Cover Letter.pdfHARRISON
BENIS &
SPENCE, LLP
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Christopher T. Benis
James C. Harrison -
Michael A. Spence
Randall J. Cornwall
Katherine A. George
October 23, 2009
Robert Chave
Director, City of Edmonds Planning Division
121 - 5th Avenue North - 2nd Floor
Edmonds, WA 98020
RE: 190 SUNSET AVE S, EDMONDS, WA
SUNSET LANDING
Dear Mr. Chave:
This office represents ESC Associates, owner of the above -referenced property, which is
commonly known as the "Old Safeway" site at the corner of Sunset Ave. and Dayton Street.
Attached to this letter please find an application for a Contract Rezone changing the current BC
zoning to CG on the southern portion of the property, and to CG2 on the northern portion,
under Edmonds City Code Section 20.40. Supporting materials are attached to the application.
We respectfully request that this application be processed sequentially with the Design Review
process, rather than concurrently.
The site is 4.3 acres in size. It currently contains a 53,222 square foot one-story strip mall,
which was built in 1966. It is bounded by James Street to the North, SR 104 (Sunset Avenue)
to the East, Dayton Street to the South, and parking for the Sound Transit/Amtrak train station
to the West. It is essentially flat, with a slight slope to the Northeast. There are no threatened
or endangered species on the property, nor are there any delineated critical areas onsite or
nearby.
The site is currently zoned BC. The BC zone, as it applies to this property, has no minimum lot
area, no minimum lot width and no street, side or rear setbacks. The only dimensional
limitations are a height limit of 25 -feet, with an extra 5 -feet available for peaked roofs, and a
maximum floor area ratio of 3 square feet per square foot of lot area. Permitted uses include
single family residential, retail, office, auto sales, dry cleaners, printers, bus stop shelters, open
air markets, multifamily housing above the ground floor, churches, schools, public facilities and
parks.
The proposed project is named "Sunset Landing". Sunset Landing is a mixed use, transit
oriented development (MUTOD), planned to take advantage of the site's proximity to the multi-
modal transit facility immediately adjacent to the site. Sunset Landing is configured in two
separate structures and will be developed in two phases: a North phase and a South phase.
Market conditions will determine the order and timing of development. We are proposing to
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limit the uses to those allowed in the BC zone, as set forth in EMC 16.50.010.
Each structure includes two levels of parking wrapped by retail/commercial spaces, which form
711 a "podium" for the residential structures above. The North structure includes two residential
buildings above the podium, for a total height of 75 feet, not counting elevator and stair
penthouses (the dimensions of the CG2 zone). The South structure includes two residential
buildings above the podium for a total height of 60 feet, also not counting elevator and stair
penthouses (the proposed CG zone). The CG zone is consistent with the current zoning of the
Harbor Square property, which is immediately to the South of Sunset Landing.
The two structures will be divided by a "Woonerf", which is a plaza designed to be shared by
pedestrians, bicyclists, and low -speed motor vehicles. The Woonerf will create an east -west
pedestrian pathway through the center of the site, which will reduce the scale of the project and
improve pedestrian circulation in the area. The project's two internal commercial parking areas
will be accessed from the Woonerf.
Commercial spaces will be located along the streetfronts on Dayton Street, Sunset Avenue and
James Street. They will also extend alongside the Woonerf leading from Sunset Avenue to the
rail station. Presently the commercial spaces are configured for sizes ranging 1000 - 3000
square feet. The size of these spaces is consistent with the scale of existing Main Street retail
establishments in Edmonds. The project will also provide new open spaces on site, including
additional street trees and planting beds between the sidewalk and roadways and several public
plazas along the perimeter of the site. The top of the podiums will have rooftop open spaces for
the residents that will include hardscape areas, plantings, grass and common gardens.
