Comments of John and Rachael Osborn

City of Spokane Planning Department

Attn: Leroy Eadie

808 West Spokane Falls Blvd.

Spokane, WA 99201

Re: Kendall Yards SEIS

Dear Mr. Eadie,

These comments are directed to the Supplemental Environmental Impact Statement (SEIS) circulated by your offices for the Kendall Yards planned unit development proposal. We thank you for this opportunity to express our concerns to the City about the project.

While we generally support the Kendall Yards development, unfortunately we find the SEIS to be a vague document that does not adequately identify or describe many of the negative impacts that we believe the Kendall Yards project will bring to the West Central neighborhood. As residents of West Central we are particularly concerned about air quality and noise during construction, traffic, and the impacts on the riparian corridor of the Spokane River. If the SEIS does not contain adequate discussion of these impacts, they will not be properly mitigated. Therefore the content of this document is a key step in the process of approval.

A. The 1993 Environmental Impact Statement is Stale.

The SEIS tiers to a 1993 environmental impact statement, prepared when the site was owned by Metropolitan Mortgage. Reliance on a 13-year old EIS is not appropriate. The differences in the amount of residential housing proposed now versus in 1993 (i.e., 2,600 units now compared with 1,000 then) are a basis to start the impact statement process anew. In reviewing the document it is apparent that many reasonably foreseeable impacts are simply not addressed at all.

As the SEIS acknowledges, some aspects of the original EIS are stale or incomplete and require new and additional review and analysis. However, there are a number of issues, including potential adverse impacts to surface water in the Spokane River, noise, plant & animal habitat, natural resources, scenic resources, light & glare, and aesthetics in which updated information is necessary. Instead, the SEIS defers to the 1993 EIS. This is inappropriate and disserves the neighborhood, given the scope and scale of the project. The addition of 1,600 new housing units to the project will cause significant impacts above and beyond those described in the 1993 EIS and should form the basis for preparing a new environmental impact statement.

B. Cumulative and Indirect Impacts are Not Properly Addressed in the SEIS.

A significant amount of activity is now and will be centering on the “Gorge Park” area of the Spokane River, adjacent to the Kendall Yards development. In addition to the Kendall Yards project, the Gorge Park master plan and its numerous activities will bring people, traffic, and other changes to the area. See Attachment 1 (Gorge Park Strategic Master Plan Project Matrix (2005)).

While the Gorge Park master plan contains some great ideas, to date the City has conducted no environmental assessment of the impacts the master plan’s 15 projects will have on the Spokane River and environs. It is predictable that these projects will bring visitors to the River; indeed that is the purpose of the Gorge Park master plan. Thus, the whitewater kayak park and boat ramps, the interpretative site and visitor “arrival points,” and a host of economic development projects will clearly add traffic to the West Central, Peaceful Valley and Browne’s Addition neighborhoods. Add in 4,000-plus new residents from Kendall Yards and the potential pressure on the river corridor becomes immense.

A related cumulative impact concerns bicycle traffic. Summit Avenue has become the de facto link in the Centennial Trail between Pettit St. (Doomsday Hill) and the Westlink Bridge. This will increase with extension of the trail in the Kendall Yards development. We acknowledge that the Gorge Park plan proposes to extend the trail through the Riverside Cemetery and other properties on the south side of the River, but given easement issues, that could take a very long time. We don’t object to bicycle traffic on Summit, but as noted below, the potential for increase in bicycle-pedestrian-automobile conflict is increasing. This is a cumulative impact problem that is not recognized or addressed in the SEIS.

Another foreseeable indirect impact is the effect the Kendall Yards proposal is having on housing stock in the West Central neighborhood. Speculative buying is already occurring and there is concern that many of the lower-value older homes will be demolished and replaced with multi-family housing. This in turn will bring additional noise and traffic to the neighborhood, along with more pressure on the Spokane River.

Finally, one cumulative impact of the project comes from the developer’s own actions. According to recent reports, the owner of Kendall Yards is attempting to purchase a number of buildings and parcels in and around the Kendall Yards property. See Attachment 2 (Spokesman-Review articles (March 2006)). These actions imply that the developer intends additional development adjacent to the Kendall Yards project, which will add more construction impacts and traffic to the neighborhood.

