CITY OF SEATTLE

ANALYSIS AND DECISION OF THE DIRECTOR OF

THE SEATTLE DEPARTMENT OF CONSTRUCTION AND INSPECTIONS

Record Number: 3029687-LU

Applicant Name: John Faley

Address of Proposal: 728 21st Ave

SUMMARY OF PROPOSED ACTION

Land Use Application to allow a new 2-story gymnasium with below grade parking for 237
vehicles (Holy Names Academy). An additional 32 parking spaces to be provided in a new
surface parking lot, 12 existing spaces to be removed for a total of 296 parking spaces. Review
includes partial demolition of existing gymnasium.

The following approvals are required:

Administrative Conditional Use (Seattle Municipal Code Chapter 23.42 and 23.44)

SEPA - Environmental Determination (Seattle Municipal Code Chapter 25.05)

SEPA DETERMINATION

Determination of Non-significance:

No mitigating conditions of approval are imposed.

Pursuant to SEPA substantive authority provided in SMC 25.05.660, the proposal has
been conditioned to mitigate environmental impacts

SITE AND VICINITY

Site Zone: Single-Family 5000

Vicinity Zoning: North: SF 5000

East: SF 5000
South: SF 5000
West: SF 5000

Environmental Critical Areas: None.

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Site Description: The site is a full block, bounded by
E Aloha Street to the north, 22nd Avenue E to the
east, E Roy Street to the south, and 21st Avenue E to
the west. The subject property includes an existing
institution (Holy Names Academy) which includes a
main school building and gymnasium connected by a
breezeway.

Public Comment

The public comment period ended March 14, 2018.

Several comments were received and carefully
considered to the extent that they raised issues within
the scope of this review. These areas of public
comment related to construction, parking, and traffic.
The top of this image is North. This map is for illustrative
Comments were also received that are beyond the
purposes only. In the event of omissions, errors or
scope of this review and analysis. differences, the documents in SDCI's files will control.

I. ANALYSIS – ADMINISTRATIVE CONDITIONAL USE

The Land Use Code allows the expansion of existing institutions into residential zones through
the administrative conditional use process. This proposal is for a new gymnasium and parking
garage for a private school in a single-family zone. The SDCI Director has the authority to
approve, condition or deny a conditional use application. This decision shall be based on
whether the proposed use will be materially detrimental to the public welfare or injurious to
property. The applicable criteria used for evaluating and or conditioning the applicant’s proposal
are discussed below.

23.44.018 – General provisions

A. Only those conditional uses identified in this subchapter may be authorized as conditional
uses in single-family zones. The Master Use Permit Process set forth in Chapter 23.76,
Procedures for Master Use Permits and Council Land Use Decisions, shall be used to authorize
conditional uses.

Private schools are listed as a permitted conditional use in single-family zones. The Master Use
Permit procedures of SMC 23.76 are being used to analyze the proposal.

B. Unless otherwise specified in this subchapter, conditional uses shall meet the development
standards for uses permitted outright in Sections 23.44.008 through 23.44.016.

The proposal is not requesting modifications to development standards through the provisions in
this subsection. Unless otherwise specified, the proposal meets the applicable development
standards for uses permitted outright in SMC 23.44.008 through 23.44.016.

C. A conditional use may be approved, conditioned or denied based on a determination of

whether the proposed use meets the criteria for establishing a specific conditional use and
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whether the use will be materially detrimental to the public welfare or injurious to property in
the zone or vicinity in which the property is located.

The proposal is to construct a new below grade parking garage and gymnasium. The parking
garage will allow students, faculty, and staff to park on-site and reduce the impact of on-street
parking in the neighborhood.

D. In authorizing a conditional use, the Director or Council may mitigate adverse negative
impacts by imposing requirements or conditions deemed necessary for the protection of other
properties in the zone or vicinity in which the property is located.

Existing landscaping and proposed setbacks mitigate potential adverse negative impacts to
adjacent properties in the zone and vicinity. Additional analysis is provided in the discussion of
criteria pursuant to SMC 23.44.022.

E. Any use which was previously authorized by a conditional use permit but which has been
discontinued shall not be reestablished or recommenced except pursuant to a new conditional
use permit, provided that such permit is required for the use at the time re-establishment or
recommencement is proposed. The following shall constitute conclusive evidence that the
conditional use has been discontinued:
1. A permit to change the use of the property has been issued and the new use has been
established; or
2. The property has not been devoted to the authorized conditional use for more than
twenty-four (24) consecutive months.

Property which is vacant, except for dead storage of materials or equipment of the conditional
use, shall not be considered as being devoted to the authorized conditional use. The expiration of
licenses necessary for the conditional use shall be evidence that the property is not being
devoted to the conditional use. A conditional use in a multifamily structure or a multitenant
commercial structure shall not be considered as discontinued unless all units are either vacant
or devoted to another use.

The existing use of the institution has not been discontinued, and no re-establishment is
necessary. No vacant property is part of the subject site.

F. Minor structural work that does not increase usable floor area or seating capacity and that
does not exceed the development standards applicable to the use shall not be considered an
expansion and does not require approval as a conditional use, unless the work would exceed the
height limit of the zone for uses permitted outright. Such work includes but is not limited to roof
repair or replacement and construction of uncovered decks and porches, facilities for barrier-
free access, bay windows, dormers, and eaves.