Sunset Landing is designed to be consistent in all respects with the dimensional requirements of
Edmonds' CG and CG2 zones. Sunset Landing contains "working envelopes" that describe the
overall limits in size of any future development. These envelopes will define the potential size
of the buildings from grade to 25 feet in height, and above 25 feet to the top of the structures.
The working envelopes fix the dimensions of the setbacks, view corridors and plazas being
proposed as part of the contract rezone. They are slightly larger than the buildings shown on
the plans in order to allow room for flexibility in the final design of the buildings. The buildings
shown on the plans are used to denote the square footage and baseline number of units, which
would be conditions of the contract rezone.
The envelopes are designed to avoid, minimize or mitigate any potential view blockage by
establishing east -west view corridors through the site, and by setting back the residential
buildings from the podiums above the 25 -foot level.
For the reasons stated below, we believe that this design is more consistent with the Growth
Management Act, the Snohomish County Countywide Planning Policies, the Edmonds
Comprehensive Plan and the goals of the Edmonds Zoning Ordinance, than what is
contemplated in the BC zone.
We also believe that the proposed project easily satisfies the criteria under which a contract
rezone is to be considered in Edmonds. Those criteria are found in Edmonds City Code (ECC)
20.40.010, which reads in full as follows:
20.40.010 Review.
The planning advisory board shall review the proposed rezone as provided in ECDC
20.100.020. At least the following factors shall be considered in reviewing a proposed
rezone:
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A. Comprehensive Plan. Whether the proposal is consistent with the
comprehensive plan;
B. Zoning Ordinance. Whether the proposal is consistent with the purposes of the
zoning ordinance, and whether the proposal is consistent with the purposes of
the proposed zone district;
C. Surrounding Area. The relationship of the proposed zoning change to the
existing land uses and zoning of surrounding or nearby property;
D. Changes. Whether there has been sufficient change in the character of the
immediate or surrounding area or in city policy to justify the rezone;
E. Suitability. Whether the property is economically and physically suitable for
the uses allowed under the existing zoning, and under the proposed zoning. One
factor could be the length of time the property has remained undeveloped
compared to the surrounding area, and parcels elsewhere with the same zoning;
F. Value. The relative gain to the public health, safety and welfare compared to
the potential increase or decrease in value to the property owners.
1. The proiect is consistent with the Edmonds Comprehensive Plan
The Edmonds Comprehensive Plan expressly acknowledges the inadequacy of the current BC
zoning of the property in at least two passages. The first passage appears on page 33, in
Paragraph 8 of the "Long Term Actions" section of the Downtown Waterfront Activity Center
section. It states:
"8. Redevelop the area from the east side of SR 104 to the railroad tracks, from Harbor
Square to Main Street, according to a mixed-use master plan. ... Every opportunity
should be taken to improve the pedestrian streetscape in this area in order to encourage
pedestrian activity and linkages between downtown and the waterfront. Uses developed
along public streets should support pedestrian activity and include amenities such as
street trees, street furniture, flowers and mini parks...."
The second passage is much more explicit. It appears on page 36, in the description of the
subject property under "Downtown Waterfront Districts". It states:
"Downtown Master Plan. The properties between SR -104 and the railroad, including
Harbor Square, the Edmonds Shopping Center (former Safeway site) and extending past
the Commuter Rail parking area up to Main Street. This area is appropriate for design -
driven master planned development which provides for a mix of uses and takes
advantage of its strategic location between the waterfront and
downtown. The location of existing taller buildings on the waterfront, and the site's
situation at the bottom of "the Bowl", could enable a design that provides for higher
buildings outside current view corridors. Any redevelopment in this are should be
oriented to the street fronts, and provide pedestrian -friendly walking areas, especially
along Dayton and Main Streets. Development design should also not ignore the railroad
site of the properties, since this is an area that provides a "first impression" of the city
from railroad passengers and visitors to the waterfront. Artwork, landscaping and
modulated building design should be used throughout any redevelopment project."
