Seattle Planning'Commission
Review of the Proposed Sports Arena in
the Duwamish Manufacturing and Industrial Center













July 27, 2012

The Seattle Planning Commission is a l6member volunteer advisory board charged with
providing independent and
objective expertise to the Mayor, City Council, and City departments on broad planning goals, policies, and plans for
the physical development of Seattle.

Our work is framed by our responsibility as stewards of Seattle's Comprehensive Plan, "Towards
a Sustainable Seattle,"
which guides new growth in population, jobs, and development, and steers the City's capital
spending and informs
new regulations.' This plan is required by the Washington State Growth Management Act that
guides grth and
coordinates land use goals and policies among jurisdictions. Other relevant plans include Vision 2040, which identies
multicounty planning policies for the Central Puget Sound Region, and King County Countywide Planning Policies,-
which addresses growth management in the county.

Volunteer members who serve on the Commission represent diverse disciplines including architecture and urban
design, transportation and environmental planning, civil engineering, public nance, land use and real estate law,
affordable housing and community development, public health, and community
organizing. As such, we provide
advice based on collective expertise and independent research and analysis.















Cover photos from left to right:
aerial of Seattle's SODO neighborhood by eastcolfax;
South Holgate Street looking west from the City of Seattle's SODO Action Agenda;
Seattle Planning Commission's Industrial Lands fourth stakeholder workshop held
on May 31, 2007;
existing conditions at Occidental Avenue South at South Holgate Street by Seattle Planning Commission staff.

SEATTLE PLANNING COMMISSION OVERALL POSITION

The Seattle City Council asked the Flaming Commission to provide
our thoughts and conclusions on several
planning, land use, and transportation-related questions regarding the proposed SODO arena. Our answers
to those specic questions are detailed in the body of this report and help provide a broader understanding
and context for the Commission's overall conclusion, which is
as follows:

The Commission recognizes that major sports and entertainment facilities
are important assets to the overall
culture and vibrancy of the city and that professional sports teams
can add value to Seattle and to the region.
However, we caution the City that developing an arena in the proposed location has the potential to generate
adverse impacts that may threaten the container port, maritime, industrial, and manufacturing sectors 
which have been found to be vital to the health and resilience of
our local, state, and regional economy and
that are expressly protected and promoted by the City's guiding policy document: the Comprehensive Plan.

Based on the ndings from the Commission's two-year analysis and outreach effort addressing the City's
industrial lands and on a thorough review of the arena proposal, the Commission believes that locating
a

new major sports and entertainment facility inside the Duwamish Manufacturing and Industrial Center
(MIC) holds a strong likelihood of displacing living wage jobs and nearby businesses and disrupting
container port operations and freight mobility. We believe these risks are inherent with
a spectator sport
facility at this location. The Commission recommends that the City not take actions that further place this
proven economic asset at risk. At the very least the Commission believes more review and analysis should be
conducted before the City takes further action.

Council asked the Commission to address thefollowing question:
Consider the minimum safeguards, protections
or mitigation that should be taken to protect the
surrounding maritime and industrial sectors if the arena were to be built.

Proceed with Caution before Signing the MOU

Our rst suggestion is one of caution. Because
an Environmental Impact Statement has not
been prepared, there is not suicient information to identify the appropriate
steps necessary
to mitigate potentially signicant adverse impacts to the Port and related manufacturing
and industrial uses. The Commission believes that
more review should be conducted before
signing the proposed Memorandum of Understanding (MOU). Much more work must be
done to ensure the proposed arena siting does not undermine long-standing goals and
policies
that support industrial businesses vital to Seattle and the state. There also needs
to be more
clarity about the proposed SODO arena site, which has not been be specically dened.'i

The following recommendations constitute the minimum action the City should take if
a new
major sports and entertainment facility is sited at this location; however, we feel many of these
recommendations are warranted regardless so as to better protect industrial lands.


Land Use and Planning Actions

" Consider establishing a Port Overlay District, or another
appropriate zoning mechanism,
that would strengthen South Holgate Street
as a 'hard edgei' and the MIC as a
manufacturing and industrial sanctuary." This effort could focus on further restricting the
amount of non-industrial uses that have been shown to undermine industrial and
port
operations.

" Further prohibit hotels specically related to stadium and entertainment
uses in IG zones
within the MIC.

