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Master Planned Developments in SR-169 Corridor by Peter Rimbos, Corresponding Secretary
The Greater Maple Valley Unincorporated Area Council (GMVAC) has deep reservations regarding the adverse impacts that two massive Master Planned Developments (MPDs) proposed by Yarrow Bay in and around the City of Black Diamond. These include: (1) The Villages: 3,600 single-family and 1,200 multi-family units for a total of 4,800 dwelling units on 535 acres, and 775,000 square feet of commercial and office space and (2) Lawson Hills: 930 single-family and 320 multi-family units, for a total of 1,250 dwelling units on 156 acres, and 390,000 square feet of commercial and office space. These two proposed outsized developments total 4,530 single-family and 1,520 multi-family units for a total of 6,050 dwelling units on 691 acres, and 1,165,000 sq ft of commercial and office space.
These MPDs are proposed on the rural/suburban fringe of the Urban Growth Boundary along the Black Diamond-Maple Valley-Renton corridor where existing transportation infrastructure already is severely strained. The GMVAC has monitored traffic patterns and volumes in and around the greater Maple Valley area for decades. We remain concerned with the inadequate options associated with our existing transportation infrastructure, as our major roadways and minor arterials throughout the area already are used near capacity for a good part of each weekday.
We have specific concerns regarding the adverse transportation impacts on SR-169 (Maple Valley Highway) and SR-516 (Kent-Kangley Road), as well as KIng County roads, major intersections, and local arterials throughout the greater Maple Valley area. Estimates of impacts on traffic flow on SR-169 show a near doubling of vehicles when the proposed developments are complete. In addition, major intersections throughout the area will be unduly clogged--even more than they already are. Clearly, these proposed MPDs will adversely impact the movement of people, goods, and services.
There are an inordinately large number (1,000‘s) of Transfer of Development Rights (TDRs) involved. TDRs are normally used for shifting higher densities into the areas which can best handle that growth. Unfortunately, relatively remote Black Diamond, is a poor choice to be a receiver of such a number of TDRs. We also are concerned with proposed improper siting of schools and storm water facilities in the Rural Area. Urban developments cannot rely on Rural Area citizens to shoulder the adverse impacts of siting their needed facilities.
Another issue of concern to all residents along the SR-169 corridor is unsustainable growth. The King County Growth Management Planning Council (Oct. 09) provides household growth targets. For the City of Black Diamond the 2006-2031 growth target is 1900 households. Black Diamond is categorized as one of 19 "small cities" which together a growth targets allocation of 10,922 new housing units (Black Diamond's 1,900 is 17% of the total small city allocation). The two Yarrow Bay proposals, by themselves, represent more than three times the Black Diamond allocation, and thus, by themselves, take up 55% of the allocation for all 19 of the small cities.
Greater Maple Valley area citizens have consistently recognized transportation as a key issue. In addition, the Area Council believes the proposed Yarrow Bay MPDs do not meet the Transportation Concurrency requirements of both the King County Comprehensive Plan and the State Growth Management Act. Consequently, we are asking King County and the State to hold Yarrow Bay and the City of Black Diamond to those requirements, respectively. We cannot allow the associated adverse impacts that greatly increased traffic will do to paralyze our existing clogged major transportation infrastructure.
Draft Environmental Impact Statements (DEISs) for the MPDs were issued last fall. Very comprehensive comments were submitted by the public, government agencies, local groups, and the Muckleshoot Tribe. Many of these comments parallel our concerns. Final Environmental Impact Statements (FEISs) were issued in December. Unfortunately, after reviewing the FEISs, it is clear that many of these comments were not fully addressed by Black Diamond officials.
Several concerned Black Diamond citizens have submitted formal appeals, which will be heard before a Hearing Examiner starting on Saturday, March 6, 10 AM - 5 PM (Black Diamond Elementary School at 25314 Baker St.) and continuing on Monday, March 8, and Tuesday, March 9, both from 7 - 10 PM (Black Diamond City Council Chambers at 25510 Lawson Street). Public Hearings on the MPDs themselves are scheduled for Wednesday, March 10, and Thursday, March 11, both from 7 - 10 PM (Black Diamond Elementary School) and continuing on Friday, March 12, starting at 10 AM (Black Diamond City Council Chambers). The City of Black Diamond website provides links to the FEISs and MPD Application documents. We urge concerned citizens throughout the area to attend any and all these hearings. NOTE: Public comments will only be taken at the Public Hearings on the MPDs.
We request that King County and State officials critically assess the proposed MPDs and push for a delay in this rapidly moving process so that further study can be made of the severe ramifications of these proposals and the City of Black Diamond’s inadequate responses to many DEIS comments. We wish to ensure the City of Black Diamond meets the requirements of the King County Comprehensive Plan and the State Growth Management Act, especially Transportation Concurrency requirements and Level of Service standards to ensure that adequate transportation infrastructure is in place prior to any approvals of each development phase, as is required.
In conclusion, the proposed MPDs must be strictly held to the multiple applicable provisions of the King County Comprehensive Plan and the State Growth Management Act and must acknowledge other projects currently in planning that would only exacerbate the adverse impacts of these two massive projects.
by Peter Rimbos, Corresponding Secretary
At the Monday, April 5, Greater Maple Valley Unincorporated Area Council regular monthly meeting. the author provided a in-depth Debrief of the proposed Master Planned Developments (MPDs) in Black Diamond and of the recently completed hearings.