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In addition to acknowledging the inadequacy of the current BC zoning, the Downtown
Waterfront Plan policies themselves contain express language encouraging a project of this
scale and design. Relevant passages are in several of the policies are underlined below:
"E.5. Extend Downtown westward and connect it to the shoreline by encouraging
mixed-use development and pedestrian -oriented amenities and streetscape
improvements, particularly along Dayton and Main Streets. Development in this area
should draw on historical design elements found in the historic center of Edmonds to
ensure an architectural tie throughout the Downtown Area...."
"E.8. Improve and encourage economic development opportunities by providing space
for local businesses and cottage industries and undertaking supporting public
improvement projects...."
"E.10. Provide a more efficient transportation system featuring improved bus service,
pedestrian and bicycle routes and adequate streets and parking areas."
"E.11. Encourage a more active and vital setting for new retail, office entertainment and
associated businesses supported by nearby residents and the larger Edmonds
community, downtown commercial activity and visitors from throughout the region."
"E.12. Support a mix of uses downtown which includes a variety of housing, commercial
and cultural activities."
"E.15. Provide greater residential opportunities and personal services within the
downtown, especially to accommodate the needs of a changing population."
"E.16. Provide for the gradual elimination of large and inadequately landscaped paved
areas."
"E.17. Provide pedestrian -oriented amenities for citizens and visitors throughout the
downtown waterfront area, including such things as:
• Weather protection
• Street trees and flower baskets
• Street furniture
• Public art and art integrated into private developments
• Pocket parks
• Signage and other way -finding devices
• Restrooms"
"E.22. Building design should discourage automobile access and curb cuts that interfere
with pedestrian activity and break up the streetscape. Encourage the use of alley
entrances and courtyards to beautify the back alleys in the commercial and mixed use
areas in the downtown area."
As you and the Planning Advisory Board can see from the application and supporting
documents, the contract rezone touches each of these criteria. It "extends Downtown
westward" and contains a "mixed-use development" with "pedestrian oriented amenities and
streetscape improvements, particularly on Dayton ... Street". It will "provide space for local
businesses and cottage industries" and will improve "pedestrian and bicycle routes and
adequate streets and parking areas". It will "encourage ... new retail, office ... and associated
businesses supported by nearby residents". It will enhance the "mix of uses downtown" and
include a "variety of housing, commercial and cultural activities". It will "provide greater
residential opportunities ... within the downtown" and will eliminate a "large and inadequately
landscaped paved area". Importantly, it is designed to "discourage automobile access and curb
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cuts that interfere with pedestrian activity."
2. The proposal is consistent with the purposes of the Edmonds Zoning Ordinance.
The purposes of the Edmonds Zoning Ordinance can be found in ECC 16.00.010, which reads as
follows:
16.00.010 Purposes.
In addition to the purposes stated in the city's comprehensive plan, the zoning
ordinance shall have the following purposes:
A. To assist in the implementation of the adopted comprehensive plan for the physical
development of the city by regulating and providing for existing uses and planning for
the future as specified in the comprehensive plan; and
Sunset Landing easily satisfies these criteria. As described above, the Comprehensive Plan
recognizes the inadequacy of the current BC zoning by contemplating on this site a "design -
driven Master Planned Development" which "provides for a mix of uses" that "takes advantage
of its strategic location", and which recognizes the taller buildings on the waterfront" and its
"situation at the bottom of "The Bowl"". In addition, the Comprehensive Plan elements cited
above make it clear that the City would like to "extend down westward" with "mixed-use
development and pedestrian oriented amenities", "particularly along Dayton and Main Streets".
The Plan further envisions a project that "improve(s) and encourages economic development ...
by providing space for local businesses and cottage industries" and one that "provide(s) greater
residential opportunities ... within the downtown, especially to accommodate the needs of a
changing population", providing for the "elimination of large and inadequately landscaped
paved areas" in the process.