" Retain the MIC and Transition Area Overlay boundaries. We also recommend holding rm

on current limitations on the uses allowed within the Overlay. For instance, allowing hotels
within the existing Transition Area Overlay should not be considered.

Transportation Related Actions
)) Provide special consideration to freight mobility. We anticipate a Port Access Study will
begin in 2013. While the study may help identify actions and investments to protect freight
mobility, a Freight Master Plan (on par with the Pedestrian, Bicycle and Transit Master
Plans) is warranted, regardless of whether or not the proposed arena is approved. In order
to ensure necessary infrastructure is built, any plan should clearly identify possible funding

sources.

)) Improve the quality and safety of the pedestrian experience from many key destinations,
including the ferry terminal, Pioneer Square, Chinatown International District, and light
rail stations, to the major sports facilities. Infrastructure investments should include
waynding, pedestrian-scale lighting, ADA accessibility, sidewalk improvements, and safety
improvements to street and rail crossings. Some of the needed pedestrian improvements
for the Stadium Transition Overlay Area District were detailed
as part of the street vacation
of Occidental Avenue South for the Safeco Field, the SODO Action Agend the Greater
,
Duwarnish Manufacturing Industrial Center Plan, and other documents pertaining to
essential infrastructure investments in SODO.


Other Related Actions

)) Provide support to
neighborhoods that could be
negatively impacted by a new
arena in this location such

as Uptown, Pioneer Square,
and Chinatown International
District.

)) Clarify feasibility of and plans
for the proposed pedestrian mall
and address access to Safeco
garage contingent upon purchase 
of adjacent property, currently
Little Ship (T18)
owned by BNSF, to the east of
Mary Iverson
the proposed site.              Oil on Canvas, 6" x 8" x 1"
Seattle City Light 1% for Art
Portable Works Collection

THE PROPOSED SODO ARENA LOCATION IN CONTEXT

The luly 18, 2012 memo prepared by Council Central Staff succinctly and effectively outlines
some of the important policies and regulations related to land use and
zoning. We refer you to
that memo for further clarication.

With reference to that memo, the Commission understands proposed location for the
arena is:
1.  Completely contained within the Duwamish Manufacturing and Industrial Center
(MIC), one of eight regionally designated MICs";
2.  Predominately within the Stadium Transition Area Overlay District (Overlay)"i;
3.  Predominately on land that is zoned Industrial Commercial (IC)"";

80 long as it is located entirely within IC zoning, the proposed SODO
arena is a permitted

use under the City's Land Use Code; to the extent the arena requires or includes land located
outside IC zoning, and depending on the
use of that additional land, the project
may no
longer be considered a permitted use.

In addition to the required review under the State Environmental
Policy Act (SEPA), the
proposed arena would require a Master Use Permit (MUP), Building Permit, and must obtain
a street vacation approval from City Council for the portion of the development located
on
Occidental Avenue. We note that the street vacation is
a discretionary decision. In order to
approve the street vacation, the City Council will be required to determine if the proposal
signicantly serves the public interest and, in doing so, must weigh the public benets under
the goals and policies applicable to this area.Viii This
same discretionary review would be
required for replacement ofvehicular access with the proposed pedestrian mall west of Safeco
Field Garage.

No warranties of any sort. including
accuracy tness. or merchantability
accompany this product.

Copyright 2012. All Rights Reserved.
City of Seattle. Prepared July 2012 by
Seattle Planning Commission stair.







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'           I"
A__lt W
['3 Duwamish Manufacturing       proposed arena site           I industrial general
& Industrial Center
I associated development        ['1 industrial commercial
D Stadium Transition
- proposed pedestrian mall        Idowntown
Area Overlay District
- - proposed Safeco Garage access
I non-required reserved                                  multifamily
stadium parking allowed      railroads                    single family

RESPONSES TO ADDITIONAL QUESTIONS FROM COUNCILMEMBERS

1.  Is the proposed SODO arena compatible with this location from
a planning, land use, and urban
design standpoint?

Given that the specic charge of the Commission is to provide recommendations based
on
broad planning goals, policies, and plans,
we have taken careful effort to review the proposed

arena relationship not only to the Land Use Code and Comprehensive Plan, but also to other
state, regional, and local goals and policies. As such, our main concern related to the proposed
arena is the strong potential to displace industrial businesses through conversion
pressure and
to disrupt container port operations and freight mobility.

