April 2011, the City Council adopted Ordinance No. 123575, which amended the City’s Comprehensive Plan (Section E on Environment) to provide for a Climate Action Plan to meet the goal of carbon neutrality by 2050; the plan was adopted by the Seattle City Council on June 17, 2013. The City performed a Greenhouse Gas Inventory for the 2012 which provides a baseline for emissions by the Seattle Campus. The inventory included the following sources of emissions:  “Core” emissions are those which the City has the greatest opportunity to influence and are the focus of Seattle’s 2013 Climate Action Plan: building energy use, road transportation, and waste management. The Plan recommends a package of actions to reduce GHG emissions in these core sectors by 58% by 2030 and 87% by 2050 from recent (2008) levels, not including offsets.  “Expanded” emissions include additional sources, such as industry, marine, rail, and air travel, yard equipment, and wastewater treatment. These sources serve regional or national demands and/or are more difficult for the City to influence. While these sources are not as directly within the City’s sphere of influence, Seattle remains interested in an expanded view of its GHG emissions to monitor emissions trends and identify opportunities where City actions can have an impact. (Seattle 2012) Seattle’s core emissions are from the road transportation, building energy, and waste sectors. In 2012, road transportation (especially passenger travel) comprises the largest share of Seattle’s core emissions at 64%. Emissions associated with building energy comprise 33%, while emissions from waste comprise 3% (Figure 2-8).

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Figure 2-8. Seattle Greenhouse Gas Inventory by Major Contributor

Table 2-11. Seattle Greenhouse Gas Inventory

Gross Annual Emissions Metric Tons CO2 GHG Sources 1990 2012 Transportation Road: Passenger 1,561,000 1,670,0007 Road: Freight 635,000 720,000 Buildings Residential 721,000 538,000 Commercial 744,000 705,000 Waste 122,000 95,000

TOTAL 3,783,000 3,728,000 Seattle City Light Offset Purchases -81,000 TOTAL WITH OFFSETS 3,783,000 3,647,000 Per Person 7.3 5.7

Source: Seattle 2012

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2.10.3 Addendum Information on Potential Impacts

2.10.3.1 Energy Energy demand for the proposed C project is well within the load planning parameters of Seattle City Light and other utilities and is consistent with analysis in the DHDC EIS.

2.10.3.2 Greenhouse Gas This analysis provides an estimate of the greenhouse gas emissions that would result from the proposed office, residential retail and hotel buildings and uses. The estimate includes separate estimates for three sources of greenhouse gases using the King County/Seattle SEPA Greenhouse Gas Emissions Worksheet (King Co. 2007) which is reproduced in Appendix D.  Embodied greenhouse gas emissions were calculated for the building life-cycle. This calculation accounted for all emissions resulting from construction, including emissions related to manufacturing of the materials used in the project action, transportation of people, goods, and materials to the project site for construction, operation of equipment used in construction or development, and energy used in construction and development. The GHG Emissions Worksheet for embodied emissions uses standard multipliers for common types of buildings but does not include specific adjustments for the specific construction type for this building or for the LEED features incorporated in the project. Adjustment were made for multi-family residential based on a multiplier similar to office use since it occupies the upper levels of the high rise building. The underground parking multiplier was based on industry calculations of the emission burden for excavation and concrete construction (Athena 2010, Johnson 1996).  Energy-related greenhouse gas emissions include emissions annually and over the life of the project. This estimate takes into account heating, cooling, lighting, operating equipment, and similar activities. The standard rates were used which does not take into account that electrical energy supplied by Seattle City Light is carbon neutral. Standard multipliers were used for all uses except residential where a slightly higher rate was used in recognition of additional energy use in a high rise building for facilities such as elevators.  Transportation-related greenhouse gas emissions were calculated annually and over the building life-cycle. Standard multipliers were used for lodging, retail and residential. Office transportation was reduced to 60% of the standard multipliers in recognition that the downtown achieves a higher use of transit and other alternatives to single occupant vehicles. No transportation component was assigned to underground parking because transportation is embedded in other uses. As shown in Table 2-12 the projected annual greenhouse gas emissions are projected to result primarily from office use, which is the predominant floor area of the building.

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Table 2-12. Project Annual Greenhouse Gas Emissions (Metric Tons of Carbon)

Building Component Unit Embodied Energy Transportation Total Percent Office 780,000 sf 30,200 5464,000 320,800 915,000 70% Residential 178 units 9,240 112,000 84000 205,240 16% Hotel 200 rooms 4,650 93,300 14,059 112,000 9% Retail 74,000 sf 2,900 42,700 18,260 63,800 5% Parking 369,000 sf 5,500 3,700 0 9,225 1% TOTAL: 52,500 815,600 437.100 1,305,300

As can be seen from the table above, the office use is the largest producer of greenhouse gasses, as would be expected as it is the largest use in the proposed development as well as the most intensive use. The greenhouse gas emissions associated with the project would contribute to the cumulative carbon footprint of the City of Seattle. These estimates, however cannot be compared with the citywide estimates in Table 2-12 above because of a difference in methodology and because the estimates above include embodied emissions. Greenhouse gas emissions for this development would be less than for a similar size development outside of the downtown because the location of high intensity office and multi-family residential uses in a pedestrian-oriented urban center with convenient access to regional transit, where the mix of activity provides convenient access to a full range of services and amenities, and opportunities for people to live within walking distance of employment all reduces the energy use and greenhouse gasses as compared to lower intensity development and development in less concentrated centers. Operational energy use and related greenhouse gasses is largely related to consumption of electricity by HVAC systems, lighting and elevators. Since Seattle City Light has been carbon neutral since 2005, greenhouse gasses are not produced from these sources.

