TO: Lake Forest Park Planning Department

FROM:Lake Forest Park Stewardship Foundation

DATE:January 27, 2003

SUBJ:Comprehensive Plan Update

The Lake Forest Park Stewardship Foundation would like to take this opportunity to comment on the pending update of the City's Comprehensive Plan. These comments are based mainly upon the Comprehensive Plan Draft ("CPD") dated November 15, 2002.

The Focus On the Proposed Land Use Alternatives

The Foundation's greatest concern, by far, at this point is the apparent focus on the part of the City on the portion of the CPD devoted to proposed Land Use Alternatives, described on page 22 of the CPD. Recent notices provided by the City regarding the public hearings on the Comp Plan (e.g., Public Notice, Jan. 10, 2003; Town Crier, Jan., 2003) appear to inform the citizens of LFP that the primary open issue which is being investigated by the Planning Commission at this time is in fact the selection of one of the proposed Land Use Alternatives.

The Foundation has the following concerns on the matter of focussing public discussion on the issue of the proposed Land Use Alternatives:

• After two years of diligent work by the Planning Commission in assembling the CPD, the sum total of the text in the CPD relating to the proposed Land Use Alternatives is one paragraph (page 22). This is significant because:
  • Clearly, this issue has not been the Planning Commission's primary focus - or even a major focus - during their two years of work on this document. The CPD comprises 146 pages. The discussion of the proposed Land Use Alternatives consists of less than one half of one page (p. 22) plus one hand-drawn map (Map 4, Attachment C). The contents of the other 145 pages of the CPD are not mentioned in the public notices describing the issues to be decided based on public hearings and comment letters. Thus, there appears to be a serious discrepancy between what the Planning Commission has intended, and what the City is presenting as the (very short) list of open issues currently being discussed.

  • The Foundation strongly believes that the proposed Land Use Alternatives (other than the default of "No Action") will have a significant impact on the following:
  1. The residents of the City - in particular, the residents of the neighborhoods which will be directly affected by the land use changes;
  2. Local businesses in Towne Center, if the zoning and/or extent of Towne Center changes; and
  3. Lyon Creek and its associated riparian habitat, if the extent of Towne Center changes.

  Given these impacts, providing exactly one paragraph (plus one hand-drawn map) dedicated to describing the proposed Land Use Alternatives is woefully inadequate in terms of evaluation of the alternatives. Neither the citizens of LFP, nor the members of the Planning Commission, nor City Council, could ever be expected to reach a decision on such a critical matter on the basis of such sketchy input. This issue will be discussed in more detail below.

• The residents of the neighborhood directly adjoining the land which is being considered for rezoning (i.e., the neighborhood directly west of Towne Center) have not been directly contacted about this matter. In fact, very few residents of the neighborhood directly to the west of Towne Center had heard anything about the proposed Land Use changes as of a week before the December hearing. (The Foundation has determined this from first hand reports from citizens in this neighborhood.) Given that at least one of the proposed changes will certainly have a significant impact on these residents, the Foundation believes that each of these residents should have been contacted by mail directly, specifically on the matter of potential rezoning of their neighborhood. This applies both to residents directly within the possible rezoned area as well as other neighbors in the vicinity, similar to the practice of notifying land owners within 300 feet of proposed project sites (per LFPMC 16.26.040).

  The Foundation strongly believes that the consideration of such a significant change to City zoning, without direct contact with the residents who will be most affected, is a serious error, even at this "Draft" stage of the Comp Plan update. It demonstrates a fundamental lack of consideration for, and understanding of, the residents of this City. While this lack of notification may in fact be within the letter of the law regarding such things, it is clearly in violation of the spirit of LFP's long tradition of strong community involvement in City affairs. On a practical level, it appears that the lack of direct contact with citizens who will be affected by this proposed change has been counterproductive for both City Staff and for citizens, due to the confusion and concern over events which have not been explained and which may or may not occur.

• The Foundation believes that a decision involving the possible rezoning of Towne Center and/or its surrounding neighborhood may not in fact be a decision which should be made in the context of the Comprehensive Plan Update at all. This is a zoning issue, a very significant one. Turning the discussion on the CPD into a debate on the merits of various specific rezoning options deflects attention away from a myriad of other issues addressed in the Comp Plan, and it results in the public discussion on the CPD descending into a potentially highly emotional debate in which residents and business owners focus on this one issue to the exclusion of the rest of the Comp Plan.

  Instead, the Foundation proposes - if this is technically and legally feasible - that the issue of the Proposed Land Use Alternatives be addressed briefly in the Comp Plan, with the explicit explanation - both in the Comp Plan itself, and in public notices regarding public hearings on the plan, and in such public hearings themselves - that the Comp Plan process does not involve solving this problem, and does not involve selecting one of these proposed Land Use Alternatives. If this separation of the discussion of the Comp Plan as a whole and the discussion of the proposed Land Use alternatives is technically or legally impossible, then the Foundation believes that it is imperative that the Comp Plan Update process be immediately amended to include detailed study and discussion of the proposed Land Use Alternatives. The treatment of such study and discussion (whether as part of the Comp Plan discussion, or as a separate issue) follows.