The historical pattern of land use changes has been documented in the Greater Duwamish
Manufacturing and Industrial Center Plan:
"The viability ofIndustrial land within the M eh I Center is under increasing
pressure
from a variety sources...Conversion ofindustrial land to incompatible uses not only
removes the sitefrom industrial use but adversely impacts the surrounding industrial

users by increasing land values and lease rates. Such development
generates additional
vehicular and pedestrian traic, reducing available parking
access to local business,
andplacing increased pressure on already congested arterials and thoroughfares vital
to
. freight mobility."'"

Also, the Commission's extensive analysis outlined in The Future of Seattle's Industrial Lands
(July 18, 2007) found that industrial zoned land is a vital civic asset and industrial businesses
located there are critical to the city's overall economic health and global
competitiveness,
contribute signicantly to Seattle's family wage job base and the
economy, and provide
signicant tax revenue to the City. This sector is an essential element of economic diversity
that serves as a counterbalance to the cyclical nature of other industries and provides middle
income jobs to individuals without higher education. Seattle's industrial zoned land provides
a sanctuary to industrial business in a tight land market and once converted is not likely to be
replaced. Competition for scarce land in Seattle has driven up rents in industrial zoned
areas
and resulted in the displacement of industrial businesses."

Policy analysis documents the value of these uses and a preponderance of state",
regional", and localXii policies prioritize industrial uses, especially within a MIC, and that
limit or restrict uses that could interfere with industrial and manufacturing operations""'.

2. What impact would the proposed SODO arena have on Seattle's manufacturing and industrially
zoned land and Port operations?

While a full Environmental Impact Statement would be required to understand the potential
impacts, based on previous studies we raise the following concerns:

Potential Loss of Tax Revenue and Jobs from the Manufacturing and
Industrial Sector

Tax revenue and jobs the proposed arena is projected to generate must be weighed against the
known value the city, region, and state derived from a healthy and vibrant manufacturing and
industrial sector. Manufacturing and industrial businesses in Seattle generated almost $20
billion in gross revenue in 2008, which was 26% of gross
revenue for Seattle. Construction,
manufacturing, wholesale, transportation and warehousing businesses in Seattle account
for over $50 billion in taxable sales receipts which is 36% of the City's total
revenue from all
sales tax receipts. In addition, the industrial sector also generates approximately 38% of the
City's total business and occupation (B810) tax revenue annually.xv The Governor's January
2009 Container Ports Initiative report found the Port of Seattle generates almost 150,000
jobs statewide"i and in 2010 it was one of the fastest growing ports in the country."ii The
City should pay close attention to any potential impacts to current operations and the future
planned expansion and needs of the Port's cargo shipping operations.XViji

Conversion Pressure on Nearby Manufacturing and Industrial Businesses and
Potential Negative Impacts to Container Port Operations

As stated previously, the proposed arena is likely to put further conversion pressure
on nearby
manufacturing and industrial business. This pressure is not solely due to the location of
sports facilities; additional non-industrial traic makes industrial transportation to and from
the area less efficient, weakening the long-term prospects for industrial growth. The goals
and policies related to manufacturing and industrial centers have been established precisely
because of the intense pressure to convert these areas to other uses."ix In addition, this project
would potentially have negative impacts to container port operations by contributing to trafc
congestion near the Port and by discouraging Port-related industry due to higher land prices.

3.  How would the proposed SODO arena impact transportation in the
area for passengers and
freight? What is your perspective on the ability of attendees to access the arena via transit and
other modes of transportation?

More Transportation Analysis is Needed

We reviewed the transportation study conducted by Parametrix
on behalf of ArenaCo,
which we recognize was preliminary. A full Environmental Impact Statement would provide
a comprehensive analysis of potential impacts that the proposed arena would have on
transportation including freight rail, trucks, automobiles, transit, bicyclists, and pedestrians,
as well as other important factors anticipated to change travel patterns and mode splits.
.Freight Mobility Requires Special Consideration
While the transportation study indicates that
arena events would occur mostly outside of
current Port operating hours, further incursion of non-industrial uses into the Duwamish
Manufacturing Industrial Center may have an adverse impact. Because efcient freight
mobility contributes to Seattle's competitive advantage in the regional and global market,
freight mobility requires special consideration in Seattle policy. It should be noted that much
of the same transportation infrastructure that makes the proposed location attractive for the
arena  including access to 1-5, 1-90, SR99, and railroads  is vital to freight mobility. See our
previous recommendations on page 5 related to the development of a Freight Master Plan.