2.10.4 Mitigation Measures It is the intent of the State Environmental Policy Act that if regulations provide adequate analysis of and mitigation for the specific adverse environmental impacts additional mitigation should not be imposed (RCW 43.21C.240, WAC 197-11-660(1)(g)). Seattle’s Environmental Policies and Procedures (SMC 25.05.660.A.5) directs considering whether local, state, or federal requirements and enforcement would mitigate an identified significant impact before requiring mitigation measures. Potential mitigating measures related to the three components of energy consumption and greenhouse gas emissions.  Embodied materials used in construction, which includes energy for manufacture, transport and used in construction  Energy emissions related to operation, and  Transportation The project is consistent with the City Climate Action Plan Implementation Strategy TLU 17 by location near existing and planned high capacity transit.

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The building developer has addressed embodied and operational sources by committing to LEED standards for the building which reduces greenhouse gas emissions. This is consistent with the City Climate Action Plan Implementation Strategy BE 9 of promoting the most sustainable buildings. The Leadership in Energy and Environmental Design (LEED) is a set of rating systems for the design, construction, operation, and maintenance of green buildings developed by the U.S. Green Building Council (USGBC), a non-profit organization headquartered in Washington, D.C. The LEED certification process uses a point system to determine the environmental merits of a building; there are different rating systems for homes, commercial buildings, interior renovations, schools, neighborhood developments, and other construction projects. For most projects, there are four levels of LEED certification, depending on how many points the project has earned. According to the USGBC, there are nine key areas measured by LEED:  Sustainable Sites  Water Efficiency  Energy and Atmosphere  Materials and Resources  Indoor Environmental Quality  Location and Linkages  Awareness and Education  Innovation in Design  Regional Priority Key measures that may contribute to LEED certification include:  Construction waste management to include salvaging demolished material and construction waste for recycling.  Recycled content of construction materials.  High performance glazing reducing heat gain.  Drought resistant and tolerant planting in landscaped areas to minimize irrigation requirements.  Use of outside air for heating, ventilating, and air conditioning.  Efficient light fixtures and controls based on occupancy and time of day.  Low flow plumbing fixtures;  Reduction in transportation related energy use related to the downtown location where a majority of office workers commute by transit, carpooling, bicycles and walking. The project is anticipated to encourage bicycling by including facilities for bicycle storage, showers and locker rooms. Operational energy use and related greenhouse gasses related to consumption of electricity is mitigated by LEED elements. In addition use of electricity supplied by Seattle City Light reduces greenhouse emissions since the utility has been carbon neutral since 2005.

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Energy and greenhouse gasses produced by transportation are currently mitigated to a substantial extent in the downtown through the greater use of transit for commuters, which is much more efficient than use of automobiles. Participation in Transportation Management Programs (TDM) as outlined in the transportation section above can further encourage transit use as well as walking and bicycle use. Regional transit facilities such as extension of the Sound Transit Link Light Rail system can be expected to both increase transit use to the downtown as well as use of electricity as a power source in light rail that further reduces greenhouse gas emissions (Sound Transit 2015).

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2.11 Construction This section describes impacts that could result from construction of the proposal on the site. Demolition, site preparation, excavation, and building construction would generate short-term environmental impacts relating to air quality, noise, transportation/ circulation/parking, and public services. While the majority of construction activity would occur during the daytime, it may be necessary for some construction activity to occur during evening and night-time hours in order to reduce the duration of the overall construction timeframe and/or because the City requires certain construction activities to avoid daytime hours in order to reduce impacts to pedestrians and vehicle circulation. The Seattle Municipal Code (SMC) environmental policies for construction impacts are found in Section 25.05.675 B.2: a. It is the City's policy to minimize or prevent temporary adverse impacts associated with construction activities. b. The decision maker may require, as part of the environmental review of a project, an assessment of noise, drainage, erosion, water quality degradation, habitat disruption, pedestrian circulation and transportation, and mud and dust impacts likely to result from the construction phase. c. Based on such assessments, the decision maker may, subject to the Overview Policy set forth in SMC Section 25.05.665, condition or deny a project to mitigate adverse impacts of the construction process. d. Noise. Mitigating measures to address adverse noise impacts during construction include, but are not limited to: i. Limiting the hours of construction; ii. Specifying the time and duration of loud noise; iii. Specifying a preferred type of construction equipment; and iv. Requiring sound buffering and barriers. e. Drainage. Mitigating measures to address adverse drainage impacts during construction may include, but are not limited to: i. Sedimentation traps and filters; ii. Sedimentation tanks or ponds; iii. Oil separators; iv. Retention facilities; v. Maintenance programs;

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vi. Performance bonds; and vii. Non disturbance areas. f. Pedestrian Circulation. Mitigating measures to address adverse impacts relating to pedestrian circulation during construction may include, but are not limited to: i. Covered sidewalks or alternate safe, convenient and adequate pedestrian routes; and ii. Limits on the duration of disruptions to pedestrian flow. g. Transportation. Mitigating measures to address transportation impacts during construction may include, but are not limited to: i. A construction phase transportation plan which addresses ingress and egress of construction equipment and construction worker vehicles at the project site; ii. Traffic control and street maintenance in the vicinity of the construction site; iii. Rerouting of public vehicular and pedestrian circulation in the vicinity of the construction site; iv. Providing a temporary High Occupancy Vehicle (HOV) incentive program for construction workers at the site to reduce the number of their vehicle staking parking places in the vicinity of the construction site; and v. HOV discounts for members of the public who were displaced from a traditional parking area by the construction activity.