The proposal is not for minor structural work and is seeking approval as a conditional use.

23.44.022 – Institutions

E. Dispersion

1. The lot line of any proposed new or expanding institution, other than child care centers
locating in legally established institutions, shall be located six hundred feet (600’) or
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more from any lot line of any other institution in a residential zone, with the following
exceptions:
a. An institution may expand even though it is within six hundred (600) feet of a
public school if the public school is constructed on a new site subsequent to
December 12, 1985.
b. A proposed institution may be located less than six hundred (600) feet from a lot
line of another institution if the Director determines that the intent of the
dispersion criteria is achieved due to the presence of physical elements such as
bodies of water, large open spaces or topographical breaks or other elements
such as arterials, freeways or nonresidential uses, which provide substantial
separation from other institutions.

The proposal is not considered an expansion of an institution for purposes of SMC 23.44.022.E
because the boundaries of the institution are not changing.

2. A proposed child-care center serving not more than twenty-five (25) children which does
not meet the criteria of subsection E1 of this section may be permitted to locate less than
six hundred (600) feet from a lot line of another institution if the Director determines
that, together with the nearby institution(s), the proposed child care center would not:
a. Create physical scale and bulk incompatible with the surrounding neighborhood;
b. Create traffic safety hazards;
c. Create or significantly increase identified parking shortages; or
d. Significantly increase noise levels to the detriment of surrounding residents.

No childcare is proposed with this application.

F. Demolition of Residential Structures. No residential structure shall be demolished nor

shall its use be changed to provide for parking. This prohibition may be waived if the demolition
or change of use proposed is necessary to meet the parking requirements of this Land Use Code
and if alternative locations would have greater noise, odor, light and glare or traffic impacts on
surrounding property in residential use. If the demolition or change of use is proposed for
required parking, the Director may consider waiver of parking requirements in order to preserve
the residential structure and/or use. The waiver may include, but is not limited to, a reduction in
the number of required parking spaces and a waiver of parking development standards such as
location or screening.

No demolition of residential structures is proposed.

G. Reuse of Existing Structures. Existing structures may be converted to institution use if the
yard requirements for institutions are met. Existing structures which do not meet these yard
requirements may be permitted to convert to institution use, provided that the Director may
require additional mitigating measures to reduce impacts of the proposed use on surrounding
properties.

The proposal does not include the conversion of existing structures to institution use.

H. Noise and Odors

For the purpose of reducing potential noise and odor impacts, the Director shall consider the
location on the lot of the proposed institution, on-site parking, outdoor recreational area, trash
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and refuse storage areas, ventilating mechanisms, sport facilities, and other noise generating
and odor-generating equipment, fixtures or facilities. The institution shall be designed and
operated in compliance with the Noise Ordinance, Chapter 25.08.

The new parking garage would be located below grade and includes ventilation fans that may
generate additional noise. The mechanical and ventilation system for the gymnasium will be
replaced, and it is not expected that the new units will have any noticeable difference in noise.
All mechanical and ventilations systems will comply with the Noise Ordinance.

The new gymnasium would not change the types, sizes, or frequencies of events that are held at
the existing gym. Therefore, noise generated from these events is expected to be similar as it
exists today. It is not anticipated that there will be any new odors as a result of this proposal. The
location of the trash and refuse area is proposed to be relocated within the same parking lot and
anticipated to be similar to existing conditions.

There is no indication that the proposal would include adverse noise or odor impacts that would
warrant mitigation with this administrative conditional use.

I. Landscaping

1. The Director shall promulgate rules to foster the long-term health, viability, and
coverage of plantings. The rules shall address, at a minimum, the type and size of plants,
spacing of plants, use of drought-tolerant plants, and access to light and air for plants.
All landscaping provided to meet the requirements of this Section 23.44.022 shall comply
with these rules.

2. Landscaping that achieves a Green Factor score of 0.3 or greater, pursuant to Section
23.86.019, is required for any lot with:
a. development containing more than four new dwelling units;
b. development, either a new structure or an addition to an existing structure, containing
more than 4,000 new square feet of non-residential uses; or
c. any parking lot containing more than 20 new parking spaces for automobiles.

This site contains existing vegetation along all of the property lines, including several large trees
and established shrubs that screen the parking lots. The new gymnasium includes landscaping to
replace existing parking areas. The existing and proposed landscaping work to screen and filter
views from the adjacent sidewalks and residences in the immediate vicinity.

J. Light and Glare. Exterior lighting shall be shielded or directed away from adjacent
residentially zoned lots. The Director may also require that the area and intensity of
illumination, the location or angle of illumination be limited.

All building mounted illumination will be directed away from neighboring buildings and fully
shielded to limit glare. Timers will control lighting to shut off in the late evening hours. Exterior
glare will be mitigated though the use of existing and supplemental planting, and non-reflective
surfaces. No additional mitigation is warranted given the location of the proposed lighting,
limited use of the lighting, existing vegetative screening, shielding of lights, and use of non-
reflective surfaces.
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K. Bulk and Siting

1. Lot Area. If the proposed site is more than one acre in size, the Director may require the
following and similar development standards:

a. For lots with unusual configuration or uneven boundaries, the proposed principal
structures be located so that changes in potential and existing development patterns
on the block or blocks within which the institution is located are kept to a minimum.

b. For lots with large street frontage in relationship to their size, the proposed
institution reflect design and architectural features associated with adjacent
residentially-zoned block faces in order to provide continuity of the block front and to
integrate the proposed structures with residential structures and uses in the
immediate area.