This project was designed with these principles in mind. It is design -driven, it contains a mix of
uses, and it takes the taller buildings on the waterfront and the location at the bottom of the
"Bowl" into account. It "protects the character and the social and economic stability of
residential and commercial uses in the City" by focusing housing and mixed-use commercial
uses into a location that is conveniently served by multiple modes of transportation, including
bicycles, bus, rail, highway and ferries, not to mention its pedestrian orientation. It extends
downtown westward with a mixed use, pedestrian -designed development, which provides
"economic opportunities" and "greater residential opportunities" adjacent to the commuter rail
station.
It's important to note that Sunset Landing will reduce development pressures on other
neighborhoods that are not as well -situated or equipped to handle increased densities and will
help stop encroachment of inappropriate uses in these locations, which is also a fundamental
principle of the Growth Management Act, Countywide Planning Policies, Comprehensive Plan
and Zoning Ordinance.
Sunset Landing is also consistent with the purposes of the CG Zone, which are discussed in
those portions ECC 16.60.005 that do not deal with the Highway 99 corridor. Those sections
are set forth below in full as follows:
16.60.005 Purposes.
The CG and CG2 zones have the following specific purposes in addition to the general
purposes for business and commercial zones listed in Chapter 16.40 ECDC:
A. Encourage the development and retention of commercial uses which provide
high economic benefit to the city. Mixed-use and transit -oriented developments
are encouraged which provide significant commercial uses as a component of an
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overall mixed development scheme.
B. Improve access and circulation for people by encouraging a development
pattern that supports transit and pedestrian access. Improve vehicular circulation
and access to support business and economic development.
D. Encourage a variety of uses and building types. A variety of uses and building
types is appropriate to take advantage of different opportunities and conditions.
Where designated in the comprehensive plan, the zoning should encourage
mixed-use or taller high-rise development to occur.
E. Encourage development that is sensitive to surrounding neighborhoods.
Protect residential qualities and connect businesses with the local community.
Pedestrian connections should be made available as part of new development to
connect residents to appropriate retail and service uses.
Again, these criteria are easily satisfied. Sunset Landing is a mixed-use transit -oriented
development, and is therefore "encouraged" by ECC 16.60.005(A). By definition, it is a
"development that supports transit and pedestrian access" and improves "vehicular circulation
and access to support business and economic development", which satisfies ECC 16.60.005(B).
It contains a "variety of uses and building types", in satisfaction of ECC 16.60.005(D). Finally,
it contains "pedestrian connections" and connects "residents to appropriate retail and service
uses", in satisfaction of ECC 16.60.005(E).
3. The proposed zoning is related to and consistent with the "existing land uses and
zoning of surrounding and nearby property".
As described above, the property is bordered by James St. to the North, SR 104 (Sunset Ave S)
to the East, Dayton St. to the South, and the Sound Transit/Amtrak station to the West.
Beyond these features, to the North lies a WSDOT parking lot and the "Old Skippers" property,
which we understand is proposed for higher density development. To the East beyond SR 104
is the ferry terminal parking area and beyond that, residential and commercial buildings of 2 -
4 stories in height. To the South beyond Dayton Ave. is the Harbor Square project, which is
currently zoned CG. To the West are the train tracks, and beyond that, larger residential and
commercial buildings and the Edmonds Senior Center.
In its current configuration, the subject property is the most underused of all of these parcels,
even though it is the closest one to the train station and bus stops on Railroad Ave. This is true
under the existing BC zoning as well. Being this close to multiple modes of transit, this site is
perfect for a mixed-use transit -oriented development of this kind. By its nature, a mixed-use
transit -oriented development is "consistent with the existing land uses and zoning of
surrounding and nearby property".
4. There has been "sufficient change in the character of the immediate and
surrounding area" and "in City policy" to justify the rezone.