2.11.1 Downtown Height and Density EIS The analysis in the DHDC EIS did not address project construction impacts because it was a non- project EIS.

2.11.2 Addendum Information on Air Quality

Affected Environment The dominant air quality pollutant in Downtown Seattle is carbon monoxide (CO) emissions resulting from vehicular traffic operating on City streets, Interstate 5, and SR-99. The Puget Sound area as a whole, including the downtown is in compliance with CO standards, having been designated a compliance area in 1996 with approval of a carbon monoxide and ozone maintenance plans and subsequent updates to both plans approved in 2004. Particulate matter is the term for small particles of dust, soot, and organic matter suspended in the atmosphere. Coarse particulate matter has a diameter of less than 10 micrometers and is referred to as PM10. Fine particulate matter has a diameter of 2.5 micrometers or smaller, and is referred to as PM2.5. Sources of particulate matter include motor vehicles, industrial boilers, wood stoves, open burning, and dust from roads, quarries, and construction activities. Relating to transportation sources, road and construction dust is often in the larger PM10 range, while vehicle exhaust emissions are generally in

2-104 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum the smaller PM2.5 range. In particular, diesel exhaust is a significant source of fine particles. The area in compliance with particulate standards, for both PM 10 and PM 2.5 particulates. The Puget Sound Clean Air Agency (PSCAA) is responsible for administration of air quality regulations in the central Puget Sound, including permits for industrial and other point sources. PSCAA also regulates the release of any air contaminant in sufficient to be, injurious to human health, plant or animal life, or property, or which unreasonably interferes with enjoyment of life and property. Odor and dust are specific contaminants that are typically related to construction. (PSCAA 2014)

Impacts Construction may generate air pollutants as a result of fugitive dust from demolition, earthwork and other site preparation and construction activities, as well as emissions from construction vehicles. Demolition of existing structures would require the removal and disposal of building materials that could contain asbestos and lead-based paint. Prior to demolition, an asbestos survey may be required and, if needed, a demolition permit would be required from Puget Sound Clean Air Agency (PSCAA). Trucks transporting construction debris, excavated earth and/or construction materials would emit carbon monoxide, hydrocarbons and particulates along truck haul routes. Construction-related truck movements, however, are not expected to cause violations of applicable ambient air quality standards. Site development would comply with the City’s construction best practices regarding demolition activity and fugitive dust emissions, and PSCAA requirements including:  Minimize the period of soil exposure through use of temporary ground cover and other temporary stabilization practices  Sprinkle the site with water until surface is wet.  To prevent carryout of mud onto street, install Stabilized Construction Entrance and Tire Wash  Spray exposed soil areas with approved dust palliative. (Seattle 2014b)

Air Quality Mitigation Measures Best Management Practices for dust suppression during demolition and excavation would likely provide adequate mitigation of typical construction impacts.

2.11.3 Addendum Information on Noise

Affected Environment Noise is defined as unwanted sound and is measured in terms of sound pressure level. The decibel scale (dB) is used to describe sound and is a logarithmic rating system that accounts for the large differences in audible sound intensities. This scale accounts for the human perception of a doubling of loudness as an increase of 10 dB. Therefore, a 70-dB sound level would sound about twice as loud as a 60-dB sound level. People generally cannot detect differences of 1 dB except in ideal laboratory situations. A difference of 2 or 3 dB can be detected by most people, but such a change probably

Rainier Square Development 2-105 University of Washington Metropolitan Tract Environmental Impact Statement Addendum would not be detectable in an average outdoor environment. A 5-dB change would probably be perceived under normal listening conditions. When addressing the effects of noise on people, it is useful to consider the frequency response of the human ear. The human ear is less sensitive to higher and lower frequencies than to middle-range frequencies. Therefore, instruments are designed to approximate the frequency response of human hearing Measurements made with this weighing system are termed A-weighted and are specified as dBA readings. All sound levels in this evaluation are reported in A-weighted decibels. Sound levels associated with a range of common noise sources are shown in Table 2-13.

Table 2-13. Sound Levels Produced by Common Noise Sources

Sound Level Subjective Thresholds/Noise Sources (dBA) Evaluations Possible Effects on Humans Human threshold of pain Continuous exposure to levels above 70 dBA 140 Deafening Carrier jet takeoff at 50 feet can cause hearing loss in majority of population Siren at 100 feet 130 Loud rock band Jet takeoff at 200 feet 120 Auto horn at 3 feet Chain saw Noisy snowmobile 110 Impact pile driver Lawn mower at 3 feet 100 Very Loud Noisy motorcycle at 50 feet Heavy truck at 50 feet 90 Pneumatic drill at 50 feet 80 Loud Busy urban street, daytime Normal automobile at 50 mph 70 Speech Interference Vacuum cleaner at 3 feet Air conditioning unit at 20 feet 60 Moderate Conversation at 3 feet Quiet residential area 50 Sleep Interference Light auto traffic at 100 feet Library 40 Faint Quiet home Soft whisper at 15 feet 30 Slight rustling of leaves 20 Very Faint Broadcasting studio 10 Threshold of Human Hearing 0

Source: EPA (U.S. Environmental Protection Agency). 1974. Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety, EPA/ONAC 550/9-74-004, March 1974. Available on the Internet at: http://www.epa.gov/nscep/index.html.