The proposal is not changing the existing school structure and the new gymnasium would occupy
a similar footprint to the existing gymnasium on the site. The site is larger than one acre in size
and has a large street frontage in relationship to the lot size. The design of the new gymnasium
utilizes articulation, perimeter modulations, and cornices to minimize the bulk and massing. No
additional mitigation is warranted given the design and location of the proposal.

2. Yards. Yards of institutions shall be as required for uses permitted outright in Section
23.44.014, provided that no such structure other than freestanding walls fences,
bulkheads or similar structures shall be closer than ten feet (10’) to the side lot line. If
the Director finds that a reduced setback will not significantly increase project impacts,
including but not limited to noise, odor, and the scale of the structure in relation to
nearby buildings, the sideyard setback may be reduced to 5 feet. Fences and freestanding
walls of utility services uses, regulated under this Section 23.44.022 pursuant to Section
23.51A.002, shall be set back from the street lot line a minimum of 10 feet, and
landscaping shall be provided between the fence or wall and the right-of-way. The
Director may reduce this setback after finding that the reduced setback will not
significantly increase project impacts, including but not limited to noise, odor, and the
scale of the fence, wall, or structure in relation to nearby buildings. Acceptable methods
to reduce fence or wall impacts include changes in the height, design or construction of
the fence or wall, including the use of materials, architectural detailing, artwork,
vegetated trellises, decorative fencing, or similar features to provide visual interest
facing the street lot line. Fences and walls may obstruct or allow views to the interior of
a site. Where site dimensions and conditions allow, applicants are encouraged to provide
both a landscaped setback between the fence or wall and the right-of-way, and a fence or
wall that provides visual interest facing the street lot line, through the height, design or
construction of the fence or wall, including the use of materials, architectural detailing,
artwork, vegetated trellises, decorative fencing, or similar features.

The proposal would meet yard requirements.

3. Institutions Located on Lots in More Than One (1) Zone Classification. For lots which
include more than one (1) zone classification, single-family zone provisions shall apply
only to the single-family-zoned lot area involved.
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The institution does not include more than one zone classification.

4. Height Limit
a. Religious symbols for religious institutions may extend an additional twenty-five
(25) feet above the height limit.

No new religious symbols are proposed above the height limit.

b. For gymnasiums and auditoriums that are accessory to an institution the

maximum height shall be thirty-five (35) feet if portions of the structure above
thirty-five (35) feet are set back at least twenty (20) feet from all property lines.
Pitched roofs on a gymnasium or auditorium which have a slope of not less than
four to twelve (4:12) may extend ten (10) feet above the thirty-five (35) foot height
limit. No portion of a shed roof on a gymnasium or an auditorium shall be
permitted to extend beyond the thirty-five (35) foot height limit under this
provision.

The proposed gymnasium structure would not exceed a maximum height of 35 feet. Rooftop
solar collectors are proposed to exceed this height limit as allowed by SMC 23.44.046. The solar
collectors are set back at least 20 feet from all property lines.

5. Façade Scale. If any façade of a new or expanding institution exceeds thirty feet (30’) in
length, the Director may require that facades adjacent to the street or a residentially
zoned lot be developed with design features intended to minimize the appearance of the
bulk. Design features which may be required include, but are not limited to, modulation,
architectural features, landscaping or increased yards.

The façades of the gymnasium feature a substantial amount of glazing and architectural features
that break down the length of façades adjacent to the street. Cornices at the first and second
stories demarcate the floors and break down the overall bulk of the building. The existing and
proposed landscaping further minimizes the size and scale of the new gymnasium.

L. Parking and Loading Berth Requirements.

1. Quantity and Location of Off-street Parking.

a. Use of transportation modes such as public transit, vanpools, carpools and
bicycles to reduce the use of single-occupancy vehicles is encouraged.
b. Parking and loading is required as provided in Section 23.54.015.
c. The Director may modify the parking and loading requirements of Section
23.54.015 and the requirements of Section 23.44.016 on a case-by-case basis
using the information contained in the transportation plan prepared pursuant to
subsection 23.44.022.M. The modification shall be based on adopted City policies
and shall:
1) Provide a demonstrable public benefit such as, but not limited to,
reduction of traffic on residential streets, preservation of residential
structures, and reduction of noise, odor, light and glare; and
2) Not cause undue traffic through residential streets nor create a safety
hazard.
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A total of 296 vehicle parking spaces are included in the proposal and would accommodate
typical school day parking demand from students, faculty, staff, and visitors. Bicycle parking is
also being provided. Some events could be expected to generate parking demand that exceeds
the available capacity of the proposed parking garage and surface lots, but any spillover
parking demand from these events would be less than experienced under existing conditions.

Pick-up and drop-off of students would occur in the northeast surface lot, similar to existing
operations. No modifications to the parking or loading requirements are requested as part of
this conditional use approval.

