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March 5, 2015

Dear Ms. Hines and Mr. Podowski:
I am writing you today, as a West Seattle resident of 15 years, to express my concern about your proposed
Director’s Rule 6-2015, Parking Reductions Based on Frequent Transit Service.
I believe that the City Council did not intend for the DPD to interpret the Land Use Code in this way, and that the
department should instead follow the Hearing Examiner’s December 1, 2014 decision. Further, the proposed rule
will unnecessarily and unjustifiably reduce parking availability as West Seattle moves towards finding ways to
make transit service more reliable, frequent, and consistent.
First, I don't believe it was the City Council’s intention to average headway times. As the Hearing Examiner
recognized, “had the Council intended that headways be averaged, it could have inserted the word ‘average’ in two
places within the definition to indicate that intent.” It did not, and as the examiner held, “neither the Director nor
the Examiner has the authority via statutory construction to add the word ‘average’ to the term ‘headway’ in the
definition of frequent transit service.” The Council has been cognizant of the need for parking as our city grows,
and allowing for parking mitigation in a neighborhood as geographically isolated and, consequently, still cardependent as West Seattle is would be unwise.
Similarly, it was not the City Council’s intention to use different routes when calculating transit service headway
times. Again, as the Hearing Examiner noted, the definition refers to the “time interval between two vehicles
traveling in the same direction on the same route.” (emphasis added). Construing the act as allowing multiple
routes is similarly incorrect.
Finally, I’d also ask you to defer to the Hearing Examiner’s correct understanding of legislative intent, as well as
the role of DPD in carrying it out. As the Hearing Examiner held, the statute is not ambiguous, and the Council did
intend to set high standards when allowing exceptions to parking impact mitigation. It is not within the scope of
DPD’s duties to redefine the parameters by which calculations are defined. The legislative branch has the authority
to define the way in which the government’s agencies act, and the land use code does this in an unambiguous way,
as the Hearing Examiner held.
This decision will have a real impact on West Seattle, and I would encourage DPD to follow the Hearing
Examiner’s December 2014 decision and adhere to the aforementioned City Council intent. With a construction
boom and an unjust drop in bus funding, the City has consistently been supportive of public transportation
measures. We should simultaneously encourage development while not burdening our communities’ residents,
many of whom have lived here with their families for decades.
I hope you will adhere to the Hearing Examiner’s findings. Thank you for your time and consideration of my letter.

Lisa Herbold
Candidate for Seattle Council District 1
Paid for by District 1 for Lisa Herbold, 2518 S. Brandon Ct., Seattle, WA 98108