Seattle’s Industrial and Maritime Strategy DEIS

Public Comments

3/2/2022

Thank you for the opportunity to comment on the Draft Environmental Impact Statement (EIS) for Seattle’s Industrial and Maritime Strategy.

Share The Cities would like to specifically appreciate the work of Ray Dubicki who has offered extensive volunteer support for our work to understand and respond to the DEIS. 

We want to emphasize our support for engagement events and materials for non-English speaking residents brought to our attention by Duwamish River Community Coalition. 

Please amend the Draft Environmental Impact Statement to address the following issues:

• Engage communities to more clearly explain the purpose of this EIS, the difference between the proposed zones and the Alternatives, and the legislative steps yet to come; (See below for expanded thoughts on this) 

• Address small business displacement fears since much of the environmental improvements expected under these new zones are reliant on new construction whose rents may be out of reach for tenant businesses

• Emphasize a greater partnership with Indigenous communities and Indigenous sovereignty 

• Present a clear path to support daily air monitoring in Ballard - Interbay

• Prioritize dramatic visual cues in built environment to get people who are driving vehicles to slow down on major arterials and urban freeways, like 15th Avenue NW

• Address the power and values imbalance caused by freight lobby’s political pressure, which causes an overemphasis on planning for freight travel in our city.

• Highlight the unique importance of Ballard-Interbay as a freshwater harbor which allows shipping fleets less destructive port environment for docking and repair of their ships

• Highlight BNSF’s historic and continuing lack of transparency and accountability 

• Clarify which existing and proposed uses in the industrial areas will be considered nonconforming under the MML, II, and UI zones; Provide a comprehensive list of uses with active exemptions or that operate under amended development standards. (i.e. Storm practice facility)

• Clarify the definition of “industry supportive housing,” provide examples from other locations of mixed use housing/industrial, and propose thresholds for mixed use buildings

• Develop a complete list of the neighborhood-level comprehensive plan recommendations in areas that will be impacted by these zoning changes, and analyze whether they conform or contradict the Draft Comprehensive Plan Goal and Policy Language found in Appendix D

• Specify which groups of zoning changes within each alternative should be treated as divisible or as a cluster/group and describe why. (i.e. what are the issues with splitting Ballard Brewery District between UI and MML?)

• Add documentation, analysis, and maps that connect Seattle’s historic segregation, redlining, and exclusion to the present day location of industrial uses. 

• Complete a city-wide analysis of zoning that looks specifically at the ways commercial and multi-family exclusions in other parts of the city lead to the competition for industrial land. Use maps of the entire city.

• Examine which recommendations and boundaries are carried over from older plans that have never been vetted for equity or impact, including transportation and public facilities.

We would also like to direct you and Seattle residents to examine the comments submitted by the following organizations: Duwamish River Community Coalition, Seattle Cruise Control, and the Georgetown/South Park Advisory Group. Each of their perspectives is valuable, since we have primarily focused on Ballard-Interbay. 

In these comments, we want to emphasize the importance of additional scrutiny regarding the impacts of the systemic racist policies that created Seattle’s industrial land and exacerbated the disparate impacts of pollution and disinvestment on nearby underserved neighborhoods of color.

The idea to rezone the city’s industrial lands is a good one. However, the impacts listed in the draft EIS are not addressed by the mitigations proposed. There is a disconnection between the greenhouse gasses, soil contamination, and water pollution created by the city’s industrial zones and their area of impact. That is because the underlying boundaries used to create the EIS study area and subareas are relics of inequities the EIS purports to address. The Environmental Impact Statement must struggle with the racialized history that formed our industrial areas in the first place.

I. Comments on the proposed zones.

Seattle’s existing industrial zoning designations are failing. The General Industrial zones are worded so broadly that grocery stores and mini-storage proliferate instead of employers who manufacture things. Car-intensive commercial uses are taking up space next to ports, rail, and vital infrastructure that cannot be moved or replaced.

The three proposed industrial zoning designations appear to recognize the changing needs of industry and its employment role. However, the actual text of the zones is not included in the document. These comments look to add information to the EIS in order to steer the creation of the zones during the legislative process.

1. Manufacturing, Maritime, and Logistics (MML) zone will replace most of the current general industrial zoning. As such, the EIS should be more explicit on which uses will become nonconforming uses. Not all commercial uses are unwelcome in industrial zones. Additionally, recent exceptions have been granted for developments such as the WNBA Storm practice facility. In lieu of extending an exemption and adding text to the hefty zoning ordinance, the code should be written to accommodate such uses. A comprehensive list of uses with active exemptions should appear in the EIS. 

2. The Urban Industrial (UI) zone will be established at the boundaries between industrial areas and urban villages. As discussed further below, Urban Villages are separated from waterways by industrial land. That would make some of the UI zoned properties the most desirable locations in the city for new homes, particularly penthouse units on top of a quasi-industrial space. This would accelerate issues of pricing out legacy industry in neighborhoods where that is already most acute. The EIS should be clearer on the definition of “industry supportive housing,” provide examples from other locations of housing on top of industry, and propose thresholds for mixed use buildings. 

