Po. Box 1209

POrt                    Seattle, WA 98111-1209
Tel: (206) 787-3000
of seat-t Ie                                            www.portseallle.org
November 30, 2012


John Shaw, Senior Transportation Planner
City of Seattle
Dept. of Planning and Development
700 5'h Ave, Suite 2000
PO. Box 34019
Seattle, WA 98124-4019

Re:          Scopingfor the EISfor Proposed Seattle Arena, DPD project
number 3014195

Dear Mr. Shaw:

Thank you for the opportunity to provide input into the scoping process for the EIS for
the Seattle Arena. Port of Seattle seaport properties comprise the heart of the region's
maritime and industrial center. The Port has invested more than $1 billion to develop
modern shipping terminals within the Duwamish MIC to support international trade and
export Washington goods. As part of our Century Agenda strategic plan, we intend to
increase marine cargo volume to 3.5 million TEUs (twenty-foot equivalent units) and
signicantly increase the value of export cargo creating thousands ofnew jobs
throughout the region. The Port also anticipates the need to extend hours of operation of
our cargo loading / transfer activities in the area to 24/7 levels..

One of the sites under consideration is amongst critical freight corridors to the Port.  This
EIS process serves as a key step in understanding the risks ofjeopardizing the Port and
the potential cost to the family wage jobs and tax revenues supported by the seaport.
Therefore the Port of Seattle is looking forward to a thorough analysis of the impacts and
siting of this facility as well as mitigation of the impacts.

Alternatives To The Proposed SoDo Location

WAC 197-11-928 provides as follows:

When the proposal involves both private and public activities, it shall be
characterized as either a private or a public project for the purposes of
lead agency designation, depending upon whether the primary sponsor or
initiator of the project is an agency or from the private sector. Any
project in which agency and private interests are too intertwined to make
this characterization shall be considered a public project...

Mr. John Shaw                                                               Page 2
November 30, 2012

The SEPA provisions concerning the analysis of alternatives to "public projects" are
more demanding than the requirements for the consideration of alternatives to private
projects. Government agencies proposing public projects have a duty to consider off-site
alternatives to the proposal. WAC 197-11-440(5)(d); Weyerhaeuser, 124 Wn.2d at 505.
In addition, SEPA requires proposals for "public projects" to be described in terms of
objectives rather than solutions. WAC 197-11-060(3)(a)(iii).

Here, there are several reasons the City should consider more than one off-site alternative
to the SoDo location for the proposed arena independently of the proponent's preference
for the SoDo site. This has already been accepted for one alternative at Seattle Center.
However, if the goal of the analysis is to determine lower environmental impacts and
reduce public costs, evaluation of additional site(s), outside of Seattle, will be necessary.
The proposed arena is clearly a "public" project that is supported and nanced with
public resources by the taxpayers of the City of Seattle and King County.  Second,
because the arena is intended to draw spectators from across the Puget Sound region, the
EIS should consider alternative sites located outside the City of Seattle.  For these
reasons, the City should expand the consideration of alternatives to the proposal to review
more than the proposed SoDo location and the Seattle Center alternative. See
Weyerhaeuser, supra, (consideration of alternatives for proposed public landll was
inadequate under SEPA.)

Direct, Indirect, and Cumulative Environmental Impacts

Among the probable signicant adverse environmental impacts that the City should
consider are the cumulative impacts of adding this proposed basketball arena to the
tightly conned Sodo neighborhood that is already home to football and baseball arenas.
WAC 197-11-792(c)(iii)(cumulative impacts are part of the scope of impacts to be
considered in an EIS) and WAC 197-1 1-060(4)(e)(content of environmental review).
"Cumulative impacts" are typically considered to be the "past, present and reasonably
foreseeable impacts..." of a proposal. See 40 CFR  1508.7  As explained below, the
City should consider the cumulative trafc impacts of adding this high impact facility to
a neighborhood that contains the Port's critical freight corridors for movement of cargo
from ships to trucks and rail.

Trafc Analysis

The analysis should cover the transportation-related issues associated with the proposed
arena and any ancillary development, including impacts on auto, truck, bus, light and
heavy passenger rail, freight rail, pedestrian and bicycle modes.

For the permanent conguration, including both the new arena and any ancillary
development that is planned, there are several different scenarios that must be evaluated:

Mr. John Shaw                                                              Page 3
November 30, 2012

A. "Built" worst-case event scenarios, for both weekday and weekend day/evenings,
both with and without the impacts ofany permanent roadway changes resulting
from the project:

- Arena only with existing land uses




- Cumulative event analysis (combined with trafc generated by nearby trafc
generators with similar trafc pattems/event timing.)