Transportation Access in the Area Requires Significant Investment
The quality of the walk from downtown and the Stadium and SODO light rail stations to
the proposed site is very poor in terms of sidewalk conditions,
access, lighting, waynding,
etc.; it would require substantial investment to support an arena at the proposed location
and make nonmotorized transportation a better alternative. SDOT has informed
us that
street and pedestrian improvements along Alaskan Way and Railroad Way from the Ferry
terminal to Railroad Way and lst Avenue South are fully funded
as part of the SR99 - Alaskan
Way Viaduct Replacement. However, more funding to create appropriate access to, through
and around the proposed arena site would likely be
necessary. We note that some of the
transportation infrastructure previously identied as important to mitigate impacts of general
trafc growth and currently permitted uses (i.e., Safeco Field, CenturyLink Field) has
yet to be
funded or constructed.xx

Finally, the potential pedestrian mall could do much to contribute to a safer and more vibrant
pedestrian environment for those attending events. We raise the question of how Occidential
Avenue South could be converted to a pedestrian mall if ArenaCo cannot purchase
or obtain

access through the parcel to the east of their site in order to replace access to the Safeco
Garage.


10

Proposed Traffic and Parking Impacts
There should be analysis of arena-related traic
impacts to those travelling through or around                          "
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SODO as well as to those traveling to the             1 ocddu'iarsziwun ql ..ll'~4 3'"    '
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proposed arena during events. For example,              1                            a
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people who work downtown and live in West                               '15:"; ____ ';    '5 gill,              12 nialllailg'qadw'
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Seattle may be impacted getting home on game        4 Railroad Avenue was! 1,. l. r.:."  Wm" ill! .*
of Occidonlal
days.                                     5' rst Amt", south of
Railroad Way

Many event attendees may take advantage of
currently free surface parking to the south
of the proposed arena, which would be an
attractive alternative to transit and may
decrease average vehicle occupancy below
what was assumed in the transportation study.
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In addition, the location on Occidental Avenue          ""ijmni'w vi
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South dened for a pedestrian mall is currently
Mumdyegmcpa El}  "'czu\  w 
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snow-sc-       , 4' ili'iifulllr
used for charter bus queuing for other events                              a ..
and games. It is unclear where this would                          i      i
occur if this area was no longer available. 
Pedestrian improvements identified in the "New Pacific NW
Baseball Park Pedestrian Connections Plan" prepared as
one of
the conditions for the vacation of Occidental Avenue South for the
Mariner's Stadium."







Buses queuing on Occidental Avenue South
west of Safeco Field Garage after a recent
Mariner's game.



11

4. What would be the impacts on KeyArena if it is left behind? What are some the potential
concerns or impacts on Seattle Center generally in light of the Master Plan work done
a few
years ago? What are the Commission's thoughts about pedestrian possibilities in Uptown and
South Lake Union should a new arena be sited back at Seattle Center instead?

The full impacts of a new, potentially larger
arena, at Seattle Center are unknown, but the fact
that KeyArena has operated as a similar sized facility for decades
suggests that operational
impacts could be managed successfully. While an Environmental Impact Statement may
be required to understand the potential impacts to KeyArena, following issues
warrant
consideration:

Impacts of Potential Competition with KeyArena
A new stateof-theart arena may draw some of the events that would otherwise be scheduled
at the KeyArena; it is unknown how this would impact the overall health and welfare of Seattle
Center."ii As for the question of Seattle Center
as a possible location for a rebuilt arena, from a
land-use perspective directing public and private investments and infrastructure to the Seattle
Center and surrounding neighborhood, which is within
a regionally-designated Urban Center,
is signicantly different from doing so in a MIC." For instance, investing in the neighborhoods
surrounding Seattle Center to improve services that accommodate the patrons of large events,
including dining and drinking establishments as well as pedestrian thoroughfares, helps further
neighborhood planning goals for this area.xxjv

Public Interest

We are not fully informed as to why ArenaCo rejected the Seattle Center
nor the other three sites
they explored nor have we been briefed on the investor's intentions if their current preferred site
is not approved. We note that a site analysis for a potential developer would be focused
on issues
such as land cost, associated permitting, and subsequent project and construction time
to ensure
an acceptable return on investment. This is
very different than process for the siting of other
public sports facilities; for example Safeco Field included a robust evaluation of alternative sites
that considered a host of criteria including factors related to the public interest."