There are two MPDs proposed by Yarrow Bay (YB) in and around the City of Black Diamond (BD) that total 4,530 single-family and 1,520 multi-family units for a total of 6,050 dwelling units on 691 acres, and 1,165,000 sq ft of commercial and office space. These are the largest MPDs in King County history. These would add 4 to 5 "new" cities of Black Diamond to Black Diamond!
A lot has happened over the past 6 or so months. King County (multiple departments); WSDOT; WA DOE; The Muckleshoots; the cities of Covington, Auburn, and Maple Valley; and countless Organizations and Individuals submitted detailed comments on the DEISs last Fall. Unfortunately, except for several brave and determined citizens, they all disappeared when the FEISs were released in mid December. Peter is still somewhat unsure why this happened. Nevertheless, when Peter came on board (around Thanksgiving) the FEISs were about to be released. Over time Peter helped secure a variety of County Expert Witnesses--including Paul Reitenbach and Matthew Nolan who spoke at the Area Council’s March monthly meeting--and a WSDOT Expert Witness. In almost all cases, these were the same people who wrote the DEIS Comment Letters.
Although both King County and WSDOT did not appeal the FEISs (WSDOT stated they were not notified), they did submit Post-FEIS Comment Letters, which largely reiterated their DEIS comments. The Area Council was instrumental in making this happen through detailed Letters of Concern.
Six groups of citizens did file appeals of the 12/11/09 FEISs by the 12/28/09 due date challenging their adequacy. They secured critically acclaimed environmental lawyer, Dave Bricklin, to argue their appeals before an appointed Hearing Examiner (HE). An appeal by the City of Maple Valley missed the filing deadline.
The Appellants used Expert Witnesses from King County and the State of WA, as well as technical consultants. Over 700 pieces of evidence were entered into the record. Over 200 citizens attended some of the Public Hearings. Several hundred Oral and Written Public Testimony were presented. One Public Hearing lasted to midnight, another to 11:10 PM. Over 60 hours of hearings in all were held.
Here is a chronology of the Hearings: 1. The Appeals Hearings on FEIS adequacy started on Saturday, March 6. 2. The MPD Application (Permit) Hearings started on the evening of Wednesday, March 10. The public offered both Oral and Written Testimony. Along with hundreds of members of the public, the Area Council’s Chair Steve Hiester provided testimony, as did the cities of Auburn and Maple Valley. 3. The Appeals Hearings on FEIS adequacy ended on Friday, March 19. 4. The MPD Application (Permit) Hearings ended on Monday, March 22, with YB and BD provided rebuttal to the literally 100's of pieces of Public Oral and Written Testimony. 5. Closing Briefs by all parties in the Appeals Hearings were submitted on Monday, March 29. 6. There are dueling subpoenas being responded to by the City of Maple Valley and the City of Black Diamond over Traffic Models and Methodology with responses due Friday, April 2, and Friday, April 9, respectively. 7. A decision by the HE on the adequacy (up or down) of the FEISs is due Thursday, April 15. 8. Should the HE rule the FEISs adequate, he also will make a recommendation on the MPD Applications (Permits) to the Black Diamond City Council due Thursday, April 15. The HE can put conditions--large or small--on the MPD Applications. After being involved with nearly every aspect of the MPDs for the past 4+ months and after attending every hour of all the hearings, Peter offered his personal assessment of the three main fatal flaws in the FEISs and, thus, reasons to find them inadequate:
1. Fiscal Analyses--although this sounds like a MPD Application issue, it is addressed in the FEISs and the HE brought it up at every MPD Application Hearing meeting, so it clearly is on his mind. The other problem is that the Black Diamond’s FEISs show the city in the red after buildout, while Yarrow Bay’s MPD Applications show the city in the black after buildout. each of these fiscal analyses show a small difference between large numbers--another recipe for high risk.
2. Transportation--not only did Yarrow Bay’s poor analysis show 28 of 46 intersections failing (amongst other problems), their poor (according to all four of the Appellants' expert transportation witnesses) mitigation schemes are all unfunded including many which will never be funded unless monies are obtained from future residents and it is questionable even that can cover all transportation-related mitigations.
3. Water--Lake Sawyer water quality (Phosphorus concentrations), massive offsite stormwater retention facility, runoff from large amounts of impervious surfaces, and shallow wells/springs throughout the Green Valley south of the Villages MPD. The HE appeared worried about the Lake Sawyer water quality issue and asked questions about it often throughout the hearings. The Appellants' expert witnesses testified that, should the development be approved, there really is no mitigation that will keep the Phosphorus concentrations low enough to meet the Lake Sawyer Management Plan requirements. Regarding the offsite stormwater retention facility, in the latter parts of the Hearings Yarrow Bay started talking about onsite locations for multiple stormwater "ponds." No analyses of these were shown or provided.
Wastewater/Sewerage is not listed above because the HE ruled those to be out of bounds in the Appeals Hearings, since the citizen Appellants--in their 17-day rush over the Christmas holiday to file appeals--failed to put those words in any of the 6 appeals. There also were other important issues discussed in detail during the hearings: Wildlife & Habitat; Construction Noise & Air Quality; and Climate Change. All of these were argued by both Expert Witnesses and the general public.
Interested citizens are advised to check the City of Black Diamond website for up-to-date information.
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