For the SoDo location, and as appropriate, any alternative location that would
experience similar peaking characteristics, this analysis should include the
impacts of:
I   One or both existing facilities having an event/s allowed with current dual
event restrictions
I   Removal of dual event restrictions

The evaluation of these scenarios should include sensitivity analyses of the
impacts oftrafc management and police control plans (temporary closures of
surrounding roadways on event days). This should cover both the existing
scenario, where each individual event venue generates its own individual trafc
control plan, and as well as a potential area-wide trafc control plan for multiple
events. For the SoDo location, it should cover the proposed guidance for arena
patrons to approach the area from the south, rather than the I-5/1-90 interchange.
It should also contain sensitivity analyses of the projected transit mode splits and
the ability of the transportation system components to handle volumes. Also of
importance are the impacts ofpatrons arriving early for activities related to
proposed ancillary development.

B.  The project should determine specic roadway and intersections segments to be
analyzed for each proposed location, and be similar in scope to the analysis
carried out for Century Link Field. At a minimum, in order to determine the
project's impacts to Port access needs, for the SoDo location, the EIS should
analyze the following intersections:
- 1st Ave SIS Atlantic St                       - 15t Ave SIS Royal Brougham Wy



- 13' Ave SIS Mass. St                        - 15' Ave SIS Holgate St



-- 15* Ave SIS Lander St                        1st Ave SIS Spokane St



- 4'" Ave S/SR-519 Ramps                    - 49' Ave SIl-90 Off-ramp
-4"' Ave S/S Holgate Street                    --8 Atlantic St/SR-99 East Frontage Rd
-S Atlantic St/Colorado Ave/Little "h" cluster

The analysis methodology, analysis periods, and assumptions should be
developed in consultation with affected agencies, including the Washington State
Department of Transportation and Sound Transit, and for locations in the City of
Seattle, the Port of Seattle and AMTRAK prior to initiating the analysis.

Mr. John Shaw                                                              Page 4
November 30, 2012

C. All trafc analyses should cover a scenario that assumes night, and weekend gate
hours for Port of Seattle terminals and rail intermodal yards.

D. For the SoDo location, the EIS should evaluate the effect of the street vacations,
not only during event times, but also during a non-event day's morning, midday,
and aemoon peak hours. The effect on arterial operations along both 1St Avenue
S (from S Lander Street to S King Street) and SR 519 (from 1-90 to East Marginal
Way) should be evaluated.

E.  In addition to the local roadway network, the analysis should include the
operational impacts on the regional transportation system (I~5, 1-90, SR-99).

F.  The new arena is expected to be completed and in operation before some of the
major transit improvements in the region will be in operation. What is the ability
ofthe transit system and services to accommodate arena-related ridership? What
are the conicts with peak period ridership for other purposescg, patrons
attempting to reach the arena during the pm rush hour? How does the ability of
the transit system change over the years, and what are the strategies for managing
periods where gaps will exist?

G. The analysis should evaluate the impacts of additional and concurrent events on
congestion, travel time, and travel time reliability on both general freight
mobility, and, in the case of the SoDo location, on the Port's primary access
routes, including freeway, intermodal, and transload center connectors such as
Hanford St at the entrance to the Main SIG intermodal yard and Spokane St
between 1-5 and T-5 and T-18.

H. For the SoDo location, the Port of Seattle is also concerned about the potential for
conict between arena patrons and rail movements. What is the impact of train
blockages on the ability of the arena to load/unload both patrons on foot and those
using the proposed garage? How will the resulting congestion impact the area, in
particular the Port's primary access routes, including freeway, intermodal and
transload center connectors? How will the additional arena event-related vehicular
and pedestrian crossings of area railroad tracks be accommodated and what are
the potential impacts to their safety and to rail operations? What would the
impacts on emergency responders be in case of an incident? The following table
further details the Port's concerns to be addressed, and the performance measure
the EIS should use to evaluate impacts:

Mr. John Shaw                                                              Page 5
November 30, 2012

Transportation Analysis Needsfor NewArena EISFocus on 5000 location

Concern                           Performance measures to evaluate
A. Effect on regional highways    0  Net change in peak period and early afternoon travel time related to single event
(l-5 and l-90)                      and concurrent event day.
0  Net change in annual vehicle hours of delay for base and banner year conditions.