2. Parking Design. Parking access and parking shall be designed as provided in Design
Standards for Access and Off-street Parking, Chapter 23.54.
3. Loading Berths. The quantity and design of loading berths shall be as provided in
Design Standards for Access and Off-street Parking, Chapter 23.54.

Parking and loading spaces are designed to meet applicable standards.

M. Transportation Plan. A transportation plan shall be required for proposed new

institutions and for those institutions proposing expansions which are larger than four thousand
(4,000) square feet of the structure area and/or required to provide twenty (20) or more spaces.

The traffic studies submitted by the applicant (Transportation Technical Report for the Holy
Names Academy Parking Garage & Gymnasium by Heffron Transportation dated January 22,
2018; Revised Transportation Technical Report for the Holy Names Academy Parking Garage &
Gymnasium by Heffron Transportation dated June 20, 2018; and the memorandum titled
Responses to SDCI and SDOT Comments by Heffron Transportation dated June 20, 2018)
disclose the probable impacts of the proposal on traffic, parking, and safety. The studies include
measures to be taken by the applicant to help the school manage its traffic and parking.

23.42.042 – Conditional uses

In authorizing a conditional use, the Director or City Council may impose conditions to mitigate
adverse impacts on the public interest and other properties in the zone or vicinity.

The Director may deny or recommend denial of a conditional use if the Director determines that
adverse impacts cannot be mitigated satisfactorily, or that the proposed use is materially
detrimental to the public welfare or injurious to property in the zone or vicinity in which the
property is located.

Conclusion

The general provisions for conditional uses in single-family zones require a finding of whether
the use will be materially detrimental to the public welfare or injurious to property in the zone or
vicinity (Section 23.44.018C). The uses that are proposed, together with the design and
landscaping elements to integrate the new building with the surroundings, will not be materially
detrimental or injurious.

DECISION – ADMINISTRATIVE CONDITIONAL USE

The conditional use application is Approved.

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II. ANALYSIS – SEPA

Environmental review resulting in a Threshold Determination is required pursuant to the State

Environmental Policy Act (SEPA), WAC 197-11, and the Seattle SEPA Ordinance (Seattle
Municipal Code (SMC) Chapter 25.05).

The initial disclosure of the potential impacts from this project was made in the environmental
checklist submitted by the applicant dated Click here to enter a date.. The Seattle Department of
Construction and Inspections (SDCI) has annotated the environmental checklist submitted by the
project applicant; reviewed the project plans and any additional information in the project file
submitted by the applicant or agents; and any pertinent comments which may have been received
regarding this proposed action have been considered. The information in the checklist, the
supplemental information, and the experience of the lead agency with the review of similar
projects form the basis for this analysis and decision.

The SEPA Overview Policy (SMC 25.05.665 D) clarifies the relationship between codes,
policies, and environmental review. Specific policies for each element of the environment, and
certain neighborhood plans and other policies explicitly referenced may serve as the basis for
exercising substantive SEPA authority. The Overview Policy states in part: "where City
regulations have been adopted to address an environmental impact, it shall be presumed that
such regulations are adequate to achieve sufficient mitigation" subject to some limitations.

Under such limitations/circumstances, mitigation can be considered. Thus, a more detailed

discussion of some of the impacts is appropriate.

Short Term Impacts

Construction activities could result in the following adverse impacts: construction dust and storm
water runoff, erosion, emissions from construction machinery and vehicles, increased particulate
levels, increased noise levels, occasional disruption of adjacent vehicular and pedestrian traffic, a
small increase in traffic and parking impacts due to construction related vehicles, and increases
in greenhouse gas emissions. Several construction-related impacts are mitigated by existing City
codes and ordinances applicable to the project such as: the Stormwater Code (SMC 22.800-808),
the Grading Code (SMC 22.170), the Street Use Ordinance (SMC Title 15), the Seattle Building
Code, and the Noise Control Ordinance (SMC 25.08). Puget Sound Clean Air Agency
regulations require control of fugitive dust to protect air quality. The following analyzes
construction-related noise, air quality, greenhouse gas, construction traffic and parking impacts,
as well as mitigation.

Greenhouse Gas Emissions

Construction activities including construction worker commutes, truck trips, the operation of
construction equipment and machinery, and the manufacture of the construction materials
themselves result in increases in carbon dioxide and other greenhouse gas emissions which
adversely impact air quality and contribute to climate change and global warming. While these
impacts are adverse, no further mitigation is warranted pursuant to SMC 25.05.675.A.
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Construction Impacts - Parking and Traffic

Increased trip generation is expected during the proposed demolition, grading, and construction
activity. The area is subject to significant traffic congestion during peak travel times on nearby
arterials. Large trucks turning onto arterial streets would be expected to further exacerbate the
flow of traffic.

The area includes limited and timed or metered on-street parking. Additional parking demand
from construction vehicles would be expected to further exacerbate the supply of on-street
parking. It is the City's policy to minimize temporary adverse impacts associated with
construction activities.

Pursuant to SMC 25.05.675.B (Construction Impacts Policy), additional mitigation is warranted

and a Construction Management Plan is required, which will be reviewed by Seattle Department
of Transportation (SDOT). The requirements for a Construction Management Plan include a
Haul Route and a Construction Parking Plan. The submittal information and review process for
Construction Management Plans are described on the SDOT website at:
http://www.seattle.gov/transportation/cmp.htm.

