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Government Entities April 2019 Government Entities AE 0036-17 List of Government Entity, Business and Business Organization, and Community Organization Commenters DRAFT – For internal discussion only. Not reviewed or approved on behalf of any party. ~I~ City of Seattle April 2, 2019 Lauren Swift Central Corri~or Environmental Manager 401 S Jackson St Seattle, WA 98104 Dear Ms. Swift, Thank you for the invitation to participate as a Cooperating Agency and the opportunity to provide scoping comments for the environmental process for the Sound Transit West Seattle and Ballard Link Extensions (WSBLE) Project. This letter details the comments and concerns of City of Seattle staff as you determine actions, alternatives, and impacts to be evaluated in the Draft Environmental Impact Statement (DE IS). The City appreciates the ambitious scope and time lines for this project and continues to be committed to helping Sound Transit deliver this project on schedule. The detail in the City scoping letter is provided to state our support for the WSLBE project moving forward and to flag key issues that the DEIS needs to cover, in order to help Sound Transit avoid delays or additional environmental review. In addition to the specific comments attached in the Technical Memo, the following reflect fundamental areas of specific importance. Alternatives Development The City commends Sound Transit for the extensive planning and public engagement activities that have informed the alternatives development phase of the project. This advancement of technical work and engagement successfully narrowed the range of potential DEIS alternatives from hundreds down to a few and built agreement in most project segments for what impacts and refinements should be studied. The resulting Level3 Alternatives should both be advanced for further study in the DEIS. However, as the DEIS further refines these alternatives, Sound Transit must ensure enough flexibility to fully bracket the range of potential environmental impacts and allow for decision-makers to assemble a final alignment that combines the most promising individual segment option(s). The environmental process will need to accurately show the tradeoffs of different station configurations throughout the line. That will help identify options to avoid and/or minimize disruptive impacts for future alignments decisions. The City would like to see additional study, problem solving, and refinements in the West Seattle, Chinatown}lnternational District, SODO, and mid-town segments. In contrast, Sound Transit should feel confident that the final alignment selected in Ballard, lnterbay1 Uptown, and South Lake Union will be within the range of possibilities represented by the two Level 3 alternatives. Equity and Mitigation The segments in the Chinatown/International District and West Seattle include the highest concentrations of communities of color along the project corridor, and as highlighted in the project's Radal Equity Toolkit, should include consideration in the DE IS as follows: 1 • The Chinatown/International District is a unique hub of cultural importance for the city and its Asian American communities. Historically, the C/ID has endured a disproportionate share of impacts from infrastructure projects, from the Second Avenue Extension in the 1920s to the building of 1-5 in the 1960s, Kingdome construction in the 1970s, the Downtown Seattle Transit Tunnel in the late 1980s, and the Seattle Streetcar in the 2010s. Now, as Sound Transit prepares to evaluate alternatives for a new light rail station in this community, the C/ID alignment and station location appear to be the single area of the project with the greatest remaining challenges to resolve. The environmental process will need to study and accurately show the tradeoffs of different station configurations in the neighborhood and to identify options to avoid and/or minimize disruptive impacts. If impacts cannot be avoided or minimized there must be adequate mitigation to offset both short-term construction and tong-term impacts. • The Del ridge station area is also a focus of racial equity due to the communities of color and low-income residents along the transit corridor expected to access the proposed Del ridge and Avalon stations via bus. These include the High Point, South Delridge, Highland Park, and White Center neighborhoods and South Seattle College. The environmental phase must evaluate enough design options to ensure seamless bus/rail connections at Delridge and Avalon Stations, recognize the importance of this regional intermodal transit hub, and identify impacts to the surrounding neighborhoods that might need mitigation if those impacts cannot be minimized. Transit Operations The WSBLE project proposes critical new transit connections that will serve hundreds of thousands of riders each day. We encourage Sound Transit to ensure that the project results in efficient, safe transportation operations and intermodal connections to bus and rail throughout the full length of the corridor that maximizes the project benefits. In-depth and robust traffic analysis for vehicles, freight, pedestrians and bicycles will also be needed. Consistency with City Plans. Policies. and Regulations As detailed in the attached memo, Sound Transit's environmental review process should ensure that the project alternatives being analyzed are consistent with city policy, plans and regulations and if not; to document variances and inconsistencies. In addition, Sound Transit should ensure that the DE IS fully discloses construction and long-term impacts and identifies creative solutions to minimize those impacts or appropriate mitigation. Sound Transit should ensure that the DE IS comprehensively evaluates the potential for business and residential displacements and relocations. Finally, as the City's role in future permitting and SEPA actions, we stand ready to assist Sound Transit in the environmental process to meet those future rigorous requirements. Comments on Purpose and Need The City would also like to offer the following comments on the project Purpose and Need. The City of Seattle offers the following italicized modifications: • Improve regional mobility by increasing connectivity and capacity through downtown Seattle and the Center City to meet projected transit demand. 4/2/19 2 WSBLE EIS Scoping • Implement a system that balances local impacts with benefits and is technically and financially feasible to build, operate, and maintain. • Expand mobility and safety for multiple modes and users, including freight bicyclists, pedestrians, those with limited mobWty, and all ages and maximize ridership for the corridor and region's residents, which include transit-dependent, low-income, and minority populations. • Encourage equitable and sustainable urban growth in station areas through support of transit­ oriented development, affordable housing, and multimodal integration in a manner that is consistent with local land use plans and policies, including Sound Transit's Transit Oriented Development and Sustainability policies. Make equitable investments in project services and benefits to historically underserved communities along the alignment, especially people of color and low-income populations. This project is the lynch pin for future mobility both within the City of Seattle and also for t he Central Puget Sound Region. The connections that converge in downtown Seattle among the three Link lines and the regional transportation network will facilitate t ravel not just for the light rail extensions to West Seattle and Ballard, but for extensions to Tacoma, Redmond, and Everett as well. The future ofthe City of Seattle and the region's transportation system is therefore dependent on the success of Sound Transit and the continued build-out of the rail system. This DE IS will help chart the course for success. We appreciate the opportunity to partner with Sound Transit on this crucial project. Thank you for the opportunity to comment and we look forward to continuing to cooperate on this project Sincerely, ~:h- ' Sam Zimbabwe Director, Seattle Department of Transportation cc: Shefali Ranganathan, City of Seattle Deputy Mayor 4/2/19 3 WSBLE EIS Scoping TECHNICAL ISSUES MEMO (in alphabetical order) Attachment to Seattle Department of Transportation's Scoping Comments for Sound Transit West Seattle Ballard Link Extensions DEIS ISSUE: Acquisitions, Displacements, and Relocations The DEIS should evaluate potential impacts to the following: • Potential physical, economic, and cultural displacement of residents and businesses, as well as potential racial disparities in displacement outcomes, through the following lenses: o. anticipated net physical displacement due to direct site acquisitions and redevelopment o. anticipated economic displacement from rent and property tax increases1 based on market trends and historical housing and land price changes in similar station areas,. Economic displacement occurs when a household is compelled to relocate due to the economic pressures of increased housing costs or other costs of living. o. anticipated cultural displacement, based on any anticipated physical or economic displacement of cultural anchors, community-serving and culturally relevant businesses, and community members that could reduce a sense of belonging for the existing community overall. Detailed analysis will be particularly important at the Chinatown/International District and Delridge Station sites. Sound Transit should identify the anticipated "non­ acquisition development outcome"
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