3. Industrial Innovation (II) zones are for areas around transportation hubs where office and manufacturing can coexist with transit. We find this zone very exciting with mixed uses between industrial and commercial as well as specifically stated support for pedestrian and cycling infrastructure. However, the current neighborhood plans and Comprehensive Plan have multiple provisions to separate bike and ped paths from industrial areas. The EIS does not examine where the II zone expressly contradicts existing neighborhood plans. Proposed changes to the Comprehensive Plan do not specifically address this issue. More broadly, the EIS should develop a complete list of the neighborhood-level comprehensive plan recommendations impacted by these zoning changes and analyze whether they conform or contradict the Draft Comprehensive Plan Goal and Policy Language found in Appendix D. 

II. Comments on the proposed Alternatives.

In discussing the EIS publicly, we have found many Seattleites are confused, including many in Share The Cities, that the three alternatives EIS are not aligned with three new zoning designations. The EIS Alternatives examine how much the new zones will be laid out across the city’s existing industrial areas. We agree that this is a smart way of setting up the EIS because it focuses the discussion on specific locations rather than ephemeral concepts in zoning. But the document can be clearer about the distinction. 

We support Alternative 4 - The Future of Industry Expanded, only because there are no alternatives that more liberally use the UI and II zones across larger portions of the city. With time, we look for those zones to be used outside of the narrow boundaries of this EIS.

As the City Council moves to adopt the new industrial zones and the accompanying zoning map, they will be able to pick and choose between parts of the Alternatives. That means the boundaries can end up erratic and narrow due to legislative horse trading. The EIS must do a better job establishing why areas change under each of these Alternatives, and which areas should be treated as a cohesive cluster.

At the neighborhood level, the proposed maps do not offer a picture of cohesiveness. Besides raw acreage or numbers of houses, what does it mean if blocks are divided? Ballard’s Brewery District is a good example. It’s the area north of Leary Avenue on either side of 14th Avenue. Alternative 2 puts it in MML, Alternative 3 in Urban Industrial, and Alternative 4 sets it as Industry and Innovation. But the legislative process can split that apart. The EIS does not strongly justify what, if anything, is keeping these clusters together. (It should be kept together.)

Speaking of splitting the baby, it must be said that Alternative 1 should be considered a non-starter in its entirety. Even a compromise where some of the current industrial zones are maintained in certain areas should be dismissed completely. The current zoning ordinance is 1,400 unreadable pages. Adding a couple hundred more for new zones without removing any of the existing would be idiotic. The EIS should reflect 

III. Comments on boundaries.

While the proposed EIS Alternatives offer needed updates to industrial and manufacturing centers, they are stuffed within the existing boundaries of the current industrial zones. And that is the source of a much deeper problem. The city’s industrial boundaries themselves carry the history of segregation that cannot be washed away with a cursory equity analysis. 

This issue was brought up in scoping. In Appendix A, the EIS drafters respond to scoping comments that requested including an overview of historic land use actions by saying “The EIS will include a review of past plans and policies…Mitigation measures that further equity and environmental justice can be linked to this objective.” (Scoping Report 4) In response to the request that the scoping include more area than just the existing industrial areas, the EIS states: “The City of Seattle, as the Lead Agency, has the prerogative to define the range of alternatives it studies in the EIS.” (Scoping Report 7)

SDCI staff and consultants have made an extensive analysis of Seattle’s industrial areas across 14 different categories, including land use, public services, geology, and noise. Each of these sections deep dives into the topic and compares possible impacts of each alternative.

But the EIS doesn’t tell the story of how these industrial zones came to exist in their current locations. Take this paragraph from the Land Use section:

“Historical land use decisions also led to the location of multi-family housing in areas bordering industrial lands that caused environmental justice harms. Seattle’s first zoning ordinance in 1923 and its major update in 1956 located multi-family residential districts at the edges of rail lines, industrial districts, and manufacturing districts. Relatively less affluent renters were exposed to noise and air quality and other impacts, while single family districts removed from the edges of industrial areas were not. The continued pattern of multi-family housing and zoning districts bordering MICs. Continues to be evident today in areas including Interbay and the northeast edge of Ballard.” (DEIS 3-241)

While accurate, this obscures two important facts. First, not only were apartments located near industrial areas, but both industrial and multi-family uses were excluded from a vast majority of the city. Second, the pattern is not just evident today. It is our city’s current policy.

Between racially restrictive covenants and apartment bans written into zoning, multifamily housing was actively pushed out of many Seattle neighborhoods. Exclusion from the remaining city is important in understanding the issues that the EIS is trying to address. The document lists six emerging factors affecting industrial lands:

• Pressures to convert industrial lands

• Emerging technologies and processes

• Unintended development

• Pending port, transportation, and new industrial building typology

• Environment and climate change

• Equity and accessibility

Three of these – conversion pressures, unintended development, and equity – are directly tied to forcing apartments and shops and factories to compete over a small portion of the city’s land. The fourth, Environment and Climate Change, is deeply tied to how pollution is concentrated in small areas and poisoning neighboring communities of color. There is not a map of the entire city in the EIS. They all cut off just above Greenlake. This is a city-wide rezoning of industrial lands, yet it does not show the whole city. It is impossible to develop policies that address land use and zoning issues without once mentioning the other side of the story – the portion of the city devoted exclusively to single-family housing.