Construction Impacts - Noise

The project is expected to generate loud noise during demolition, grading and construction.
The Seattle Noise Ordinance (SMC 25.08.425) permits increases in permissible sound levels
associated with private development construction and equipment between the hours of 7:00 AM
and 10:00 PM on weekdays and 9:00 AM and 10:00 PM on weekends and legal holidays.

If extended construction hours are needed to an emergency, the applicant may seek approval
from SDCI through a Noise Variance request. The applicant’s environmental checklist does not
indicate that extended hours are anticipated.

A Construction Management Plan will be required prior to issuance of the first building permit,
including contact information in the event of complaints about construction noise, and measures
to reduce or prevent noise impacts. The submittal information and review process for
Construction Management Plans are described on the SDOT website at:
http://www.seattle.gov/transportation/cmp.htm. The limitations stipulated in the Noise
Ordinance and the CMP are sufficient to mitigate noise impacts; therefore no additional SEPA
conditioning is necessary to mitigation noise impacts per SMC 25.05.675.B.

Environmental Health

Should asbestos be identified on the site, it must be removed in accordance with the Puget Sound
Clean Air Agency (PSCAA) and City requirements. PSCAA regulations require control of
fugitive dust to protect air quality and require permits for removal of asbestos during demolition.
The City acknowledges PSCAA’s jurisdiction and requirements for remediation will mitigate
impacts associated with any contamination. No further mitigation under SEPA Policies
25.05.675.F is warranted for asbestos impacts.

Should lead be identified on the site, there is a potential for impacts to environmental health. Lead
is a pollutant regulated by laws administered by the U. S. Environmental Protection Agency (EPA),
including the Toxic Substances Control Act (TSCA), Residential Lead-Based Paint Hazard
Reduction Act of 1992 (Title X), Clean Air Act (CAA), Clean Water Act (CWA), Safe Drinking
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Water Act (SDWA), Resource Conservation and Recovery Act (RCRA), and Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) among others. The EPA
further authorized the Washington State Department of Commerce to administer two regulatory
programs in Washington State: the Renovation, Repair and Painting Program (RRP) and the Lead-
Based Paint Activities Program (Abatement). These regulations protect the public from hazards
of improperly conducted lead-based paint activities and renovations. No further mitigation under
SEPA Policies 25.05.675.F is warranted for lead impacts.

Long Term Impacts

Long-term or use-related impacts are also anticipated as a result of approval of this proposal
including: greenhouse gas emissions; parking; potential blockage of designated sites from the
Scenic Routes nearby; possible increased traffic in the area. Compliance with applicable codes
and ordinances is adequate to achieve sufficient mitigation of most long-term impacts and no
further conditioning is warranted by SEPA policies. However, greenhouse gas, historic
resources, height bulk and scale, parking, trees, and traffic warrant further analysis.

Greenhouse Gas Emissions

Operational activities, primarily vehicular trips associated with the project’s energy
consumption, are expected to result in increases in carbon dioxide and other greenhouse gas
emissions which adversely impact air quality and contribute to climate change and global
warming. While these impacts are adverse, no further mitigation is warranted pursuant to SMC
25.05.675.A.

Historic Preservation

The gymnasium proposed to be demolished is not more than 50 years old. No additional
mitigation is warranted per SMC 25.05.675.H.

Height, Bulk, and Scale

Section 25.05.675.G describes SEPA policies for height, bulk, and scale. The proposal was not
subject to design review. The site is not on the edge of another zone. The design of the new
gymnasium utilizes articulation, perimeter modulations, and cornices to minimize the bulk and
massing.

Per the Overview policies in SMC 25.05.665.D, the existing City Codes and regulations to
mitigate impacts to height bulk and scale are presumed to be sufficient, and additional mitigation
is not warranted under SMC 25.05.675.G.

Parking

The proposed development includes 296 off-street vehicular parking spaces, for a net addition of
257 spaces. The traffic and parking studies submitted by the applicant (Transportation Technical
Report for the Holy Names Academy Parking Garage & Gymnasium dated January 22, 2018;
Revised Transportation Technical Report for the Holy Names Academy Parking Garage &
Gymnasium dated June 20, 2018; and the memorandum titled Responses to SDCI and SDOT
Comments dated June 20, 2018; all by Heffron Transportation) indicate a peak demand for
approximately 249 vehicles on a typical school day. The parking supplied would accommodate
the average peak school demand.
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The parking analysis also provides an estimate of evening parking demand during school events,
such as concerts, sports practices and games, and open houses. The proposed project is not
anticipated to change the type, size, or frequency of these events, but attendees would be able to
park in the new garage and thus reduce on-street parking spillover during large events. No
additional mitigation is warranted per SMC 25.05.675.M.

Plants and Animals

Mature vegetation is located on the site, including five Exceptional Trees. The applicant
submitted three arborist reports, which are on file with SDCI, and identified the Exceptional
Trees on the MUP plan set. SDCI’s Arborist has reviewed the information.