Investments in the Public Realm, Pedestrian Environment, and
Transportation Network
It is well documented that transportation for major events at the Center is challenging.
Similarly,
transportation challenges would exist for arena patrons travelling to the proposed SODO site,
where industrial uses and the movement of freight and
cargo shipping are prioritized and where
the potential exists for overlapping event schedules at multiple sports facilities. Any location
where a new facility of this magnitude is sited would require investments in the public realm,
pedestrian environment, and transportation network, as well as careful event scheduling nad
programming. Such required investments could be more limited in an area were a certain level
of pedestrian-friendly infrastructure currently exists, such
as the Seattle Center area, than in

an industrial area like SODO. Without an analysis that contrasts potential sites
many questions
remain unanswered.

12

5. Any other issues or concerns that you think would be helpful to the Council as we consider this
proposal?

Impacts of Potential Development "Creep"
There has been speculation about whether ArenaCo or its investors would look south of
South Holgate Street or to other properties within the MIC to build required parking
or other
development to support the proposed arena. As stated on page 4, the City should clarify with
the proponents and possible investors that South Holgate Street is a hard edgemi for spectator
sports facilities including any related non-industrial uses. If the City proceeds with developing
the proposed arena at this location, Council should include clear language in the MOU that

any zoning requests now or in the future to accommodate non-industrial development related
to the arena will not be considered. The MIC boundaries should remain intact. We also
recommend holding rm on the boundary of the Transition Area Overlay and limitations
on

uses allowed within the Overlay. For instance, allowing hotels within the existing Transition
Area Overlay should not be considered.

impacts on Pioneer Square and the Chinatown-International District
The City Council should better understand how this proposal will impact current efforts to
revitalize Pioneer Square and the Chinatown-International District. Neighborhood businesses
in Pioneer Square and the Chinatown-International District have raised
concerns for years'"ii
that generally they see many negative impacts and few benets from nearby spectator
sporting events. While we do not have statistical information to assess this issue, it is not clear
whether these communities would see a positive economic impact if
an arena and associated
development were to be developed in the proposed location. The proposed business model
includes adjacent uses along a pedestrian mall such as retail, restaurants, and taverns along
a
pedestrian promenade on Occidental Avenue South between Edgar Martinez Drive South and
South Massachusetts Street. While permitted under the Land Use Code, this 'entertainment
zone' could draw customers who may otherwise gather in the Pioneer Square and the
Chinatown-International District prior to and after events at the arena
or other spectator
sports facilities in the area.


In 2006, the Governor launched an initiative to study the value of marine container
ports to the state's economy. Based on the findings of this initiative, the State
Legislature adopted changes to the Growth Management Act that require Seattle and
Tacoma to prepare new container port elements for their Comprehensive Plans. Earlier
this year, Seattle adopted this new element, which includes goals to
preserve cargo
container activities, minimize conflicts between uses, and prevent the conversion of
industrial land.



13

DISCLOSURES AND RECUSALS

The Seattle Planning Commission is
a volunteer advisory board that provides recommendations and advise to city
oicials on planning, land use, transportation and community development issues. We
are dedicated to conducting
our business in a manner which ensures that discussions, deliberations and the resulting advice and recommendations
of the Commission are open and transparent to the general public and to the ofcials that consult
us. To ensure this
transparency the Planning Commission has adopted an Ethics Management Plan. Planning Commission advice is
enhanced by its broad membership. Although Commissioners exhibit
a variety of interests, professional experience
and opinions, they act as individuals and represent the entire city
as opposed to any particular special interest
group or
groups (Commission Resolution 7/8/82). The disclosure of interests and ailiations of Commissioners help mitigate the
appearance of a conict of interest by better informing the public and the recipients of Seattle Planning Commission
advice. We act in accordance with appropriate conict of interest rules and standards and follow the rules outlined for
advisory boards in SMC 4.16.