Distance from the source, the frequency of sound, the absorbency of the intervening ground, obstructions, and duration of the noise-producing event all affect the transmission and perception of

2-106 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum noise. The degree of this effect also depends on who is listening and on existing sound levels. The variability in the way individuals react to noise makes it impossible to accurately predict how any one individual would respond to a given noise. However, when the community is considered as a whole, trends emerge that relate noise to annoyance. Two main types of health effects may potentially occur from excessive noise: auditory and non auditory. Auditory impacts are caused by high noise levels that can potentially damage hearing and produce either partial or total deafness. Non-auditory health impacts include sleep and speech disturbance and may also involve human physiological (other than hearing damage) or behavioral effects. Traffic noise is generally not experienced at a loud enough level or over a long enough period of time to cause hearing impairment, and is more often considered as a factor of non-auditory health impacts such as sleep deprivation. The equivalent sound pressure level represented as Leq is a constant sound level that has the same sound energy as the actual, fluctuating sound being measured by an instrument. As such, it can be considered an energy-average sound level. In discussing sound level measurements and predictions, it is important to identify the time period being considered because most sound-energy criteria address sound-energy averages over a time period. In this way, noise criteria address both the intensity and the duration of sounds. Environmental noise level limitations are regulated by the Seattle Department of Planning and Development under the City’s noise ordinance (Seattle Municipal Code [SMC], Chapter 25.08). This ordinance adopts provisions similar to those contained in Washington State's Maximum Environmental Noise Levels (Washington Administrative Code [WAC] 173 60). Washington State and City of Seattle maximum permissible sound levels are shown in Table 2 15 and Table 2-16, respectively.

City of Seattle noise standards indicated in Table 2-15 are similar to the state standards, but utilize zoning rather than land use to define receiving property. The City of Seattle also uses a Leq measurement with an interval of 1 minute for a constant sound source or a 1-hour measurement for a non-continuous sound source with a limit of a maximum of 15 dBA above the maximum. This measurement process results in somewhat higher thresholds than the state system, which is based on instantaneous noise measurements with a provision for exceeding the level for short time periods.

City of Seattle regulations allow construction activities to exceed the noise standard between 7 am and 7 pm on weekdays and between 9 am and 7 pm on weekends and legal holidays in residential districts. For other districts, or for equipment used for a public project, the exceedance period is between 7 am and 10 pm on weekdays and between 9 am and 10 pm on weekends and legal holidays (SMC 25.08.425). The maximum level of exceedance is as follows:  25 dBA for equipment on construction sites, including but not limited to crawlers, tractors, dozers, rotary drills, augers, loaders, power shovels, etc.;

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 20 dBA for portable-powered equipment, such as chainsaws, log chippers, lawn and garden maintenance equipment, and powered hand tools; and

Construction Noise Impacts  During construction, there would be a temporary increase in sound levels in the immediate vicinity. The majority of this noise would result from the use of heavy construction equipment (excavators, bulldozers, generators, etc.) and the hauling of soils and construction materials. The increase in noise levels would depend on the type of equipment being used as indicated in Table 2-16. The increase in noise levels would depend on the type of equipment being used and the amount of time it is in use.  An additional concern with construction noise is the character of the noise. Most construction noise is characterized by intermittent and tonal qualities that change the impact on receivers.  15 dBA for powered equipment used in periodic maintenance or repair of the grounds of residential property, including but not limited to lawnmowers, powered hand tools, snow- removal equipment, and composters. City of Seattle limits sounds created by impact types of equipment (such as pavement breakers, pile drivers, jackhammers, sandblasting tools) to 8 am and 5 pm on weekdays and 9 am and 5 pm on weekends with the following maximums:  Leq 90 dBA continuously;  Leq 93 dBA for 30 minutes;  Leq 96 dBA for 15 minutes; and  Leq 99 dBA for 7 1/2 minutes.  Leq in excess of 99 dBA are prohibited without a variance. Short duration, high-intensity, intermittent noises are judged by most people to be more annoying than steady noises having the same overall energy content. Even when impulses are regular and expected, their sharpness and startle effects contribute to increased annoyance. Impulsive noise events are more likely to cause deeper annoyance during the night than during the day and to increase the overall sensitivity to the noise. Therefore, some impulsive noises can be disturbing to some individuals if heard at all—classically, the dropping of a pin or dripping of a faucet—even though they may be lower than the normal ambient or background noise levels (Niedzielski 1991).