More broadly, the EIS mentions patterns of exclusion and redlining as if they happened in the past. Exclusion and redlining are current issues supported by current policy. In Exhibit 3.8-2, the EIS did an amazing thing by combining the Urban Villages map with the Industrial Centers map, two that are not normally put together. They show that density never touches water, only industrial waterfront. Beaches are reserved for Seattle’s homeowners.

Examining Exhibit 3.8-2 (left above) side-by-side with the 1930’s Home Ownership Lending Corporation map (right above) that established mortgage patterns which “redlined” communities of color shows that nothing has changed in 100 years of Seattle’s zoning. Industrial and downtown neighborhoods are left unshaded. “Undesirable” neighborhoods, still the city’s most diverse, were in red. The boundaries of the industrial zones and urban villages are the same lines that separated White mortgagees from Black and industrial neighborhoods in the 1930s. (HOLC map from The Seattle Civil Rights and Labor History Project, University of Washington)

In the Seattle 2035 Comprehensive Plan from 2015, the Urban Village strategy is described as “places that already have active business districts and concentrations of housing” (Seattle 2035 10, emphasis added). This continued the Urban Village concept that was adopted in the 1994 comprehensive plan, where the first goal was to “Maintain and enhance Seattle’s character” which it started to define as “large single family areas of detached houses.” (Toward a Sustainable Seattle 5) That plan never once mentioned how many of those single family neighborhoods had restrictive covenants written into their deeds. The comprehensive plans did not break any barriers, they reinforced them and continue as the basis for zoning we have today. The EIS states “since MICs were established in 1994, there have not been large-scale alterations to their geographic boundaries.” (DEIS 1-6) That same recognition can go back to the HOLC maps decades earlier.

The EIS struggles to explain how new zones will overcome the disparate impacts to communities burdened by the impacts of industry. As extensively documented by the Duwamish River Community Coalition in their comments, many of the EIS mitigation measures come down to “new zones will prompt construction of new buildings that will be better.” No matter how good a new building is, it cannot surpass the boundaries it is dropped into. And those boundaries have remained unchanged for 100 years. The industrial boundaries are steeped in systemic racism and continued by this Industrial and Maritime Strategy. The city is once again specifying factories and manufacturers are only allowed in certain areas that are next to communities of color. The boundaries are the segregation. This EIS maintains each and every one of them.

And that’s the reason it’s vitally important that this story be told within this EIS. There are 100 years of policies squeezed between that first Seattle zoning code in 1923 and today. Each one builds upon the last. Unquestioningly carrying forward the framework of racial segregation and exclusion from one copy to another is just putting a new book cover on the same redlining manual. This EIS fails to recognize that chain, much less break it.

It is indeed the city’s prerogative, as the Lead Agency, to define the range of alternatives it studies in the EIS. But that is exactly the same prerogative it has used to segregate and redline for the last century. While this EIS cannot single-handedly undo that damage, it can make some steps in the right direction:

1. Add documentation, analysis, and maps that connect Seattle’s historic segregation, redlining, and exclusion to the present day location of industrial uses. 

2. Complete a city-wide analysis of zoning that looks specifically at the ways commercial and multi-family exclusions in other parts of the city lead to the competition for industrial land. Use maps of the entire city.

3. Examine which recommendations and boundaries are carried over from older plans that have never been vetted for equity or impact, including transportation and public facilities.

IV. Conclusion and Summary of Comments

These comments are not offered to summarily reject or undermine the Industrial and Maritime Strategy or the draft EIS. As said, the proposal to update the city’s industrial zoning is good. The proposed zones have a lot of potential to reflect the new realities of manufacturing. They offer a chance for employers to be participants in the neighborhoods rather than kept segregated and apart. We look forward to making further comments during the legislative process to draft and locate the zones in order to prevent petty, classist, or biased exceptions. But the proposal is strong and having it on the table is a massive step forward.

However, the EIS is missing any recognition that the lines themselves are part of the issue. These historical boundaries made their own problems, and we are left to unquestioningly continue being constrained within them. To address the impacts of the Seattle Industrial and Maritime Strategy, the Environmental Impact Statement must make robust efforts to understand history and the sources of inequity in shaping land use decisions. Without those components, the mitigations proposed are simply inadequate, and the City will set itself up for unlimited challenges as it moves ahead with this rezoning and the coming 2024 Comprehensive Plan. 

Share The Cites Action Fund

March 2 DEIS comments

Submit your own comments by 5 pm on 3/2/2022 here: https://www.seattle.gov/opcd/ongoing-initiatives/industrial-and-maritime-strategy 

Send written comments on the Draft EIS by March 2 to PCD_Industry_And_Maritime_Strategy@seattle.gov