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Cover Letter.pdfHARRISON BENIS & SPENCE, LLP ATTORNEYS AT LAW 2101 Fourth Avenue, Suite 1900 Seattle, WA 98121-2315 FAX 206.448.1843 206.448.0402 Christopher T. Benis James C. Harrison, Michael A. Spence -Also sm7rr*0 In Cslilernts Randall J. Cornwall Of Counsel Katherine A. George Of Counsel July 15, 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 pa rks. 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 Page 1 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. Each structure includes two levels of parking wrapped by retail/commercial spaces, which form 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: Page 2 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 project 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." Page 3 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.S. 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 andap rking 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 importunities 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 streetscapee. 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 Page 4 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 Page 5 are encouraged which provide significant commercial uses as a component of an 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(8). 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 Page 6 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 Page 7 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. ATIN (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. Page 8 Sunset Landing is also strongly supported by other sections of the GMA. Specifically: 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 activity. 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. Page 9 RCW 36.70A.090 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 existing12ublic 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 Page 10 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 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 Edmond's 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 multimodai 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, BENTS & SPENCE, LLP Mi 4el A. Spence DOCUMENT13 Attachments Cc: ESC Associates Pace I I