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Table 2-14. State of Washington Maximum Permissible Environmental Sound Levels

EDNA of Receiving Property Environmental Designation for Noise Abatement (EDNA) of Noise Source Class A Class B Class C Class A (Residential, recreational, entertainment, and community 55 dBA 57 dBA 60 dBA services used for habitation)

Class B (Commercial) 57 dBA 60 dBA 65 dBA

Class C (Storage, industrial, and agricultural) 60 dBA 65 dBA 70 dBA

Table 2-15. City of Seattle Maximum Permissible Environmental Sound Levels

Land Use of Receiving Property

Land Use of Noise Source Residential Commercial Industrial

Rural 52 dBA 55 dBA 57 dBA

Residential 55 dBA 57 dBA 60 dBA

Commercial 57 dBA 60 dBA 65 dBA

Industrial 60 dBA 65 dBA 70 dBA

Source: SMC 25.08.410

There are various common sources of tonal noise including rotating mechanical equipment (fans, pumps, chillers, etc.) as well as electrical equipment (motors, transformers, lighting dimmers) as indicated in Table 2-17. The most common source of tonal sound in construction is vehicle back-up alarms, which have been reported to total over 40 percent of nighttime construction complaints. Tonal noise refers to pitch, which is analogous to a musical note. Most noise encountered is broadband noise from a variety of sources ranging from wind to road noise. Broadband noise contains many different frequencies but it does not have the character of pitch. Tonal noise is a perception issue because humans are adept at selectively hearing tones, even when immersed in broadband noise of fairly high levels. Because tones demand our attention, they tend to be more annoying than broadband sounds, especially when they are part of unwanted sound (FHWA 2008). Distance from the noise source is a primary consideration in assessing noise impacts. The noise levels perceived by a listener generally decrease by 3 to 6 dBA when the distance is doubled, depending on factors such as topography, ground cover, and vegetation (Bies and Hansen 2003). A sound level that is 85 dBA at 50 feet will decrease to between 79 and 82 dBA at 100 feet and to between 73 and 79 dBA at 200 feet.

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Table 2-16. Noise Associated with Common Construction Equipment

Equipment Description Impact Device? Lmax at 50 feet (dBA, slow) Backhoe No 80 Chain Saw No 85 Compactor (ground) No 80 Compressor (air) No 80 Concrete Mixer Truck No 85 Concrete Pump Truck No 82 Concrete Saw No 90 Crane No 85 Dozer No 85 Dump Truck No 84 Excavator No 85 Front End Loader No 80 Generator No 82 Grader No 85 Impact Pile Driver Yes 95 Vibratory Pile Driver No 85 Jackhammer Yes 85 Mounted Impact Hammer (hoe ram) Yes 90 Pneumatic Tools No 85 Poker Vibrator No 84 Compressed Air Blower No 104 Power Saw No 88 Electric Drill No 83 Air Track Drill No 113 Impact Wrench No 88 Welder/Torch No 73 Source: FHWA. 2010. Construction Noise Handbook. Table 9.1 Equipment Type Inventory and Related Emission Levels. Accessed at: http://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/handbook09.cfm. CDC 2014 Center for Disease Control NIOSH Noise Meter http://www.cdc.gov/niosh/topics/noise/noisemeter_html/hp103.htm

Sensitive receivers are generally considered uses that are used for purposes sensitive to noise and requires protection. Examples of noise sensitive receivers are residences, hotels and hostels, educational institutions and hospitals and clinics. In most cases, sensitivity has to do with noise levels that interfere with communication and concentration, such as in schools, interfere with sleep and normal enjoyment of domestic quiet, such as residences. Hospitals and clinics are generally subject to disruption in all these functions. Sensitive receptors in the vicinity of the site include mostly residences and hotels. The Fairmont Olympic Hotel is directly south of the site across University Street. The Cobb building residences are across Fourth Avenue to the west. Other hotels in the vicinity include the Motif on Fifth Avenue between Pike and Union Streets, the Inn at the Washington Athletic Club at Sixth and Union, the Hilton at Sixth Avenue and University Street, the W at Fourth and Seneca, the Crown Plaza at Sixth and Seneca Street and many others. Most of these hotels are potential recipients of traffic

2-110 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum noise from truck hauling but generally are too far from the site to experience adverse construction noise. Pedestrians on sidewalks adjacent to the site are generally not considered a sensitive use, but since they can be closer than 50 feet to the source of noise, they may be subject to higher noise levels than indicated on Table 2-7 and may experience auditory impacts.

Noise Impacts of Each Phase of Construction The increase in sound levels and vibration would depend upon the type of equipment being used, the duration of such use, and the proximity of the equipment to sensitive land uses. Sound levels within 50 feet of construction equipment often exceed the levels typically recommended The work performed in each phase of construction, the typical practices and equipment used, and the associated noise levels are described below. In assessing construction noise from this project, the projected noise from scheduled activities at the adjacent Sound Transit light rail construction site were considered in the resulting impacts. Major phases of the project and activities that are substantial generators of noise are described below.

Phase I Mobilization Most activities in this phase have relatively low levels of noise and likely would not be noticeable outside the construction site.

Phase II Demolition Noise from demolition typically includes heavy machinery such as backhoes equipped with sears and other devices. Much of the demolition noise comes from pneumatic impact tools demolishing concrete or from portions of buildings collapsing. Most potential receivers would be on the opposite side of the street, due to sidewalk closures. Persons accessing the existing Rainier Tower, however could be within 50 feet of demolition of the nearest portions of the existing shopping center.

Phase II Excavation Excavation for underground parking is likely to involve a variety of equipment on-site such as backhoe, dozers, heavy trucks, and other equipment with peak noise levels between 80 and 90 dBA. Most potential receivers would be on the opposite side of the street, due to sidewalk closures. To the extent that sidewalks are open during this phase, it is likely to be after initial excavation when excavation is 30 or more feet below the surface and the wall of the excavation would provide a barrier to immediately adjacent receivers. Persons accessing the existing Rainier Tower, however could be within 50 feet of excavation of the nearest portions of the site.