The proposal includes retention of the Exceptional Trees. In order to mitigate impacts to the
Exceptional Trees under SMC 25.05.675.N, the applicant proposes tree protection measures in
the arborist reports submitted (Bigleaf Maple Tree Risk Assessment dated November 1, 2017;
Bigleaf Maple Tree – Proposed Construction and Root Impacts; Proposed Construction and Root
Impacts dated December 14, 2017; Limits of Disturbance for Three Trees dated January 8, 2018;
all by Greenforest Inc.) and MUP plan set. No additional mitigation is warranted per SMC
25.05.675.N.

Transportation

The traffic studies submitted by the applicant indicate that the school generates approximately
575 morning peak hour trips, 257 afternoon peak hours trips and 131 evening peak hour trips.
The transportation analysis reviewed operations at five intersections to measure the impact of
vehicle trips that would shift to the on-site parking garage and its access driveways. While the
shifts in trip routing would have an impact on levels of service (LOS) at nearby intersections, it
is not anticipated to be significant. The traffic study found levels of service at the study
intersections are projected to be LOS D or better during all peak hours. Concurrency analysis
was conducted for nearby identified areas. That analysis showed that the project is expected to be
well within the adopted standards for the identified areas. No further mitigation is warranted per
SMC 25.05.675.R.

DECISION – SEPA

This decision was made after review by the responsible official on behalf of the lead agency of a
completed environmental checklist and other information on file with the responsible
department. This constitutes the Threshold Determination and form. The intent of this
declaration is to satisfy the requirement of the State Environmental Policy Act (RCW 43.21.C),
including the requirement to inform the public of agency decisions pursuant to SEPA.

Determination of Non-Significance. This proposal has been determined to not have a

significant adverse impact upon the environment. An EIS is not required under RCW
43.21.030(2) (c).

The lead agency for this proposal has determined that it does not have a probable significant
adverse impact on the environment. An environmental impact statement (EIS) is not required
under RCW 43.21C.030 (2)(c). This decision was made after review of a completed
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environmental checklist and other information on file with the lead agency. This information is
available to the public on request.

This DNS is issued after using the optional DNS process in WAC 197-11-355 and Early review
DNS process in SMC 25.05.355. There is no further comment period on the DNS.

CONDITIONS – ADMINISTRATIVE CONDITIONAL USE

None.

CONDITIONS – SEPA

Prior to Issuance of Demolition, Excavation/Shoring, or Construction Permit

1. Provide a Construction Management Plan that has been approved by SDOT. The submittal
information and review process for Construction Management Plans are described on the
SDOT website at: http://www.seattle.gov/transportation/cmp.htm.

Michael Houston, AICP, Land Use Planner Date: November 29, 2018
Seattle Department of Construction and Inspections
MH:rgc
3029687-LU.docx

IMPORTANT INFORMATION FOR ISSUANCE OF YOUR MASTER USE PERMIT

Master Use Permit Expiration and Issuance
The appealable land use decision on your Master Use Permit (MUP) application has now been published. At the
conclusion of the appeal period, your permit will be considered “approved for issuance”. (If your decision is appealed,
your permit will be considered “approved for issuance” on the fourth day following the City Hearing Examiner’s
decision.) Projects requiring a Council land use action shall be considered “approved for issuance” following the
Council’s decision.
The “approved for issuance” date marks the beginning of the three year life of the MUP approval, whether or not
there are outstanding corrections to be made or pre-issuance conditions to be met. The permit must be issued by SDCI
within that three years or it will expire and be cancelled (SMC 23-76-028). (Projects with a shoreline component have
a two year life. Additional information regarding the effective date of shoreline permits may be found at 23.60.074.)
All outstanding corrections must be made, any pre-issuance conditions met and all outstanding fees paid before the
permit is issued. You will be notified when your permit has issued.
Questions regarding the issuance and expiration of your permit may be addressed to the Public Resource Center at
prc@seattle.gov or to our message line at 206-684-8467.
Dec 11, 2018

To: City of Seattle

Office of Hearing Examiner
PO Box 94729
Seattle, WA 98124-4729

We hereby appeal the City decision to grant Holy Names a green light to build a multi-story large commercial size
parking lot in the center of a quaint and historic residential neighborhood and to destroy a beautiful historic park
on the North side of its premises which has been used by the neighborhood for years as a green space. This appeal
is filed on behalf of the undersigned names, and on behalf of the more than 100 families who reside in the im-
mediate vicinity of the school and who signed a written petition in opposition to the project, voicing their strong
disapproval of the school’s plans to build an oversized parking lot and to destroy the green space on the north
side of the school. We are extremely disappointed with the City’s decision but are perhaps more disappointed
with Holy Names. We were hoping that someone would do the right thing and consider the historical and envi-
ronmental impact this project will have on our neighborhood, as well as the input from the immediate neighbors
who are overwhelmingly opposed to these retrograde plans. But in the end, money speaks volumes and the school
apparently intends to proceed as if the neighbors do not exist and are not worthy of listening to. As surprising as
it is, that has been their plain message which has not been lost on any of us.