At the time that the zoning code and comprehensive plan were last amended, the Edmonds
Crossing project, which proposed to relocate the ferry terminal and Sound Transit/Amtrak
station to the south of the property, was alive and well. Since then, as the City Council
discussed at length in its February, 2009 retreat, the State has only allocated $26 million to the
Edmonds Crossing project, which means that the current station has been designated as an
"interim station" for the foreseeable future. In addition, we understand that Sound Transit has
issued permits and is soliciting a design for the Edmonds Station, another indication that
Edmonds Crossing is not going to be built for a long time. In addition to this monumental
change, we also understand that the owner of the former "Skipper's" site is proposing an
increase in height and density on that property. For these reasons, we believe that there has
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been "sufficient change in the character of the immediate and surrounding area or in City policy
to justify the rezone" under ECC 20.40.010(D).
S. The property is no longer "economically and physically suitable for the uses
allowed under existing zoning, and under the proposed zoning".
As set forth above, the BC zone has no street, side or rear setbacks, a 25 -foot height limit (30
feet with peaked roofs) and a floor area ratio of 3. These unsophisticated and overly simple
dimensional requirements encourage little more than what is already there - a one-story strip
mall, which when located next to a commuter rail station is the antithesis of the Growth
Management Act of 1990 and its progeny.
The property is not economically suitable for redevelopment under the BC zone, given the
values of land this close to multimodal transportation facilities in Puget Sound. Without zoning
sufficient to allow an economically viable use on this property, it is almost guaranteed to remain
a one-story strip mall far into the future. Nor is a strip mall physically suitable for this property,
given its proximity to multimodal transportation.
Conversely, the property is well suited for the proposed zoning. It is probably the most
multimodal site in all of Puget Sound. It has been underdeveloped since 1966, and since then,
larger projects have been built in the vicinity. In addition to this, the presence of the Sound
Transit commuter rail station makes a mixed-use transit -oriented development on this site
much more appropriate than a one-story strip mall.
6. The project represents a "significant gain to the public health, safety and welfare,
compared to the potential increase or decrease in value to the property owners".
As set Forth in this letter, the public will gain significantly from a mixed use transit -oriented
development on this site, versus a one-story strip mall. Transit -oriented development reduces
the use of single -occupant vehicles by increasing the number of times people walk, bicycle,
carpool, vanpool, or take a bus, streetcar, or rail. Transit -oriented development does this by
bringing potential riders closer to transit facilities rather than building homes away from
population centers, which makes people more dependent on roads and automobiles, reducing
traffic congestion in the process. TOD makes it easier for residents to commute to work, run
errands, socialize and meet basic needs without always needing a car. Importantly, TOD also
makes public transit investments work more efficiently by putting more riders on alternative
modes of transportation.
For these reasons, we believe that the CG zoning easily satisfies the requirements of ECC
20.40.010, 16.00,010 and 16.60.005, as well as the sections of the Comprehensive Plan
mentioned above.
It's important at this juncture to discuss Sunset Landing's consistency with the Growth
Management Act of 1990 (GMA). Specifically, the project is consistent with the following
sections of the GMA:
RCW 36.70A.020
Planning goals.
The following goals are adopted to guide the development and adoption of comprehensive plans
and development regulations of those counties and cities that are required or choose to plan
under RCW 36.70A.040. The following goals are not listed in order of priority and shall be used
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exclusively for the purpose of guiding the development of comprehensive plans and
development regulations:
(1) Urban growth. Encourage development in urban areas where adequate public facilities and
services exist or can be provided in an efficient manner. Comment: Sunset Landing is clearly
in an urban area and all public facilities and services are already available.
(2) Reduce sprawl. Reduce the inappropriate conversion of undeveloped land into sprawling,
low-density development. Comment: Sunset Landing will significantly reduce the pressure to
convert undeveloped land to low density development elsewhere in the City and County.