Phase III Building Structure Noise sources are typically from tools such as impact wrenches and hammers that are not continuous, but can result in high piercing sounds for several minutes at a time. Equipment use to place and compact concrete and are typically in the 80 to 90 dbA range. Most potential receivers would be on

Rainier Square Development 2-111 University of Washington Metropolitan Tract Environmental Impact Statement Addendum the opposite side of the street in initial stages due to sidewalk closures. After completion of the base structure due sidewalk are likely to be open, or pedestrian enclosures provided. For construction above the fourth floor, distance to receivers will generally be more than 50 feet and shielded to some extent by floors. Persons accessing the existing Rainier Tower, however could be within 50 feet of construction of nearest portions of the site.

Phase IV Internal Construction Noise impacts are typically from portable tools such as saws. The extent of noise disturbance is substantially influenced by whether building facades have been installed, which intercept much of the noise. After completion of the base structure due sidewalk are likely to be open, or pedestrian enclosures provided. For construction above the fourth floor, distance to receivers will generally be more than 50 feet and shielded to some extent by floors and walls. Persons accessing the existing Rainier Tower, however could be within 50 feet of internal construction of nearest portions of the site.

Phase V Street and Sidewalk Improvement and Landscaping Noise sources for sidewalk improvement and landscaping are typically related to concrete placement and compaction and from equipment such as backhoes. Areas where construction is taking place are likely to be closed unless pedestrian shelters are provided. Noise impacts from on-site activities on nearby sensitive receivers would have the greatest impacts on Fairmont Olympic Hotel directly south of the site and the residences in the Cobb building to the west. Vehicle noise will be produced by trucks entering and leaving the site. Truck traffic will produce noise impacts on uses adjacent to existing roadways. The greatest volume of truck traffic is for hauling material off-site during excavation for underground parking. Routes with steep up-gradient roadways are especially prone to noise impacts since trucks produce substantially higher noise level when travelling uphill, particularly from a stop. Excavated materials are often removed from a downtown site during off-peak daytime hours between 10 am and 3 pm and nighttime hours after 7 pm to avoid peak traffic at commute times. The choice of routes for hauling also should take into consideration avoiding sensitive receivers during night-time sleeping hours such as the Fairmont Olympic Hotel south of the site, the Cobb Building residences west of the site, the xx hotel on Fifth Avenue, the xx hotel on Fourth Avenue at xx Street. There are no open-space areas in the vicinity likely to be adversely impacted.

Noise Mitigation Measures Construction noise impacts on the most sensitive uses, such as sleeping will be mitigated by the noise hours specified in the Seattle Noise Ordinance. If variances for night work are proposed, specific measures will be reviewed for mitigating impacts, such as limiting work to the portions of the site furthest from sensitive receptors such as the Olympic Hotel. Construction noise is generally mitigated in one of four ways (FHWA 2010):  Use of alternative construction practices and machinery;

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 Mitigation at the source, through screening or other means of reducing noise caused by operations or machinery;  Mitigation along the path, generally through barriers; and  Mitigation at the receiver through retrofitting building components. Construction practices that may be used at the site to reduce noise include:

 Use of the quietest practical type of equipment where alternatives are available.  Whenever appropriate, substitute hydraulic impact tools with electric models to further reduce demolition and construction-related noise and vibration.  Provide properly-sized and maintained mufflers, engine intake silencers, and where necessary engine enclosures on operating equipment.  Turn-off idling equipment.  Use alternative devices instead of tonal backup beepers on vehicles, especially at night, to reduce the intrusiveness of tonal noise. For instance, broadband backup alarms are effective at about 5 dBA less than a conventional tonal alarm and are less likely to be perceived outside of the construction area. They have the additional advantages of allowing identification of the specific source more readily (Alali and Casali 2011).  Limit most construction to standard construction hours between 7 am and 10 pm on weekdays and 9 am – 7 pm on Saturdays when potential receivers would be less likely to be disturbed.  Limit the use of the noisiest equipment, specifically impact-type equipment, such as pavement breakers, pile drivers, jackhammers, sand blasting tools and other impulse noise sources, to City of Seattle designated hours of 8 am to 5 pm on weekdays and 9 am and 5 pm on weekends.  If work is required outside of the standard hours, locate work areas on the portions of the site furthest from sensitive receivers such as the Fairmont Olympic Hotel.  To the extent possible, limit work outside of standard construction hours to less noisy activities.  Truck haul routes would be proposed by the applicant, and approved by the Seattle Dept. of Transportation (SDOT) and DPD. These routes should be designed to avoid sensitive receivers, particularly on up-gradient roadways where dump trucks and other heavy trucks are likely to be loudest.  Schedule several noisy operations concurrently to take advantage of the fact that the combined noise levels produced may not be significantly greater than the level produced if the operations were performed separately. Mitigation at the source involves strategies such as:

 Screening stationary equipment such as compressors;  Proper muffling of diesel- or gasoline-powered equipment, or use of electric-powered equipment where feasible, and use of alternatives to tonal alarms; and

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 Construction of on-site barriers around particularly noisy activities. This option is most applicable to the excavation phase when noise from activities at or below grade level can be effectively addressed by barriers.  Undertake noisy interior finishing work after the building façade has been installed on affected floors. Mitigation along the path of noise propagation through off-site barriers is of limited effectiveness for sensitive residential or hotel uses during sleeping hours because the upper floors will not be benefitted by barriers places at ground level. Mitigation at the receiver through retrofitting building components generally includes installing double- or triple-pane windows. Windows and other openings in walls are the most likely pathways for transmittal of noise to the interior of the buildings. In some cases, retrofitting also can include noise insulation in walls and ceilings depending on the levels experienced. It may be practical to arrange with Olympic Hotel management to reduce the use of rooms facing the construction site during the noisiest operations.