Unfortunately, the SEIS does not discuss any of these cumulative and indirect impacts. The fact that some of them are outside the control of Kendall Yards is not relevant. SEPA requires the City to ensure that all impacts, direct, indirect and cumulative, are properly considered and mitigated. At present the SEIS does not offer the analysis or proposed mitigation to satisfy SEPA requirements.

C. The Traffic Discussion in the SEIS is Inadequate.

Detailed discussion of the traffic impacts associated with the Kendall Yards project is deferred to a “Traffic Impact Analysis” (TIA). The TIA in turn is to be conducted in phases connected to the phased development of the project. The SEIS indicates that the project is proposed to be built in 6 stages. The first stage of development will occur in the easternmost section, adjacent to Monroe Street. After that, build-out will be random, “based on market conditions.”

While we appreciate that the City has directed the developer to provide additional detail concerning traffic in the TIA, it is not appropriate to remove consideration of impacts from the SEIS. The EIS must contain discussion of significant impacts on the environment and reasonable mitigation measures. WAC 197-11-440(6). By deferring discussion of traffic impacts to other documents at some unknown future time, you deprive the citizens of Spokane of their opportunity (and right) to understand and comment on the full impacts of the project, along with proposed mitigation, that is afforded under the protective standards of the State Environmental Policy Act. Because of this, the SEIS is inadequate.

We are also concerned that phased review of traffic impacts will lead to a failure to collect baseline data for the West Central neighborhood. By the time data is collected, the Kendall Yards project will already be affecting traffic in the neighborhood. Current traffic patterns and numbers, from which impacts and appropriate mitigation can be measured, must be collected before the project begins. SEPA requires agencies to collect essential information about a project’s impacts as part of the EIS process. WAC-197-11-080(1). The proposal to defer traffic analysis is inappropriate.

D. High Density & the Neighborhood

The SEIS is vague about the details of the actual density of development. It appears that the intent is to put 8 to 12 story apartments or condominiums on the west end of the project (SEIS p. 53). High-rise housing is inappropriate for the West Central neighborhood, where the west end of the project is located. High rise condos, if any, should only be located at the east end, near the downtown area. Further, the potential aesthetic, traffic and light & glare impacts associated with such an intensive level of development are not identified or properly mitigated in the SEIS.

E. Impacts of the Build Out Period Require Mitigation

According to the SEIS, the developer plans to build Kendall Yards over a 20-year period. Phase 1 will be near Monroe Bridge, but the order of development for the subsequent five phases will be determined by market demand (SEIS p. 1). It will harm the quality of life in the West Center neighborhood to allow random development of Kendall Yards. The SEIS fails to acknowledge or address the impacts associated with such a long building period, including noise and air quality impacts.

As mitigation for these impacts, the City must require the builder to provide clear commitments and a timeline of when and where building will occur. The City should also require full development of all transportation infrastructure at the outset of the project.

F. Air Quality & Construction Impacts

At present, the Kendall Yards property is a big, empty dirt lot that is upwind of the West Central neighborhood and downtown Spokane. The SEIS promises that during construction, dust will be controlled according to SCAPCA guidelines (SEIS p. 32). But, during dry spells, particulate matter is already are blowing off the site. This is an important public health issue that requires thought and attention. The SEIS should more fully describe this problem, including its time-scale dimension, and the City must impose conditions immediately to require the developer to control dirt blowing off the site. Simply deferring to SCAPCA requirements is not adequate to describe the problem and the mitigation required. Given that this is a 78-acre lot with a 20-year build out period, the developer must be held responsible for keeping dust and dirt under control at all times.

G. Traffic Impacts Will Likely Be Substantial

The SEIS states that, because Kendall Yards will include an east-west arterial to funnel traffic to the Maple and Monroe Bridges, therefore “the impacts to existing West Central neighborhood streets are not expected to be significant.” (SEIS p. 81)

But, the SEIS contains no discussion of the impacts that will occur when traffic is headed northwest out of Kendall Yards via A Street, Lindeke, Cochran, and Nettleton, when residents go out to Shadle shopping center (Wal-Mart), Spokane Falls Community College, and other northwest destinations.

As those of us who live in the neighborhood can attest, a lot speeding occurs on West Central streets. Summit Avenue, because of its open aspect and wide breadth (due in part to lack of sidewalks on the inside edge), is a magnet for speeders. Drivers also, quite understandably, take Summit Avenue because it is a pretty street. Kendall Yards residents will do this too.