Commissioner Colie Hough Beck disclosed that her rm, HBB, works
on commercial, multifamily, and public
infrastructure projects throughout the city and that the Port of Seattle, King County and City of Seattle
are clients of
HBB.

Commissioner Kadie Bell disclosed that her rm, Grifn, Hill & Associates, has worked with
a variety of public parties
that could be affected by the arena outcome.

Luis F Borrero's rm DRVE.LLC, has a strategic partnership with Heartland LLC. Heartland LLC's
current clients may
be impacted indirectly by the outcomes of this decision.
Commissioner David Cutler disclosed that his rm, GGLO, works
on public and private projects throughout the City
that may be impacted the outcome of this project.

Commissioner Mark Johnson disclosed that his rm, Environmental Science Associates (ESA) provides
consulting
services to public and private clients that may be affected, including the City of Seattle (SDOT, SPU, and DPD),
King
County, the Port of Seattle, Seattle School District, Sound Transit, and Washington State Ferries.

Commissioner Jeanne Krikawa disclosed that the SODO Business Association is
a past client.

Commissioner Amalia Leighton disclosed that her company, SvR Design, works
on a variety of public and private
projects in the city of Seattle including projects for the City of Seattle, Port of Seattle, and Washington State.

Commissioner Kevin McDonald disclosed that his employer, the City of Bellevue, could be impacted by the
arena
decision.

Commissioner Matt Roewe disclosed that his rm, Via Architecture, works
on municipal planning and private
development in areas of Seattle that could be inuenced by the outcome of this project. He also volunteers with the
Uptown Alliance who is currently asking the City for further study of a new basketball/hockey/concert arena at Seattle
Center.

Commissioner Morgan Shook disclosed that his rm, BERK, has worked with
a variety of public and private parties
that could be affected by the arena outcome.

Commissioner Sarah Snider disclosed that her rm, LMN, does urban design and various
types of architectural
projects in the Seattle metropolitan area.


14

ENDNOTES

i.    Comp Plan 101 and Seattle's Comprehensive= Plan webpages.

ii.    The Commission notes that the eastern portion of the proposed site
as depicted in the May 31, 2012 presengtion to City Council
lies outside of the Stadium Transition Area Overlay District and is zoned Industrial General 2, which prohibits spectator
sports
facilities within the Duwamish Manufacturing and Industrial Center.

iii.   Seattle Municipal Code 23.74.002 B: "There should be well-dened edges between the pedestrian activity of the Stadium Transition
Area and industrial activity surrounding it. The portion of Fourth Avenue South that is north of Royal Brougham and the main line
railroad tracks create a strong edge to the east and should be the eastern boundary. South Holgate Street, the rst major
cross street
to the south of Safeco Field, should be the southern boundary. Boundaries should not be shifted farther into the industrial area."

iv.    Governor's Container Ports Initiative: Recommendations of the Container Ports and Land Use Work Group Main Report, January
2009, pages 12: "As use of port lands has increased, our major cities face pressure to redeveloper areas that have historically been
industrial. While this urban development is attractive and provides
many benets, it cannot be sustained without parallel industrial
economic development.
. .competing visions for the use of our industrial shorelines, conicts between high-trafc trucking
corridors and pedestrian-friendly neighborhood redevelopment, and changes in zoning that push warehouse and distribution
centers away from designated harbor areas, have the potential to signicantly impair port operations and limit future economic
development opportunities." The Future of Seattle's Industrial Lands, Seattle Planning Commission, 2007, page 7: "Pressure on
industrial lands, a phenomenon not unique to Seattle, is a major concern for many industrial business
owners.
.
.this pressure is
pushing land costs up, forcing businesses out of Seattle or limiting their opportunities to expand, and promoting the increasing
number of requests for the conversion of industrial lands to non-industrial uses."