The Presentation of the Proposed Land Use Alternatives

As mentioned above, the Foundation believes that the existence of one paragraph of text and one hand-drawn map is an utterly inadequate basis for public discussion of such a crucial issue. Given the impact that this decision will have on the residents of the City, on business owners in the City (particularly those currently operating in Towne Center), and on the Lyon Creek corridor, the following is a list of issues which should be studied and information which should be provided to the public before such a discussion (or debate) even commences.

1. How were the boundaries shown in Map 4 arrived at? This map was not the same map as provided by the Economic Development Commission when they proposed a possible expansion of Towne Center. Why expand west of 44^th Ave. NE? Why not expand north to 178^th Street? This map appears to reasonably educated eyes to be arbitrary, with no rhyme nor reason as to the selection of its boundaries. The citizens of LFP are intelligent enough to deal with detailed explanations of such decisions or proposals. And, more importantly, they deserve them.
2. What will the impact be on the owners of houses which are currently in and around the area which may be rezoned to allow high density residential and/or commercial development? What will be the impact on their property values? Surely this must be taken into account when discussing such a significant change. What will be the impact on their lives during construction? What will be the impact on the traffic in their streets?
3. What will be the impact on the businesses currently operating in Towne Center? Will some have to relocate, either temporarily or permanently, as a result of potentially massive and disruptive construction?
4. What will be the impact on Lyon Creek, which flows directly through the proposed Urban Village? It has been well established that development near streams can have adverse affects on water quality and on the wildlife which depends on the streams. Such matters as streamside buffers, potential restoration of the stream corridor as part of mitigation by developers, the type of material used for parking lots, and landscaping all need to be studied. We recommend that any proposal in the Comp Plan in which Towne Center is be expanded (either in terms of physical boundaries or intensity of use) contain a discussion about the sensitivity of Lyon Creek, and that such a proposal indicate that preserving and enhancing the Lyon Creek corridor, in and around the Towne Center area, be a high priority when the associated development occurs.
5. What will be the financial impact on the City of the proposed rezoning and (presumed) subsequent development? Will additional services (transportation, public safety, etc.) be needed? Will the City's tax revenues increase? If so, by how much? These financial questions actually need to be asked of all four of the proposed alternatives, and the results - hard data - made available to all.

When such information is available, we recommend that the City hold one or more public meetings, similar to the meetings which were held in February 2001 at the start of this Comp Plan Update process, at which this information can be provided (and thoroughly explained) to interested citizens. Those initial meetings, in 2001, were well attended and were (and are) widely seen as a great example of the City's tradition of community involvement in LFP affairs. Since those meetings, there have been no presentations open to the public by either the Planning Commission or by City staff which provided a means for citizens to actually ask questions and learn about the ongoing Comp Plan update. Public hearings in which citizens can speak for a few minutes but can not actually interact with Staff and get their questions answered are not really enough. Interactive and informative meetings are, we believe, crucial to the decision making process involved in such an important step as rezoning or expanding the Towne Center area.

Other Concerns With the Land Use Component of the Comprehensive Plan

1. Another concern about the presentation of the proposed Land Use Alternatives is that of the justification for their existence. This section, on page 22, begins:

   Since residential land is the most pressing land use need for Lake Forest Park, the plan includes three land use alternatives for Lake Forest Park to consider based upon its future residential needs.

   Yet page 30 of the CPD makes this statement:

   The City currently has the available land capacity to achieve its assigned housing target allocations.

   This statement is in the context of meeting the target specified in the King County Growth Management Planning Council; this number is 523 units by 2022. The CPD indicates that this target can be met with existing zoning (i.e., with existing residential land).

   If it is in fact the case that existing residential land use classifications already provides the targets we seek to meet through the year 2022, how can the concept that "residential land is the most pressing land use need for Lake Forest Park" be justified as the reason for adding high density housing to an existing single-family residential neighborhood? This discrepancy in the CPD is very troubling to the Foundation. If there are in fact other reasons underlying the proposed changes to the zoning in and around Towne Center, that may be fine - if the City is forthcoming about those reasons. The reasons stated in the CPD are not sufficient.

2. Similarly, the section on Land Use appears to assign undue emphasis on providing for additional housing units in LFP over the next twenty years. In fact it states on page 22:

   The goals and policies of the plan are designed to establish appropriate development patterns to manage land use and to ensure future housing needs are met.

   That may be the intent of this particular section - the Land Use section - but that is certainly not the intent of the entire Comp Plan. The sections on Environmental Quality, on Economic Development, Human Services, and Recreation and Open Space are certainly not at the service of ensuring that "future housing needs are met", yet they are crucial to the Comp Plan as a whole.