Liz Swift, Head of School, was quoted in a recent publication as saying “As a long-time steward of this community,
we look forward to continuing our collaboration with neighbors, students, families, alumnae and other stakeholders as this critical and
sustainable school-improvement project moves through construction.”
Really? Collaborating? As for neighbors, we know of zero collaboration in response to the petition. In April
2018, we submitted to the school a petition which was signed by over 100 families in the immediate vicinity of the
school, including many long-time neighbors, who spoke with a clear and unified voice as follows:

Petition summary and background

We, being good neighbors of Holy Names Academy, earnestly oppose the present planned construction of a
multi-level parking garage on the site and the erasure of the beautiful park on the north side of the school, which
is deeply valued green space. We believe both proposals are inimical to our neighborhood.

Action petitioned for

We believe the plans will introduce additional vehicle traffic to our area, will result in additional congestion, are
over scale, will be a blight, especially on the north end of the property where the cherished, revered, and historic
park will be paved with a parking lot, will cause unwanted noise and lighting on adjacent homes, will bring nox-
ious fumes and construction and wreak havoc in the adjacent area during and after a lengthy period of construc-
tion, and is plainly contrary to environmentally conscious policy of encouraging less driving, not more. We, the
undersigned, oppose the current plans and wish our voices to be heard and respected. If the school cares about
the neighbors as it professes, we ask that its current plans be reconsidered, that additional inclusive discussion be
held, and that rational alternatives be pursued.

This petition reflected a lot of thought by the neighbors. The signatures were collected by no less than 10 people.
We walked from the school outwards, covering those streets contiguous to the school, and fanning out to north
Capitol Hill and south. Most of the signees are long-time residents. We stopped at 125 signees as that seemed a
sufficient enough sampling. We found over 90% support for the Petition of those we encountered.

The school’s reaction to the Petition was to fully ignore it. To pretend it did not exist. There was zero effort to
engage with the neighbors over their concerns set forth in the Petition. We were simply ignored so that the school
can proceed with its plans to black top a beautiful park and create a vast underground parking area so that people
can begin driving to the school and parking their vehicles in far greater number than before and on weekends.
This is common sense and the school knows it.
For years, there has been a balance of mutual respect and benevolence between the school and those who surround
it. This has helped the school succeed. It has been a positive and affirming force. The current plans destroy that
balance with the community. There has been zero genuine effort to discuss these issues or to compromise in any
way. We believe that was a real mistake. Rather than search for a compromise that might have been acceptable to
all, the school just does not care about the neighbors, or their genuine concern for the environmental impact of
the project. And we do not mean whether or not you receive a green “go” pass from the city. You are a school.
You are entrusted with education. Building a parking lot to encourage driving, which is what you are doing, is
plainly counter to considerations of greenhouse gases, and will just throw Holy Names’ divine weight behind the
further destruction of our environment. This will be clear to your students in years to come. We believe they will
see this project as a mistake as well. They will see what was done to their environment, and the many missed op-
portunities there were to each for other alternatives. Their own green space will be gone. Once you eliminate the
park that has been here since 1906, it will be gone forever. This should matter. Voices matter.

What happens when others feel unheard, unvalued, and disregarded, is quite negative, and should be no surprise.
We oppose the current plans. We think they are ill-conceived. We have been wholly ignored, but our voices will
continue and should the school proceed in this manner, it can expect the neighbors to continue to protest the
activity in the many means that are available in a public space and where there are students as well as others who
are capable of understanding.

Accordingly, we ask that the matter be further considered, that there be a greater search for common ground, and
that actions are undertaken which will mend rather than portend to further disruption of the relationship be-
tween the school and its neighbors. We believe this matter will only become increasingly disruptive and divisive if
the matter proceeds on its current path.

As for the city, we specifically appeal the decision that: “The city has determined there will be no probable signif-
icant adverse environmental impacts from this proposal.” This conclusion is bereft of facts and makes no sense
to us. When the school embarked upon a far more limited expansion quite recently, all of the neighborhood
homes surrounding the school shook during the construction and the homes were impacted. This is a far more
massive project. Far out of scale and beyond what the Bush School did and beyond what University Prep did to
address parking challenges. A 5-story underground garage is a massive undertaking that will unearth ground and
disturb the adjacent homes in a far more profound level. Massive pick-up trucks will transport dirt out using
our old streets. This is significant impact. In addition, there will be long-term impact as we believe the plans
will undoubtedly introduce additional vehicle traffic to our area and will result in additional congestion. We do
not understand how you could have reached an opposite conclusion, since it is common sense that “if you build
it, they will come”. In addition, we believe the construction will result in a blight, especially on the north end of
the property where the historic park will be paved with a parking lot. We believe all of this is plainly contrary to
environmentally conscious policy of encouraging less driving, not more. Seattle talks about wanting less cars, and
encouraging people to walk, take the bus, etc. As for the City’s mission statement, we only wish this were true:
"As stewards and regulators of land and buildings, we preserve and enhance the equity, livability, safety and health
in our communities."

We remain vehemently opposed to these plans and will continue to resist them as we believe we are duty-bound to
do as stewards of the neighborhood.

Merry Christmas.