(3) Transportation. Encourage efficient multimodal transportation systems that are based on
regional priorities and coordinated with county and city comprehensive plans. Comment: It's
hard to imagine a more multimodal site in Puget Sound. Sunset Landing is walking distance
from the ferry terminal, the Amtrak and Sound Transit commuter rail train stations and a
Community Transit bus stop. It also abuts State Highway 104, which provides direct access to
Interstate 5.
(4) Housing. 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. Comment: Sunset Landing will provide
housing that is affordable, at a variety of densities and housing types. One element of
affordability is that TOD's de-emphasize automobiles, making more money available for
housing. In addition, no housing stock will be lost in redevelopment of this site.
(5) Economic development. Encourage economic development throughout the state that is
consistent with adopted comprehensive plans, promote economic opportunity for all citizens of
this state, especially for unemployed and for disadvantaged persons, promote the retention and
expansion of existing businesses and recruitment of new businesses, recognize regional
differences impacting economic development opportunities, and encourage growth in areas
experiencing insufficient economic growth, all within the capacities of the state's natural
resources, public services, and public facilities. Comment: Sunset Landing will promote
retention and expansion of Edmonds businesses, as well as the creation of new Edmonds
businesses. And since this site is already developed, no natural resources are impacted.
Further, adequate public services and facilities are available close by.
(9) Open space and recreation. Retain open space, enhance recreational opportunities,
conserve fish and wildlife habitat, increase access to natural resource lands and water, and
develop parks and recreation facilities. Comment: The pedestrian orientation of Sunset Landing
and its proximity to several parks and Puget Sound beaches serve to enhance recreational
opportunities for more residents and businesses in Edmonds. In addition, it will feature more
open space on site than in its current configuration.
(10) Environment. Protect the environment and enhance the state's high quality of life,
including air and water quality, and the availability of water. Comment: Sunset Landing will
reduce pressure for inappropriate greenfield development elsewhere. Additionally, the proximity
of this site to ferry, rail and bus transit reduces the use of single occupant vehicles and carbon
emissions.
Sunset Landing is also strongly supported by other sections of the GMA. Specifically:
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RCW 36.70A.070
Comprehensive plans — Mandatory elements.
The comprehensive plan of a county or city that is required or chooses to plan under RCW
36.70A.040 shall consist of a map or maps, and descriptive text covering objectives, principles,
and standards used to develop the comprehensive plan. The plan shall be an internally
consistent document and all elements shall be consistent with the future land use map. A
comprehensive plan shall be adopted and amended with public participation as provided in RCW
36.70A.140.
Each comprehensive plan shall include a plan, scheme, or design for each of the following:
(1) A land use element designating the proposed general distribution and general
location and extent of the uses of land, where appropriate, for agriculture, timber
production, housing, commerce, industry, recreation, open spaces, general aviation
airports, public utilities, public facilities, and other land uses. The land use element shall
include population densities, building intensities, and estimates of future population
growth. The land use element shall provide for protection of the quality and quantity of
groundwater used for public water supplies. Wherever possible, the land use element
should consider utilizing urban planning approaches that promote physical activitx.
Where applicable, the land use element shall review drainage, flooding, and storm water
run-off in the area and nearby jurisdictions and provide guidance for corrective actions
to mitigate or cleanse those discharges that pollute waters of the state, including Puget
Sound or waters entering Puget Sound.
(2) A housing element ensuring the vitality and character of established residential
neighborhoods that: (a) Includes an inventory and analysis of existing and projected
housing needs that identifies the number of housing units necessary to manage
projected growth; (b) includes a statement of goals, policies, objectives, and mandatory
provisions for the preservation, improvement, and development of housing, including
single-family residences; (c) identifies sufficient land for housing, including, but not
limited to, government -assisted housing, housing for low-income families, manufactured
housing, multifamily housing, and group homes and foster care facilities; and (d) makes
adequate provisions for existing and projected needs of all economic segments of the
community.
(6) A transportation element that implements, and is consistent with, the land use
element.
