August 8, 2011
Planning and Development Commission
210 Lottie Street
Bellingham, WA 98226
Re: Padden Trails Rezone Request
Dear Planning Commission Members,
Please accept this letter as the Samish Neighborhood Association’s (SNA) formal request to deny the rezone request by Padden Trails LLC. Our Board of Directors and the residents it represents believe the rezone does not meet the criteria of BMC 20.19.030.A, subsections 1-7 (a-c) of the 2006 Comprehensive Plan Policy FLU-2 or the 2007 Samish Neighborhood Plan.
On Tuesday July 12, 2011 the Samish Neighborhood Association Board of Directors voted unanimously to oppose the request by Padden Trails LLC and Free Spirit Enterprises LLC to rezone 113 acres from Residential Single (20,000 sq ft minimum detached lot size) to Multifamily Residential (8,000 sq ft minimum). This decision is based on months of detailed analysis of the proposed rezone plans, two meetings with the consultants for the developer, discussions at several of our regular Board meetings, two special Board meetings, and input from Samish area residents. We fully comprehend the seriousness of this decision and its impact on our neighborhood and the community as a whole.
Please understand that we (the Board and Samish residents) fully expect increased development in our neighborhood and look forward to working with the City and developers in the future. Our long-standing position however has always been that a rezone request and the higher density that comes with it ought to be in those areas that can adequately accommodate the greater impacts that these types of developments generate. For example, multi-family residential development is very appropriate along the San Juan Boulevard and proposed extension of Governor Road that can accommodate the higher traffic densities associated with these developments.
To elaborate on the reasons why we came to our decision, we have provided responses to each of the points made by the consultants in their rezone request as follows:
1. It is consistent with the Bellingham Comprehensive Plan or corresponds to a concurrent comprehensive plan amendment application. The developers rezone request states:
“These tools enable an efficient use of land, less pressure for sprawl, encourages alternative transportation, safeguards the environment, promotes healthy neighborhoods and protects neighborhood character, The proposed zoning also encourages a diverse residential neighborhood with a variety of housing opportunities as stated in Policy FLU-4.”
The 113 acres of the Padden Trails development area are not within the city’s geographical boundaries designed for urban infill but are instead located in a geographically isolated single-family residential zoned area at the south end of the city. Changing the zoning for this area will not assist Bellingham in meeting its Comprehensive Plan mandate for residential infill development.
The proposed zoning is also not consistent with Infill Strategy 4 in the Comprehensive Plan:
“..some Bellingham neighborhoods (Samish, South and Whatcom Falls for example) contain significant blocks of undeveloped land currently zoned for relatively low density development. These and other areas could be evaluated to determine if higher densities might be appropriate. Factors that could limit development potential such as environmental constraints (wetlands, steep slopes) and infrastructure capacity (water, sewer, roads, parks, schools) would need to be considered in the process.” (Page LU-30).
The steep slopes and lack of infrastructure readily acknowledged by Padden Trails in their own rezone request, draft traffic study, and other supporting material clearly supports this not being an appropriate location for higher densities.
The Samish Neighborhood Plan (Plan) states:
“Urban villages, cluster developments, and higher intensity land uses may be considered when transportation infrastructure is in place or is concurrent with development and located in appropriate areas of the neighborhood consistent with current zoning, such as along San Juan Boulevard and Governor Road. In judging appropriateness, the distinguishing characteristics of the neighborhood, e.g. drainage, circulation, single-family areas, should be considered “
Padden Trails LLC and Free Spirit LLC acknowledge this statement from the SNA Plan and yet this proposed development is not along a major arterial such as San Juan Boulevard or Governor Road. Instead it is located in an isolated area that can only be accessed and exited by one substandard arterial. Moreover, road-width limitations along that arterial hinder access by WTA buses, as well as by the Bellingham Fire Department. Future residents would not have access to alternative transportation, resulting in more vehicle traffic in and out of the development. This is contrary to the transportation mode shift targets in the city’s Comprehensive Plan (TP-1) which calls for fewer trips in cars and more trips on public transportation or by bicycle or on foot. Moreover, the BFD has required that all dwellings be built with built with fire sprinklers, adding to the cost of the housing. This would reduce or eliminate low-cost housing options to those in need.
The developer’s own Draft Traffic Study acknowledges that the development will have a negative impact on traffic flow in an already strained geographical area:
“The transportation character of the development is likely to be mostly vehicle oriented. No local transit service is available within the generally accepted quarter mile walking distance of the proposed future homes. A park and ride with regular service is located at the I-5 freeway ramps, but is only served by WTA Route 80x, a commuter route to Mt. Vernon. There is expected to be considerable bicycle activity generated by the development, but it is expected to be mostly recreational in nature. A designated bike route, without marked lanes, does pass by the development’s access on Connelly and mixed-use trails will connect with the Lake Padden Park, both of which would encourage bicycle use. However, Bellingham’s employment centers are located a fair distance away and bicycles cannot be expected to be used regularly for commuting.”
