May 25, 2010 Covington Planning Commission City of Covington 16720 SE 271st Street Suite 100 Covington, WA 98042 RE: Proposed

Land Use Code Changes Thank you for the opportunity to submit this letter. CollinsWoerman is the architecture firm recently engaged by MultiCare for the purposes of helping them expand the services offered on their Covington campus. To that end, we have reviewed your proposed new land use code and offer the following observations, comments and suggestions. Permitted Uses The MultiCare Covington campus was purchased and developed by the institution for the purpose of serving the community with a range of Healthcare services. For nearly twenty years, they have operated this campus for that purpose and they are now executing a 100 year building expansion of the site, expanding the scope of services available to the community dramatically. Under current zoning, the existing and proposed uses would be permitted outright. Under the new zoning these uses are conditional. This seems an unintended consequence of the new code. In many jurisdictions, Healthcare institutions have a designated zone or overlay. Seattle and Bellevue come immediately to mind. We strongly encourage you to review the applicability of applying generalized zone use criteria to sites such as MultiCare’s which have a historical specific use and provide great benefit to the community. Height Limits in the MC zone Under the current zoning ordinance the height limit for the MultiCare property is four stories or 60’. Under the proposed zoning the new height limit is proposed to be 55’. The existing building on the Covington campus is four stories. We believe the proposed new code height limit will hurt the potential to develop a hospital facility on the site. We would expect the height of a new building will be four stories; two Diagnostic and Treatment floors and two Patient Bedroom floors. Our experience suggests that D and T floors will have a floor to floor height of 16’ to 18’. Patient room floors are generally at least 14’ high. Using the most conservative numbers, a four story hospital facility on the site would be 60’ high to top of roof.


SEATTLE W A 98104-1710

T 206.245.2100

F 206.245.2101



Covington Planning Commission May 25, 2010 Page 2

We would propose that you consider a 65’ height limit on the MultiCare campus, or 65’ for intended medical uses within the City of Covington. We believe this height limit will never create an additional story for an inpatient hospital facility although it may allow a medical office building to develop five levels within 65’. Similar to your current code, you could describe both height and story limits if that served an intended purpose for which we are not yet familiar. Development Standards A final observation with respect to your proposed code is that it appears to be written for new developments, not for expansions of existing development. An example of this is the new standards for development along street frontages by type. MultiCare’s campus fronts Wax Road, a type 2 street in Covington’s definition. By standard, 50% of the frontage along Wax Road is to be building with parking behind the facility. MultiCare’s campus has 1800’ of frontage requiring a 900’ long building eliminating the existing parking. To achieve a building that length would almost certainly demand a single story solution which will immediately challenge lot coverage and impervious surface regulations. Again thank you for the opportunity to present this letter. We admire the goals and intent of your proposed land use code changes and agree with the ambitious effort in large measure. We have written this letter from the perspective of operationalizing the code and raising issues related to what we believe are unintended consequences. Thank you for your consideration. Sincerely,

Phil Giuntoli Principal cc: Hugh Kodama, Administrator – MultiCare Covington Medical Center Kristopher Kitz, Director – Strategic Planning & Business Development Tyler Paytas, Project Manager – CB Richard Ellis/MultiCare Health System

P:\Corresp\Giuntoli\Covington - Code letter_052510.docx

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