PSRC Vision 2040 and King County Countywide Planning Policies provide regional guidance for Seattle's Comprehensive Plans
as
required by the State Growth Management Act. Manufacturing and Industrial Centers are regional designations of "locations for
increased employment" and a key aspect of the Regional Growth Strategy.
PSRC VISION 2040: "Regional manufacturing industrial centers are locations of more intensive industrial activity. These centers
are characterized by large contiguous blocks served by the region's major transportation infrastructure, including roads, rail, and
port facilities. VISION 2040 discourages non-supportive land uses in regional manufacturing industrial centers, such as retail,
non-related ofces, or housing, in order to preserve the basic sector industries located in these centers. These centers
are expected to
accommodate a signicant share of the region's manufacturing employment growth."
King County Coungmide Planning Policies: "Manufacturing/Industrial Employment Centers are key components of the
regional economy. These areas are characterized by a signicant amount of manufacturing, industrial, and advanced technology
employment. They differ from other employment areas, such as business/ofce parks, in that a land base and the segregation of
major nonmanufacturing uses are essential elements of their operation."

vi.   Seattle Municipal Code 23.74 Stadium Transition Area Overlay District. As noted in ii above, the eastern portion of the proposed
site appears to be outside of the transition area.

vii.   Seattle Municipal Code 23.50 Industrial.

viii.  City of Seattle's Street Vacation Policies, amended July 2009, page 4: "There is no right under the land use code or elsewhere to
vacate or to develop public right-ofway. In order to do so, a discretionary legislative approval must be obtained from the City
Council and, under State law, the Council may not vacate rightof-way unless it determines that to do
so is in the public interest...
the Council is not bound by land use policies and codes in making street vacation decisions and
may condition or deny vacations
as necessary to protect the public interest. The City will generally deny vacations as necessary to protect the public interest. The City
will generally not support vacations that do not advance City planning goals, particularly if inconsistent with the desired intensity of
development and preferred uses."

ix.   Greater Duwamish Manufacturing and Industrial Center neighborhood plan, April 27, 1999,
page i.



15

RCW 36.70A.085 requires the container port element for Seattle's Comprehensive Plan. Findings
Intent - 2009 c514: "(1)
The legislature nds that Washington's marine container
ports operate within a complex system of marine terminal operations,
truck and train transportation corridors, and industrial services that
together support a critical amount of our state and national
economy, including key parts of our state's manufacturing and agricultural sectors, and directly create thousands of high-wage
jobs throughout our region. (2) The legislature further nds that the container port services
are increasingly challenged by the
conversion of industrial properties to nonindustrial
uses, leading to competing and incompatible uses that can hinder port
operations, restrict efcient movement of freight, and limit the opportunity for improvements to existing port-related facilities. (3)
It is the intent of the legislature to ensure that local land
use decisions are made in consideration of the long-term and widespread
economic contribution ofour international container ports and related industrial lands and
transportation systems, and to ensure
that container ports continue to function effectively alongside vibrant
city waterfronts."

Puget Sound Regional Council 2902 Urban Centers Report Duwamish Manufacturing]Industrial Center,
page 2: "The regional
signicance of the Greater Duwamish Manufacturing and Industrial Center to the City of Seattle and the Puget Sound Region
cannot be overemphasized.
.
.The Duwamish MIC provides the largest concentration of family
wage jobs in the Puget Sound region,
generating enormous tax and export revenues. . .The MIC is a vital international trade and transportation crossroads, receiving
and distributing goods via roadway, water, rail and air. It's ability to provide
multiple modes of transportation represents a unique
asset to the region and an enhancement to the local business environment."
King County goungm'de Planning Policies, updated
December 2010: FW 15, FW 16, LU-51, LU-52, LU54, LU-58, and LU-60.

xii.   Seattle Comprehensive Plan, Urban Village Element: UVG23 Promote the
use of industrial land for industrial
purposes. UV21
Promote manufacturing and industrial employment growth, including manufacturing
uses, advanced technology industries, and a
wide range of industrial-related commercial functions, such
as warehouse and distribution activities, in manufacturing/industrial
centers. UV22 Strive to retain and expand existing manufacturing and industrial
activity. UV23 Maintain land that is uniquely
accessible to water, rail, and regional highways for continued industrial
use. UV24 Limit in manufacturing/industrial areas those
commercial or residential uses that are unrelated to the industrial function, that
occur at intensities posting short- and longterm
conicts for industrial uses, or that threaten to convert signicant amounts of industrial land
to non-industrial uses.

xiii.  Legislative/Executive Staff Report on the Stadium Transition Area, page 4: "Over the last ve
years, there has been intense
development in this area, including the construction of Safeco Field and the Seattle Exhibition Center and the issuance of permits
for the Football Stadium.. .The change in development pattern and intensity justies
a re-evaluation of the zone criteria as applied
to the site.
. .recommendations include a strong connection between this area and downtown, while maintaining a clear separation
between the fairly intense commercial development occurring at the north end of the
Manufacturing and Industrial Center and the
industrial area further south."

xiv.  RCW 36.70A.085 nding (2). Director's Report
on the Mayor's Recommended Comprehensive Plan 2011 Annual Amendments,
City of Seattle Department of Planning and Development, November 2011, page 4.