Shannon Martin
Bill Gildea
Pat Griswold
Kate Pollock
Josh Pollock
Ron Friedman
Lili Sacks
Carol Hannum
Aze Hannum
Tim Anstey
Liz Nichols
 Pet±i_ion summary and We, being good neighbors of Holy Names Academy, earnestly oppose the present planned construeion of a multi-level
background ~ parking garage on the site and the erasure of the beautiful park on the north side of the school, which is deeply valued
', green space. We_believe both proposals are inimical to our neighborhood.
P,ction petitioned for We believe the plans will introduce additional vehicle traffic to our area, will result in additional congestion, are over scale,
will be a blight, especially on the north end of the property where the cherished,_revered, and historic park will be paved
with a parking lot, will cause unwanted noise and lighting on adjacent homes, will bring ncxio:~s fumes and construction
i and wreak havoc in the adjacent area during and after a lengthy period of construction; and is plainly contrary to
environmentally conscious policy of encouraging less driving, not more. We, the undersigned, oppose the current plans
and wish our voices to be heard and respected. If the school cares about the neighbors as it professes, we ask that its
I current plans be reconsidered, that ae~ditional inclusive discussion be held, and that rational alternatives be _pursued.

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Peti~iun summary and We, being good neighbors of Holy Narnes Academy, earnestly oppose the present planned construction of a multi-level
t~ackg:ound parking garage an the site and the e. sure of the beautiful park on the north side of the school, which is deeply val:~ed
green space. We believe both proposals are inimical to our neighborhood. ';
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property where the cherished, revered, and historic park will be paved ',
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with a parking lot, will cause unwanted noise and lighfiirg en adjacent homes, will bring noxious fumes and construction
and wreak havoc in t"e Gdjacent area during and after a lengthy period of construction, and is plainly contrary to
e~virermentaily conscious policy of ericauraging less driving, not more. We, the undersigned, oppose the current plans
and wish our voices to be heard and respected. If the school cares about the neighbors as it professes, we ask that its
c~.arrent pla ns be reconsidered, that additional inclusive discussion be held, and that rational alternatives be pursued.

I Pri~itPd Name Signature`~~; 'Address ~ ~ Date

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bacKgro~.~nd parking garage on the site and t"e ~r~3~ure of the ~~eautifui park on one north side of the school, which is deeply valued
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with a parking lot, will cruse unU~ante~~ noise and lighting on a~jacer,t homes, ~n~ill bring noxious fumes and construction
and wreak havoc in the adjacent area during and after a lengthy persod of construction, and is plainly contrary to
environmentally conscious policy of encouraging less driving, not more. We, the undersigned, oppose the current plans
and wish our voices to be heard and respected. If the school cares about the neighbors as it professes, we ask that its
current plans be reconsidered, that additional inclusive discussion be held, and that rational alternatives be pursued,

Printed (Name Sigrsature Address ~ ~ Date

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Petition summary and
backgrou~~d
Action petitioned for
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! parking garage o~; the site and the ~ra~urA of the beautiful park on the north side of the school, which is deeply valued
green space. We believe ~o~h p.~opcs~is are irimfcal to _our r?eighbonc~od. ____
We ~zlieve the plans vain introduce additional vehicle traffic to our area, will result in additional congestion, are over scale,
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with a parting lot, will cause unwanted noise and lighting on adjacert home, will br;ng noxious fumes and construction
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environmentally conscious policy of encouraging less driving, not more. We, fihe undersigned, oppose the current plans
and wish our voices to be heard and respected, If thz school cares about the neighbors as it professes, we ask that its
current plans be reconsidered, that additional inclusive discussion be held, and that rational alternatives be pursued.

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Petition summary and We, being good neighbors of Holy Narnes Academy, earnestly oppose the present planned construction of a multi-level
background parking garage on the site and the ensure of the beautiful park on the north side of the school, which is deeply valued
green space. We believe both proposals are inimical to our neighborhood.
Action petitioned for We believe the plans will introduce additional vehicle traffic to our area, will result in additional congestion, are over scale,
will be a blight, especially on the north end of the property where the cherished, revered, and historic park will be paved
with a parking lot, will cause unwante«~ noise and lighting on adjacent homes, will bring noxious fumes and construction
and wreak havoc in the adjacent area during and after a lengthy period of construction, and is plainly contrary to
environmentally conscious policy of encouraging less driving, not more. We, the undersigned, oppose the current plans
and wish our voices to be heard and respected. If the school cares about the neighbors as it professes, we ask that its
current plans be reconsidered, that additional inclusive discussion be held, and that rational alternatives be pursued.

Printed Name Signature Address Date

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 Petition summary and We, being good neighbors of Holy Names Academy, earnestly oppose the present planned construction of a multi-level
, parking garage on the site and the erasure of the beautiful park on the north side of the school, which is deeply valued i
background
green space. We believe both proposals are inimical to our neighborhood.
I Action petitioned for ' We believe the plans will introduce additional vehicle traffic to our area, will result in additional congestion, are over scale,
will be a blight, especially on the north end of the property where the cherished, revered, and historic park will be paved
with a parking lot, will cause unwanted noise and lighting on adjacent homes, will bring noxious fumes and construction '~
and wreak havoc in the adjacent area during and after a lengthy period of construction, and is plainly contrary to
environmentally conscious policy of encouraging less driving, not more. We, the undersigned, oppose the current plans ~
and wish our voices to be heard and respected. If the school cares about the neighbors as it professes, we ask that its
',. current plans be reconsidered, that additional inclusive discussion be held, and that rational alternatives be pursued.

Printed Name '~, Sig ature ;~ .' ~ Address - ,' i Dato

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