The SEIS contains no discussion regarding the inevitable increased use of Summit Avenue and north-south access streets, nor does it acknowledge potential exacerbation of the problem of speeding cars. The issue is briefly mentioned (SEIS p.91), but not addressed. The deferral of this issue to the phased TIA at an unknown future date is inappropriate.

The SEIS makes a downward adjustment of the projection for car trips in and out of Kendall Yards, based on the assumption that people will walk and take transit. But there is no transit scheduled for a Kendall Yards route. The developer plans to ask for a bus line, but there’s no guarantee if or when they’ll get it, especially because, as a 20-year phased project, it is not clear when demand for buses would be adequate to support a new route.

The SEIS discusses the developer’s laudable goal for a pedestrian oriented project. But the SEIS also acknowledges that most people won’t walk more than one mile (if that). There is no discussion of pedestrian activity during winter weather. At this time there is no evidence to support the SEIS projection that there will be less traffic in the neighborhood because of transit and pedestrian and bicycle usage within Kendall Yards.

The SEIS should include a comprehensive transportation analysis and it should assume that people will use cars at the same ratio as elsewhere in Spokane. The SEIS should discuss appropriate mitigate measures for that level of use. Further, if the developer intends to rely on alternative transportation systems as a mitigation measure for traffic impacts, then alternative transportation infrastructure should be installed at the outset of the project, including light rail, bike paths, sidewalks, etc.

H. Bicycle-Pedestrian-Automobile Conflicts

We support and endorse Kendall Yards proposal to accommodate the Centennial Trail on the north bank of the Spokane River. The problem is that, as ever more bicycles use Summit Avenue as the de facto Centennial Trail link, and as Kendall Yards residents increase the number of walkers and joggers along Summit, bike-car-pedestrian conflicts will increase. This is especially true because Summit has only one sidewalk. More bikes and pedestrians is fine, more accidents is not.

This issue is not discussed in the SEIS. As with the transportation element generally, the potential for increased bicycle traffic and multi-use conflicts should be included in the SEIS. The SEIS should also discuss potential mitigation measures that will be needed to slow down the cars and safely accommodate all street users.

I. Spokane River Natural Areas.

Kendall Yards will sit atop a bluff overlooking Spokane River natural areas, including Lower Crossing, Harry Hamblen Natural Area, Riverside Park, and People’s Park. No doubt many Kendall Yards residents will utilize these areas. The Westlink pedestrian bridge is already bringing a lot more people to the crossing, causing bank erosion and de-stabilization as pedestrians take shortcuts down the hillslopes, which are composed of highly erodable till. Kendall Yards residents will exacerbate this problem.

Without careful planning, Kendall Yards will also degrade the habitat values associated with these natural areas, including wildlife corridor values of the relatively untouched Spokane River canyon. We who live in this neighborhood are lucky to often see deer, coyotes and the occasional moose, along with all kinds of birds (raptors, song and game birds) that access the area via the wild river corridor. This a unique urban wilderness and the City must put significant thought into identifying the impacts of this massive development on the river environment, and the appropriate measures necessary to preserve these unique and important natural values.

It is our hope that the developer – who is clearly attracted to the proximity of the Spokane River to his property (and who will benefit from the increased value that it brings) – will acknowledge and address the need to preserve the natural areas that border the project. To do that, however, the SEIS must identify and describe both the existing values and potential impacts. Unfortunately, the SEIS contains limited and inadequate discussion of the increased pressure and potential degradation that Kendall Yards can be expected to bring to neighboring natural areas and the Spokane River.

At a minimum, the SEIS should inventory and discuss the wildlife habitat and water quality values that are at stake. Insofar as mitigation measures go, much additional discussion is needed. The City must require Kendall Yards to contribute to adequate paving and paths within the park and natural areas to prevent erosion that harms the hillside and holds potential to send sediments into the Spokane River. Mitigation measures should also include careful outdoor lighting to reduce nighttime light and glare (an element that is completely missing from the SEIS). No doubt there are more ideas on how to reduce adverse impacts and we ask the City to fully explore the potential for preservation of the wildness and beauty of the Spokane River.

We very much appreciate the opportunity to comment on the SEIS. We look forward to continuing participation in the City’s processes for review of the Kendall Yards Project.

Yours very truly,

Rachael Paschal Osborn

John Osborn, MD

West Central Neighborhood residents