Where old meets new: 12th Ave Arts affordable housing next to Pine Street Apartments built circa 1908. MHA to have impact on historic resources. Image: Google.
According to the City of Seattle's website, Mandatory Housing Affordability (MHA) is "a new policy to ensure that growth brings affordability. MHA will require new development to include affordable homes or contribute to a City fund for affordable housing. To put MHA into effect, we need to make zoning changes that add development capacity and expand housing choices."
On June 8th 2017, the City of Seattle published its draft environmental impact statement (DEIS) for MHA. This draft includes a section that describes potential impacts on historic resources and possible mitigations. Over the past month, some of us at CHHS spent considerable time reviewing this section and related materials. On August 4th, we submitted the following statement to the city.
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The Capitol Hill Historical Society (CHHS) is new, having formed in January 2017. This is our first policy feedback on the Housing Affordability and Livability Agenda (HALA). Like other neighborhood historical societies, we advocate for historic preservation.
While many comments you receive may focus on the alternatives themselves, we are instead focused on the content of the Historic Resources section, 3.5.
Impacts
There are two impacts to historic structures that CHHS is concerned about in HALA’s Mandatory Housing Affordability (MHA) Draft Environmental Impact Statement (DEIS) section 3.5.2. These should be improved in the final EIS.
The Pike/Pine Conservation Overlay District (PPCOD) is directly threatened by HALA. Developers currently can make taller buildings if they preserve some or all of a building constructed before 1940. With HALA they can take the same benefit if they destroy the building but provide affordable housing. HALA presents the same perk via an alternate route that may be more palatable to developers but less desirable to the community and city.
On page 3.251 and again on 3.252, HALA’s impacts appear to include a proposal to limit the impact of Seattle Municipal Code 25.675.H.2.d. Currently the Historic Preservation Officer must review all projects adjacent to or across the street from a landmark. The DEIS suggests limiting this to projects near landmarks that will demolish or modify “buildings over 50 years in age.” If this is an error, it should be corrected in the final statement. If it is purposeful, we strongly object -- all projects near landmarks should continue to require review by the Historic Preservation Officer to avoid degrading the landmarks. Capitol Hill has 37 landmarks and none of them should be diminished.
Mitigations
There are many mitigations outlined in the DEIS section 3.5.3 that we strongly agree are necessary. Especially important are the following mitigations which the city should immediately fund and staff.
As stated in the DEIS, the city should fund “continuation of the comprehensive survey and inventory”. The Department of Neighborhood’s historical resource survey has been stalled for a decade. This puts Capitol Hill and other neighborhoods’ sites at risk because surveyed structures are more likely to trigger the landmark review process of the Washington State Environmental Policy Act (SEPA). Because perspectives on architectural history and understanding of community history change over time, the Department of Neighborhoods needs to repeat these surveys on a regular interval.
The City should support and encourage new historic districts. Our neighborhood historic districts are all relics of the early days of preservation in Seattle during the 1970s. Areas not recognized or cherished at that time have eroded over the last forty years. Capitol Hill has several areas that seem to meet the criteria, but without city help the process and challenges are insurmountable. One benefit of historic districts to developers is that it removes questions and risk. All buildings in the district are assessed in advance as contributing or not contributing.
Broadly reviewing buildings for landmark status before approving demolition permits is another useful mitigation considered in the DEIS. Currently the reactive landmark eligibility review process is only activated when the subject building is larger than a specific number of square feet or dwelling units. Many buildings that are important to our neighborhood history fall under those thresholds, such as the historic mansions on Millionaire’s Row. Proposal to demolish one of them should cause pause, but the current process does not allow for that. It seems necessary to update city policy or landmark review systems prior to implementing MHA.
One other concern with the demolition review mitigation is that outright demolition may be too high of a threshold. If developers are allowed to significantly modify structures and then later apply for a demolition permit, there may not be enough building left to meet the integrity requirements of landmark designation.
The DEIS describes mitigations for the Pike/Pine Conservation Overlay District in Appendix F in the middle of section F.4. These should be at least mentioned in section 3.5.3 with a reference to Appendix F to describe how other neighborhoods can use PPCOD as a model for mitigation.
Conclusion
As the availability of parking lots and background buildings for new project sites dwindles on Capitol Hill, development has already started replacing our character-defining structures. New policies like MHA that increase redevelopment need to mitigate new impacts. Assessment of our buildings, encouragement of historic districts, and safeguards for demolition are all tools that should be put to use. With these in place, Seattle can enjoy the benefits of MHA while avoiding unintended impacts on our historic urban fabric.
Sincerely, Tom Heuser, President, Capitol Hill Historical Society Rob Ketcherside, Vice President, Capitol Hill Historical Society