Basic Industries Economic Impact Analysis, City of Seattle Oice of Economic Development,
July 2009, pages 27, 32-33.

Governor's Container Ports Initiative: Recommendations of the Container Ports and Land Use Work
Group Main Report, January
2009, page ii.

xvii.  America's Container Ports: Linking Markets at Home and Abroad, US. Department of
Transportation Research and Innovative
Technology Administration, January 2011, page 6, table 1.

xviii. Ordinance 12354 adopted the new Container Port Element of Seattle's Comprehensive Plan, relevant
policies include: LU3, LUS,
L7, EDI, and ED2.





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xix.  1994 designation of the Duwamish MIC, Ordinance 117211; 2000 recognition of the Greater Duwamish Neighborhood Plan,
Resolption 30018; 2002 PSRQ Qrban genters Report; 2004 update to the Comprehensive Plan, Qrdinance 121291; 2007 SPC's
Future of Industrial Lands report and lad use code changes; 2008 Vision 2049; 2009 update t9 GMA
requiring the container port
element- 2010 update to qungmide planning policies; 2012 update to the Comprehensive Plan adopting Seattle's Container Port
Element, Ordinance 12354.

Some ofthe needed transportation infrastructure and programmatic investments for the Stadium Transition Overlay Area District
and SODO area are detailed as part of the street vacation of Occidental for Safeco Field, Ordinance 119534; the SODO Action
Agend ; the Greater Duwamish Manufacturing Industrial Center Plan; SDOT Freight Mobility Action Plan; and in other similar
documents pertaining to essential infrastructure investments needed in SODO.

Status of Ballpark Street Vacation Conditions, Washington State Major League Baseball Stadium Public Facilities District,
January
15, 1999, Appendix 10, page 27.

xxii.  KeyArena Subcommittee Final Report and Recommendations Executive Summary, February 15, 2006, page 2: "In the event that the
Sonics/Storm remain in this region and develop a new arena in another location, KAS recommends that the future of KeyArena be
fully reevaluated, as experience from around the country shows that an arena that has lost a major league franchise which stays in
the area, becomes a second-tier facility and struggles nancially."

xxiii. Vision 2040 denes urban centers as locations for housing and employment growth while manufacturing/ industrial centers
are
locations for increased employment.

xxiv. Relevant goals and policies can be found in the Seattle Center Century 21 Master Plan, August 2008, and Queen Anne
Neighborhood Plan, January 1999, as well as the Planning Commission's Seattle Transit SQQmmunities report, which identied
Uptown as one of Seattle's "transit communities with the most urgent near-term planning needs".

Washington State Major League Baseball Stadium Project Final Environmental Impact Statement, 1996.

xxvi. Seattle Municipal Code 23.74.002 B; see endnote iii above.

xxvii. Washington State Major League Baseball Stadium Project Final Environmental Impact Statement, 1996, page 3-89: "While events
at the Kingdome have a positive effect on some businesses, the level of impact for specic businesses generally depends
on the type
of event and total attendance. For some businesses and residents, however, trafc congestion and parking problems associated with
large afternoon and early evening events (generally more than 15,000 attendees) have resulted in lost business. On these event days,
established customers often avoid businesses in Pioneer Square because of traffic congestion and re-routing.
. .Lack of accessibility
and the ability to meet customer needs are seen as a substantial problem
on these days. Some businesses, such as art galleries, book
stores, and antique stores, do not believe they benet from Kingdome events; individuals attending events are not generally their
customers."

Stadium Panel Whittling List, Seattle Times, March 14, 1996: "Walter Carr,
owner of the Elliott Bay Book Co., said that his business
drops by 25 percent on Seahawks Sundays and that his store lost $40,000 in sales during the baseball playoffs."







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