(a) The transportation element shall include the following subelements:
... (vi) Demand -management strategies;
(vii) Pedestrian and bicycle component to include collaborative efforts to identify and
designate planned improvements for pedestrian and bicycle facilities and corridors that
address and encourage enhanced community access and promote healthy lifestyles.
RCW 36.70A.090
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Comprehensive plans — Innovative techniques.
A comprehensive plan should provide for innovative land use management techniques,
including, but not limited to, density bonuses, cluster housing, planned unit developments, and
the transfer of development rights.
RCW 36.70A.108
Comprehensive plans — Transportation element — Multimodal transportation
improvements and strategies.
(1) The transportation element required by RCW 36.70A.070 may include, in addition to
improvements or strategies to accommodate the impacts of development authorized under RCW
36.70A.070(6)(b), multimodal transportation improvements or strategies that are made
concurrent with the development. These transportation improvements or strategies may
include, but are not limited to, measures implementing or evaluating:
(a) Multiple modes of transportation with peak and nonpeak hour capacity performance
standards for locally owned transportation facilities; and
RCW 36.70A.110
Comprehensive plans — Urban growth areas.
(1) Each county that is required or chooses to plan under RCW 36.70A.040 shall designate an
urban growth area or areas within which urban growth shall be encouraged and outside of
which growth can occur only if it is not urban in nature. Each city that is located in such a
county shall be included within an urban growth area. An urban growth area may include more
than a single city. An urban growth area may include territory that is located outside of a city
only if such territory already is characterized by urban growth whether or not the urban growth
area includes a city, or is adjacent to territory already characterized by urban growth, or is a
designated new fully contained community as defined by RCW 36.70A.350.
(2) Based upon the growth management population projection made for the county by the office
of financial management, the county and each city within the county shall include areas and
densities sufficient to permit the urban growth that is projected to occur in the county or city for
the succeeding twenty-year period, except for those urban growth areas contained totally within
a national historical reserve. Each urban growth area shall permit urban densities and shall
include greenbelt and open space areas. In the case of urban growth areas contained totally
within a national historical reserve, the city may restrict densities, intensities, and forms of
urban growth as determined to be necessary and appropriate to protect the physical, cultural,
or historic integrity of the reserve. An urban growth area determination may include a
reasonable land market supply factor and shall permit a range of urban densities and uses. In
determining this market factor, cities and counties may consider local circumstances. Cities and
counties have discretion in their comprehensive plans to make many choices about
accommodating growth.
(3) Urban growth should be located first in areas already characterized by urban growth that
have adequate existing public facility and service capacities to serve such development, second
in areas already characterized by urban growth that will be served adequately by a combination
of both existing public facilities and services and any additional needed public facilities and
services that are provided by either public or private sources, and third in the remaining
portions of the urban growth areas. Urban growth may also be located in designated new fully
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contained communities as defined by RCW 36.70A.350.
To summarize, we believe that the existing BC zoning is inconsistent with the Growth
Management Act, the Snohomish County Countywide Planning Policies and the Edmonds
Comprehensive Plan. The Comprehensive Plan itself clearly acknowledges this fact, and
expressly invites this application in two passages. We also believe that the CG zoning
requested in this application, in combination with the plans for Sunset Landing is much more
consistent with these touchstones of growth management. A mixed-use transit oriented
development is much more appropriate for arguably the most multimodal site in Puget Sound,
versus the one-story strip mall that the BC zone encourages.
Thank you for reviewing this letter and the attached application. We are happy to meet with
you, your Department, the Planning Review Board or any other representatives of the City you
feel are appropriate. We look forward to working with you and any others you deem
appropriate on this project, which we sincerely believe is the best possible use for this
strategically -located and extremely important property. Please contact me at the above
address with any questions you may have.
Very truly yours,
HARRISON, BEMIS & SPENCE, LLP
Michael A. Spence
DOCUMENT13
Attachments
Cc: ESC Associates
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