LETTER | Supplemental EIS for Potala Village and Possible New Shorelines Permit

 

 

Numerous citizens noted that the Potala Village proposal has grown more than 25% since the Environmental Impact Study was done. 

 

Recently, city staff noted that whether a Supplemental EIS or an Addendum would be required was a decision that will be made by the SEPA Responsible Authority, Eric Shields.  It was indicated that this decision was not yet made.

 

The difference in the addendum and the supplement are huge.  An addendum is basically a rubber stamp of prior EIS, without public input or further study.  A Supplemental EIS may require new “scoping” meetings, and makes new studies and new public comment period mandatory.

 

Citizens note that Washington Department of Ecology makes the decision very clear for any SEPA Responsible Authority.   This includes the DOE’s references to state laws (WACs).   

 

“3.6 Supplementing an EIS:  A supplemental EIS [WAC 197-11-620] adds information and analysis to supplement the information in a previous EIS. …There are several situations when a supplemental EIS is appropriate:  - The proposal has changed and is likely to cause new or increased significant adverse environmental impacts that were not evaluated in the original EIS. - New information becomes available indicating new or increased significant environmental impacts are likely.”

“[T]he additional analysis, changes to the proposal, or new mitigation may be relevant to other agencies’ decisions. The agency preparing the document should notify all agencies with jurisdiction that a supplemental EIS is being prepared.”

“2.7.3 Addendum:  An addendum [WAC 197-11-600(4)(c) and 625] contains minor new information that was not included in the original SEPA document… Addendums are NOT appropriate if the changes or new information indicates ANY new or increased significant adverse environmental impact.”

 

The current proposal appears to have grown by more than 25% in the mass that is above ground and creates negative impact.  Current proposal 138,434sq ft and prior 110,972 sq ft (33,083 + 33,083 + 15,241 + 29,565, source Appendix A Potala Village Environmental Impact Study).  The height has also increased from 30 feet ABE to 33 feet ABE.  The current proposal also disregards major mitigations previously agreed to by both the City and the Developer.  These mitigations removed significant adverse impacts and removed substantial volume from the building.

 

The current proposal greatly increases negative impacts and these increased impacts have not yet been studied.  The current proposal adds new impacts not previously studied.  The Potala proposal of late has become more massive, although EIS stated the smaller version already had incompatible mass.  The proposal brings 41 feet of height to within 10 feet of the property line rather than being set back 30 feet with the top story set back 40 feet.  Modulations on the east side of the building have been removed and it now robs the neighboring properties of privacy.  There is a very long list of newly introduced negative impacts that need study.

 

The Citizen Groups also note that the increased size of the Potala Village project seems to exceed the threshold of change allowed to maintain vesting in the Shorelines Development Permit.  A new SDP is likely necessary if the applicant wants to proceed with the currently proposed plan.

 

Citizens look forward to participating fully in the Supplemental EIS and in any new Shorelines Development Permit Application.

Karen Levenson