0  Variability in delay created by event trafc (a measure of system reliability)


8. Effect on primary               0  Level of service analysis for key intersections in $000 for the commuter peak
access routes to Port             hour, pre-event arrival peak, and post-event egress peak. The following intersections
terminals                        should be included in any analysis:
- 15' Ave SIS Atlantic St         -- 1st Ave SIS Royal Brougham Wy


- 1st Ave SIS Mass. St           - 1st Ave SIS Holgate St


- 1*it Ave S/S Lander St           1st Ave SIS Spokane St


- 4"1 Ave S/SR-519 Ramps        4"1 Ave S/l-90 Off-ramp
"43' Ave SIS Holgate Street      --S Atlantic StlSR-99 East Frontage Rd
--S Atlantic St/Colorado Ave/Little "h" cluster
0  Effect that rerouting event trafc to the Spokane Street \aduct would have on
access to Terminals 5 and 18 as well as to the SIG Yard.
0  Net change in delay related to single-event and concurrentevent day.

.  Net change in annual vehicle hours of delay for base and banner year conditions.

0  Variability in delay created by event trafc (a measure of system reliability)


C. Effect of street vacations      o  Peak period and early afternoon level of service analysis for key intersections listed
above to determine Net change in delay without and with the street vacations.
0  Net change in annual vehicle hours of delay for base and banner year conditions.

0  Variability in delay created by street vacation(s) and event trafc (a measure of
system reliability)

D. Safety of RR Crossings           Net change in pedestrians and vehicles crossing tracks at S Holgate Street.
Frequency and duration of train blockages at the at-grade crossings
Historic rail-vehicle and rail-pedestrian collisions in $000 (all crossings)
Safety analysis of RR crossing
Pedestrian storage needs when waiting for a train
Effect of additional queues, delays or safety issues on the potential to close S
Holgate Street during events or permanently

Parking Analysis
Even with an aggressive trafc management plan encouraging the use of transit, the
proposed arena will likely generate signicant numbers ofpersonal vehicles looking for
parking. The EIS should evaluate the availability of adequate parking, both existing and
new, within the walking shed ofthe site: Are there sufcient spaces? Are they available

Mr. John Shaw                                                              Page 6
November 30, 2012

when patrons are arriving, both immediately before an event, or early, to take advantage
of ancillary development like restaurants and pubs? What are the likely conicts with
daytime and evening use of the available spaces and existing trip generators in the area?
For the SoDo location, that should include both a dual event under the current
restrictions, and a scenario where those restrictions are removed. What is the impact of
the limitatiOns of the parking supply, and its pattern of dispersion, on both passenger and
freight trafc, other businesses, and neighborhoods in the study area? What are the
differences between weekday, weekday evening, and weekend events? The effort should
include a sensitivity analysis that evaluates impacts if likely parking guidance systems
and other means ofparking management do not achieve the projected goals.

Air Quality

The EIS must analyze issues of air quality given the large trip generation potential of a
facility of this size.  The air quality analysis must account for the inevitable trafc
congestion caused by adding such facility to an already constrained street network. A
great deal of the fan base can be expected to live outside of the City of Seattle. Therefore
air quality should be analyzed within the framework of the City's goal ofbeing carbon
neutral.

Construction

Depending on the timing and location of construction of the proposed new arena, the
trafc impacts of construction could be signicant. The EIS should include an evaluation
ofthe impacts of construction on both roadway, and, where relevant, rail trafc. This
should take into consideration other projects that may impact the capacity and
functionality of the impacted transportation infrastructure during the construction
timeframe.

Land and Shoreline Use

It should be noted that page three of the Determination of Signicant and Scoping Notice
incorrectly categorizes the proposed use as "indoor sports and recreation." The correct
use is Spectator Sports Facility per SMC 23.84A.010. The distinction is important since
the Indoor Sports and Recreation use is characterized by the players whereas the
Spectator Sports Facility use is characterized by the fans.

Use Compatibilities
The EIS must analyze issues of incompatible uses created by the proposed arena,
particularly for the SoDo site. We are concerned about use compatibility issues
emanating from the arena itself as well as from the accompanying commercial uses that
would cater to the fans (restaurants, taverns, retail, etc.).  Statements by the applicant
about planned accompanying uses suggest that they should be considered as part ofthe
arena proposal. Moreover the City will have a stake in the level of utilization of the arena
and may try to cultivate related commercial uses as a means ofboosting arena utilization.