   The Comp Plan in its entirety is a Vision Statement of what the citizens of LFP want their city to be, in all respects. Implying that the prime focus of the Plan is on meeting future housing needs is, in the Foundation's opinion, a mistake. We recommend changing the sentence quoted above, from page 22, to indicate the intent of that particular section of the Comp Plan rather than that of the Comp Plan as a whole.

3. Apparently there has been a change in zoning in the Future Land Use Map (Map 3, attachment B) involving the RS-15 and RS-20 areas. This change is discussed in an accompanying document entitled "2003 COMPREHENSIVE PLAN UPDATE" (which lists a summary of the changes between the last version of the Comp Plan and the present Draft) but is not directly referred to in the text of the CPD proper. This accompanying document states, in part (bold emphasis added):

   The Puget Sound Growth Management Hearings Board has determined that four units per acre is an appropriate density for urban environments… Currently, the plan includes two land use designations that result in densities below four units per acre. These include the Single Family Residential, Low Density (RS-20) and Single Family Residential, Moderate Density (RS-15) land use classifications… Exceptions to this density standard apply when there are significant restrictions to development, such as …when a lower density would greatly further other objectives of the Growth Management Act, such as preservation of environmentally sensitive areas. The Single Family Residential, Low Density (RS-20) land use classification currently contains language that incorporates these restrictions and justifies the need for such a low-density land use classification. The draft plan includes similar language for the Single Family Residential, Moderate Density (RS-15) classification. Additionally, changes are included on the future land use map that will ensure that these two classifications are present only in areas where the exceptions would apply. All areas previously designated as Single Family Residential, Low Density (RS-20) and Single Family Residential, Moderate Density (RS-15) that do not meet the standards of these exceptions have been redesignated as Single Family Residential, Moderate/High Density (RS-10).

   However, referring to Page 44 of the CPD, in a discussion of Sensitive Area Mapping, see the following text:

   The City of Lake Forest Park currently has a series of maps that identify the approximate location of environmentally sensitive areas within the City. [...] These maps serve as reference tools by showing the general area of sensitive areas, however, they do not show exact boundaries of sensitive areas or include classifications (such as wetlands).

   This is troubling for two reasons. One reason is that the CPD itself makes no mention of the modifications to the zoning map; indeed, conversations with members of the Planning Commission have indicated that the Commission itself did not make these changes. Second, the CPD itself makes it clear that the City does not possess the knowledge of the exact boundaries of sensitive areas within the City; as indicated on page 44 of the CPD. What, then, is the justification for changing the zoning of these areas which are presumed not to contain sensitive areas? If the City's own sensitive area maps are known to be approximate - which they are, by the City's own admission - then using these maps as the basis for changes in zoning seems very ill advised at best.

   There is no legitimate justification for these zoning changes. The Foundation recommends that without detailed sensitive area studies on the land in question, no such zoning changes should be made.

The Housing Target Allocations

Much is made of the need for meeting specific housing targets (total residential growth target of 523 units for 2022, p.29). There are many aspects of this subject that are unclear at best. For instance, the King County Countywide Planning Polices document provides a range of housing targets for LFP of 473 to 540. How does one select the number 523 for the Comp Plan, given this range?

More importantly, some explanation is needed as to the ramifications of a City's meeting, not meeting, attempting to meet, or providing zoning which might enable a City to meet, these targets. What happens if the City's zoning provides capability to meet the targets (which the Draft clearly states, on page 30, that the current zoning is capable of) but does not actually have that many additional units in place in 20 years? What happens if a City declines to modify its zoning to meet the recommended targets?

Does Staff believe that the majority of citizens of LFP actually want to add 523 housing units to the City over the next 20 years? What if we don't add this many units? What are the consequences if we don't?

Our concern is that these target numbers - wherever they come from - are being presented to the citizens as hard and fast rules, with no possibility of being altered, and with no alternative but to actually ensure that 523 units are built by 2022. Is this actually, literally, the case? We believe that the citizens should be told, carefully and succinctly, what exactly the ramifications are of a City either failing to actually meet the specified targets, or of not modifying its land use policies to enable it to meet the targets. At that point, armed with this concrete information, we believe that it is up to the citizens of LFP to make an informed decision as to what priority is to be placed on meeting these targets.

Other parts of the Comprehensive Plan Draft

In our review of this document, the Foundation has focussed mainly on the overall structure, the process by which the update is being performed, and on two section of the CPD: the Land Use Section, and the Environmental Quality Section. Our concerns with the Land Use section are described above.

We believe that the section on Environmental Quality is superb. We have no changes to recommend for this section at this time.

Thank you for the opportunity to comment on the Comprehensive Plan Draft.

The Lake Forest Park Stewardship Foundation