2.11.4 Addendum Information on Drainage

Drainage Affected Environment The site and vicinity is in a portion of the city served by a combined sewer/stormwater system. The policy and regulator concern in such areas relates to the capacity of the treatment system when runoff volumes are large due to intense rainfall, there may be “combined sewer overflows” (CSOs) of a mix of runoff and untreated sewage into surface waters. The City is considering various Long-term Control Plan (LTCP) Alternatives for the construction of storage and tunnel options to control CSOs. The plans anticipate that use of combined sewers will continue. (Seattle 2014d) This portion of the downtown is effectively at 100 percent impervious surfaces. The city’s Drainage Control Ordinance generally does not require areas discharging into combined sewers to control the volume of flows, but generally does require control of soils and other materials that may discharge into the system (SMC 22.800 - 22.808)

Impacts on Drainage Construction is not likely to impact the stormwater system except for discharge of rainwater collected on the site during construction or soils or other excavated materials tracked onto streets that may discharge to catch basins.

Mitigation Measures for Drainage The City requires submittal of a Construction Stormwater Control Plan or checklist that addresses discharge of materials into the combined system. Of greatest concern for a developed site such as this is during the excavation stage and includes sediment removal through a sediment trap, sediment pond, or other appropriate sediment removal BMP, and preventing the transport of sediment onto

2-114 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum roads through wheel washers and may include street washing and prevention of sediment from entering storm drains through inlets protection devices (SMC 22.805.020).

2.11.5 Addendum Information on Pedestrian Circulation

Pedestrian Circulation Affected Environment The site is currently served by perimeter sidewalks and the downtown underground pedestrian concourse that extends in an east-west direction through the site and connects to the Hilton Hotel to the east and the Puget Sound Building to the west. (Seattle 1976)

Impacts on Pedestrian Circulation Construction areas typically separate pedestrians from the potential hazards of construction. Options range from complete pedestrian closure to full protected access such as covered walkways to maintain access. Pedestrian access during construction is regulated Traffic Control Manual and the Right-of-Way Improvements Manual. The removal of a pedestrian routes on the perimeter of the site and closure of the underground pedestrian concourse would displace pedestrians to the opposite sides of adjacent streets. Pedestrians may experience increased travel time for walking making it a less convenient mode of transportation.

Mitigation Measures for Pedestrian Circulation The city requires a construction phase transportation plan which addresses safe pedestrian circulation in the vicinity of the construction site. The extent of pedestrian access may vary during different phases of construction.

2.11.6 Addendum Information on Construction Impacts on Transportation

Transportation Affected Environment Discussion of existing transportation conditions is found in Section 2.9.2 Addendum Information on Affected Environment

Construction Impacts on Transportation Construction of the development would include the following activities and durations:  Demolition, shoring, excavation – 6 months  Building structure and enclosure – 20 months  Residential, retail and office build-out – 6 months Construction activities may result in periodic lane and sidewalk closures. Haul routes will access the primary arterial system between the site and I-5.

Rainier Square Development 2-115 University of Washington Metropolitan Tract Environmental Impact Statement Addendum

The limitations on construction activities and obligations of the owner are documented in the City code. In addition, a Construction Management Plan would be completed, as discussed in Section 5.1.

Mitigation Measures for Construction Impacts on Transportation The Contractor should prepare a Construction Management Plan that documents the following:  Truck haul routes (to and from the site)  Peak hour restrictions for construction truck traffic  Communication and Enforcement of restrictions  Truck staging areas  Construction employee parking areas  Measure to reduce construction employee trips  Lane, sidewalk, or bike lane closures required  Temporary traffic control, channelization, and signalization measures for all closures  Impacts to King County Metro stops  Other details, as required by City of Seattle, to obtain street use permit

2-116 Rainier Square Development University of Washington Metropolitan Tract Environmental Impact Statement Addendum

3 REFERENCES

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Flom, Eric L. and John Caldbick, 2012 5th Avenue Theatre (Seattle) HistoryLink.org Essay 3750 : Available on the internet at http://www.historylink.org/index.cfm?DisplayPage=output.cfm&file_id=3750

Herrington, Lee P.; Vittum, J. S. 1977 Human thermal comfort in urban outdoor spaces In: Heisler, Gordon M.; Herrington, Lee P., eds. Proceedings of the conference on metropolitan physical environment; Gen. Tech. Rep. NE-25. Upper Darby, PA: U.S. Department of Agriculture, Forest Service, Northeastern Forest Experiment Station. 130-138 http://www.nrs.fs.fed.us/pubs/gtr/gtr_ne25/gtr_ne25_130.pdf Lentz, Florence . 1978. National Register of Historic Places Inventory, Nomination Form, Skinner Building, September 18, 1978 Available on the Internet at: Honjo, Tsuyoshi 2009. Thermal Comfort in Outdoor Environment. Available on the Internet at: www.researchgate.net/...Thermal_Comfort.../0046351c1e7 King County. 2007. Climate Change and Development Regulations. King County Department of Development and Environmental Services. Regulations available at: http://www.kingcounty.gov/property/permits/info/SiteSpecific/ClimateChange.aspx. King County 2012, King County Comprehensive Plan, Countywide Planning Policies, Appendix D, Growth Targets and the Urban Growth Area, March 2012 Available on the Internet at http://your.kingcounty.gov/mkcc/compplan/2012/AttachmentF.pdf