Mr. John Shaw                                                               Page 7
November 30, 2012

The proposal harkens back to past planning debates about residential uses adjacent to
Port terminals. Experience in Seattle and in other cities show that residential uses are
inherently incompatible with intensive marine cargo operations and other industrial uses.
As a result, attempts to provide mitigation for use conicts might ultimately fail and the
City's economy would su'er as a result. Even with advance notice of existing
conditions, over time new residents will begin to le nuisance complaints, attempt to
delay future permits and potentially le law suits once they actually experience living in
close proximity to an industrial use. A very similar incompatibility exists between
industrial uses and pedestrian-oriented commercial uses. The arena-related commercial
uses would be oriented towards an animated street life.  For example, the restaurants
could be expected to have sidewalk seating.  An issue of compatibility with nearby
industrial uses is created any time a new use involves patrons who object to the sights and
sounds of industry.

Scarcity ofIndustrial Land and Shorelines
Seattle's working waterfront is a scarce resource. Past generations invested tremendously
in the Duwamish manufacturing and industrial district by lling tide ats and
straightening the course of the Duwamish River. To this day the district represents prime
industrial land by offering access to a deep water port, the interstate highways, and
railheads.  Presently-adopted City policies underscore the need to preserve industrial
designations in this area. (See the Land Use and Container Port elements of the Seattle
Comprehensive Plan.) Similar designations for this area exist in King County and Puget
Sound Regional Council plans and also t into the state's planning 'amework under the
Growth Management Act. The EIS must analyze the impacts of the arena consuming
industrially-zoned land. This point is timely given that citywide vacancy rates for
commercial properties have been higher than for industrial properties for some time now.

Related to the issue of the scarcity of industrial land we note that materials from the
applicant have represented the proposed arena facility extending slightly outside two
important land use boundaries. The May 31st presentation to the Seattle City Council
showed the facility extending outside (to the east) of the Stadium Transition Area
Overlay District and also outside of the IC zone into the IG2 zone. (The presentation can
be found here:
http://clerk.seattle.gov/~public/meetingrecords/ZO12/gpnf2012053 l_l a.pdf ) The
Spectator Sports Facility use is not permitted in 1G2 within the Duwamish MIC. Beyond
the regulatory aspect, this is such a conict with adopted city policies about protecting
industrial land that the EIS process must answer how this encroachment will be
mitigated.

Speculation Patterns
The EIS must analyze the likely displacement of industrial businesses caused by property
speculation. The speculation pattern is well-known: new markets for non-industrial
developments lead to increased property valuations which, in turn, lead to increased rents
that established industrial businesses can no longer afford. This pattern stems from two
di'erent conditions: 1) the existing code allows for a certain amount of non-industrial
developments as prescribed by the size-of-use limits for the various I-zones (IC in

Mr. John Shaw                                                              Page 8
November 30, 2012

particular) and 2) property owners make predictions that their land will experience
additional up zoning in the future. There is compelling evidence that the applicant's
actions have already caused speculation -- the price they recently paid for land at the
SoDo site is reportedly three times the price-per-square-foot that three of the parcels sold
for only 18 months earlier.

Utilities

The EIS must analyze whether the arena project would overburden utility infrastructure.
in
City Light is already trying to reduce loads based on substation capacity, particularly
the downtown area. Introducing the arena to an area that has historically been
warehouses exacerbates the problem. Similar issues may exist for the sanitary sewer
system and should be studied in the EIS.

Thank you for the opportunity to provide input into the EIS scoping process. We are
looking forward to working with your staff throughout the EIS process, in particular with
regard to the expected transportation and land use compatibility impacts of the proposed
at
project. Please do not hesitate to call Geri Poor at (206) 787 3778 or Joseph Gellings
(206) 787 3368 if you have any questions.

Sincerely,
W
Stephanie Jones Stebbins
Director, Seaport Division Environmental and Planning

cc:     Bob Chandler, Marshall Foster, Tom Hauger  City ofSeattle
Linda Styrk, Patricia Akiyama, Kurt Beckett, Joseph Gellings, Traci Goodwin,
Eric Hanson, Mike Merritt, Geri Poor, Christine Wolf, Port ofSeattle

Encl:  Report: Impact of a SoDo Arena on Port of Seattle Operations, Heffron
Transportation Inc., August 7, 2012
Report: Economic Issues of a Proposed Arena, BST Associates, August 6, 2012
Report: SoDo Arena Proposal, Seattle Duwamish Manufacturing and Industrial
Center, Land Use and Flaming Issue, Steinbrueck Urban Strategies, LLC, August
7, 2012