Laurelhurst Community Club                                                     

Serving 2800 Households in Seattle’s Laurelhurst Neighborhood


September 24, 2004





Councilmember Richard Conlin

Seattle City Council

11th Floor, Municipal Building

600 4th Avenue

Seattle, WA  98119


Re:       Street Vacation Policies Amendments – FOR 9/28/04 COMMITTEE MEETING


Dear Councilmember Conlin:


            We appreciate the opportunity to submit these comments on the proposed amendments to the Street Vacation Policies.  These comments are based on our experience as land use counsel for most of Seattle’s hospitals and universities over the past twenty plus years (the Major Institutions.)


            At the outset, we urge you to consider that physical adjacencies and campus consolidations are essential to operation of hospitals and universities.  For example, the physical proximity of diagnostic and treatment facilities on hospital campuses is vitally important to avoid costly duplication of medical equipment and personnel.  Most of Seattle’s hospitals and universities have consolidated the core of their campuses through property acquisitions and street/alley vacations.  However,  it will be necessary in the future to further consolidate these campuses to meet the growing demand for health care and higher education in our community.  The proposed amendments to the street vacation policies include language that would move the City even further in the direction of discouraging street and alley vacations and increasing even more the burden on the applicant to justify the proposed vacation.  We do not agree that street and alley vacations should be further discouraged on a blanket basis as proposed in these amendments.  Vacations should be considered on a case-by-case basis that takes into consideration the unique circumstances of each request.  More specifically, we urge the City to consider policy language that recognizes that large institutions such as our hospitals and universities have unique needs for physical adjacency that should be recognized in the policies.


            In addition, we respectfully request that the City consider the following revisions to the proposed policy amendments:


·        Public Trust Policies, Guideline 1.1 G regarding alleys, on p. 11:  We request that the proposed policy be revised to add a category for Major Institution Overlay that is separate from the other zones.  In this category, separate criteria should be established that are similar to the criteria for Downtown zones.  We would he happy to propose specific language.

·        Public Trust Policies, Guideline 3.8 C regarding aerial vacations, on p. 24: The proposed amendment would limit the consideration of aerial vacations to the development or expansion of public facilities or public institutions.  We believe this language is too limiting and should be deleted.  If deletion is not acceptable, we request that the statement be expanded to include non-profit institutions in addition to public institutions.  All of Seattle’s hospitals and universities are either public or non-profit entities.

·        Public Benefit Policy, Policy 5 Public Benefit:  On p. 41, the proposed amendments list those items that would not constitute public benefit.  We request that the last item be deleted (“Providing a public, governmental or educational service; while the nature of the project is a factor in determining the adequacy of a public benefit proposal, it does not in and of itself constitute an adequate public benefit.”)  The service to be provided by a public or non-profit institution as a result of a vacation should be considered part of the public benefit.  The proposed policies are internally contradictory on this point.  At pp.42- 43, the proposed policies appear to recognize that the applicant’s purpose is a factor to be considered: “The City will also consider: … Public nature of the project (library, governmental purposes, low-income housing)”.  We urge you to acknowledge the important work of the major institutions and clarify the policies on this point by deleting the statement on p. 41.


            Thank you for your consideration of these comments.


Very truly yours,


Transmitted electronically


Judith M. Runstad

Thomas M. Walsh


cc:        Councilmember Jean Godden

            Councilmember Tom Rasmussen

            Beverly Barnett, SDOT

            Major Institutions