In another part of their study it is noted:
“The Connelly Avenue and 34th Street intersection currently operates at LOS B under existing channelization and traffic control, but will degrade to a LOS F in 2013 with the development’s added traffic.” Moreover, it states:
“The intersection of Connelly Avenue and 34th Street is predicted to be impacted by the proposed development and would represent 49.7% of the future traffic volumes at this location. Mitigation analysis has shown that the intersection would operate at an acceptable LOS as and All-Way Stop, requiring the installation of stop signs and appropriate striping. A cost estimate for the proposed All-Way Stop control improvements was performed and it is expected that the proposed improvements at this location would total $5,000. The resulting proportionate share for the Padden Trails Residential development would offer $2,485 ($5,000 x 49.7%) for mitigating traffic impacts to this intersection. (Emphasis Added)
2. It will not adversely affect the public health, safety or general welfare;
There is only one road providing ingress/egress for this proposed development. This limitation was such a great concern to the Bellingham Fire Department (BFD) that when the previous application was approved years ago it required every single home be installed with a sprinkler system. There are no other single family residential developments within Bellingham City limits that have ever been held to such a strict standard. Obviously the BFD has identified this area to be a fire hazard with the potential for significant impacts to property, human health, and the environment because of the limited ingress and egress to this isolated area. Moreover, its physical isolation from the rest of the Samish neighborhood community and greater Bellingham area may attract criminal activities that would adversely impact the safety, health or general welfare of the neighboring residents. Those activities will also impact the city by requiring greater police presence and resources. Rezoning this area to multi-family residential would drastically increase the potential for catastrophic, negative impacts to the public health, safety, and general welfare of the residents of this development, the rest of the community, and the Fire and Police personnel we count on to keep us safe and secure.
3. It is in the best interests of the residents of Bellingham;
This is not in the best interest of the residents of Bellingham for many of the reasons previously noted and is contrary to the principles and goals in the Samish Neighborhood Plan. Approving this rezone request in any manner would reflect poorly on our neighborhood and the community as a whole.
4. The subject property is suitable for development in general conformance with zoning standards under the proposed zoning district;
Contrary to this statement, the property is not amenable to development as evidenced by the difficulty experienced by the previous owners in getting the preliminary plat approved years ago. The steep topography, numerous streams and springs, wetlands and other infrastructure limitations on the property were the reasons for this difficulty. Rezoning this area to accommodate up to four times the original platted density will only serve to create “islands” of multi-family residences within the area interconnected with a network of narrow roads. This is not a suitable area for this kind of development considering that other areas along San Juan Boulevard and Governor Road are more appropriate, providing the infrastructure and services to support multi-family residential development. We recognize our community’s need for flexible and diverse housing forms, and suggest there are more appropriate areas in the Samish area for multi-family development.
5. Adequate public facilities and services are, or would be, available to serve the development allowed by the proposed zone;
Public facilities and services are currently available only at the perimeter of the development site. During construction and many years after completion these services will be inadequate to meet the needs of the residents. In addition to the fire and safety issues already discussed, there will also be significant traffic impacts and safety issues.
According to the developer’s Traffic Impact Analysis (TIA):
“The northbound I-5 interchange ramp intersection at Old Fairhaven Parkway (SR 11) will require major intersection improvements to obtain acceptable WSDOT level of service standards. The State has recommended these improvements for the northbound ramp intersection in its Fairhaven to Slater Interstate 5 Master Plan, (November 2008).
The developer has committed to funding 100% of the cost of installation of a traffic light here. This should be clearly incorporated into the formal rezone request.
All traffic leaving the development will approach the 34th Street/Connelly intersection from the south. According to the TIA, at full build-out there will be an average of 4,332 trips per day from the development, which during PM peak hour will degrade the Level of Service at this intersection to E or F. This gives rise to safety problems as drivers get impatient to make their turns onto Connelly. The city has declined to mitigate this intersection due to the status of Connelly as an arterial. The safety problems will remain.
There are also concerns about the traffic impact on 34th Street and 36th Street heading north from their Connelly intersections. The TIA estimates 5% of the 4,332 trips per day, or about 215 trips, will travel on each of these two residential streets. Neither street was constructed in a way that will adequately accommodate this extra traffic load. This will make driving, walking, and biking on both streets more hazardous. The Samish Neighborhood Plan (p 12) already identifies 36th Street as an area of concern.
The proposed development will also exacerbate the already dangerous conditions at the I-5 northbound Samish Way off-ramp. The TIA predicts that this will fail by 2023; the increased traffic will only hasten this failure.
6. It will not be materially detrimental to uses or property in the immediate vicinity of the subject property; and
The development will be ”materially detrimental” to all the property in the immediate vicinity due to the strain it will place on the existing traffic infrastructure and corresponding residential traffic.
7. It is appropriate because either:
a. Conditions in the immediate vicinity have changed sufficiently since the property was classified under the current zoning that a rezone is in the public interest; or
b. The rezone will correct a zone classification or zone boundary that was inappropriate when established; or
c. The rezone will implement the policies of the Comprehensive Plan.
Conditions in the area have changed, but it has been for the worse since the property’s previous zoning and preliminary plat were approved. Mitigation has been attempted such as installing sidewalks on Old Fairhaven Parkway and speed humps on 34th and 36th streets. Traffic in the immediate vicinity, however, has increased 50% in some areas since the last traffic study was completed in 2006. A multi-family residential development with no means for buses to access and egress the area will only compound the traffic problems in the area.
In summary, this rezone request will allow much higher densities in an area that does not have the public facilities, fire and police services or infrastructure to support these densities and is located in an area that was not identified in the Samish Neighborhood Plan as appropriate for this zoning. Moreover, this rezone request does not correct an inappropriate zone classification or zone boundary. We therefore strongly recommend that this rezone request be denied.
Submitted on behalf of the SNA Board of Directors and residents in the Samish neighborhood area.
Joseph Carpenter, President
Samish Neighborhood Association
cc: Jeff Thomas, Director, Bellingham Planning and Community Development Department
Kathy Bell, Planner II, Bellingham Planning and Community Development Department
City Council, city of Bellingham
George Huston, Padden Trails, LLC
Samish Neighborhood Association Board of Directors
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