King County Assessor 2014 King County Parcel Viewer. Available on the Internet at:http://www.kingcounty.gov/operations/GIS/PropResearch/ParcelViewer.aspx Accessed February Kezmis, Kathleen. 2009. 1411 4th Avenue Building (Seattle). History Link, the Online Encyclopedia of Washington State History. Available on the internet at http://www.historylink.org/index.cfm?DisplayPage=output.cfm&file_id=9000 Kreisman, Lawrence. 2005 Mountain Magic, Seattle architect honors the adventurous spirit. Pacific Northwest Magazine, February 29, 2004 Available on the internet at http://seattletimes.com/pacificnw/2004/0229/living.html

Mace, Douglas, et. Al. 2001. Countermeasures for Reducing the Effects of Headlight Glare. Prepared for the AAA Foundation for Traffic Safety. December 2001. Available on the Internet at https://www.aaafoundation.org/sites/default/files/HeadlightGlare.pdf Niedzielski, Rebecca A. 1991. Environmental Impulse Noise Study Final Report. Minnesota Pollution Control Agency. May 1991. Available at: http://www.nonoise.org/library/impulse/impulse.htm.

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O’Flaherty, Coleman. 1996. Chapter 23 Road Lighting in Transport Planning and Traffic Engineering. CRC Press. Available on the Internet at: http://books.google.com/books?id=EAczDTp7ESQC&pg=PA443&lpg=PA443&dq=20+degrees+gl are&source=bl&ots=FsMn1WlGam&sig=knPoKYyrPl0vBT87AewaK_FYXBk&hl=en&sa=X&ei=2blTV J6uJ4L2igKIuoDADA&ved=0CCsQ6AEwAg#v=onepage&q=20%20degrees%20glare&f=false

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APPENDIX A

Distribution List

This Addendume is circulated in accordance with WAC 197-11-630(3)(a) and SMC 25.05.625 WAC 197-11-630(3)(a): (i) The agency shall send copies of the adoption notice to the department of ecology, to agencies with jurisdiction, to cities/counties in which the proposal will be implemented, and to local agencies or political subdivisions whose public services would be changed as a result of implementation of the proposal. (ii) The agency is encouraged to send the adoption notice to persons or organizations that have expressed an interest in the proposal or are known by the agency to have an interest in the type of proposal being considered, or the lead agency should announce the adoption in agency newsletters or through other means. (iii) No action shall be taken on the proposal until seven days after the statement of adoption has been issued. The date of issuance shall be the date the statement of adoption has been sent to the department of ecology and other agencies and is publicly available. SMC 25.05.625 Addenda—Procedures. A. An addendum shall clearly identify the proposal for which it is written and the environmental document it adds to or modifies. B. An agency is not required to prepare a draft addendum. C. An addendum for a DEIS shall be circulated to recipients of the initial DEIS under Section 25.05.455 D. If an addendum to a final EIS is prepared prior to any agency decision on a proposal, the addendum shall be circulated to the recipients of the final EIS. E. Agencies shall circulate notice of addendum availability to interested persons. Unless otherwise provided in these rules, however, agencies are not required to circulate an addendum. F. Any person, affected tribe, or agency may submit comments to the lead agency within fifteen (15) days of the date of issuance of an addendum.

Environmental Impact Statement Addendum

APPENDIX A – DISTRIBUTION LIST

Federal Agencies U.S. Environmental Protection Agency U.S. Army Corps of Engineers U.S. Fish & Wildlife Service, Pacific Region Field Office U.S. Department of Housing & Urban Development State Agencies Washington State Department of Ecology Washington State Department of Community Development Washington State Department of Transportation Washington State Department of Fish & Wildlife Washington State Department of Social & Health Services Washington State Department of Natural Resources Washington State Office of Archaeology and Historic Preservation Regional Agencies King County Metro Transit King County Department of Transportation King County Office of Regional Policy and Planning King County Executive King County Department of Assessments King County Department of Design and Environmental Services King County Housing and Community Development Port of Seattle Puget Sound Clean Air Agency Puget Sound Regional Council Sound Transit Seattle-King County Housing Authority Public Facility District Public Stadium Authority

Fifth and Union Development A-1 University of Washington Metropolitan Tract Environmental Impact Statement Addendum

Seattle School District City Departments Fire, Police, Neighborhoods Department of Transportation Human Services, Parks Seattle Public Utilities Seattle Public Library Office of Housing City Light Public Libraries Planning Commission City Council Tribes Muckleshoot Suquamish Duwamish United Indians of All Tribes Tulalip Organizations Downtown Seattle Association

The following Appendixes are provided in a separate dsocument APPENDIX B Pedestrian Le vel Wind Analysis APPENDIX C Transportation Impact Study APPENDIX D Greenhouse Gas Emissions Calculation Spreadsheet

A-2 Fifth and Union Development University of Washington Metropolitan Tract