Seattle Displacement Coalition

4554 12th NE * Seattle * Washington * 98105 * 206-632-0668 *


Interfaith Task Force on Homelessness

creating the political will to end homelessness in king county in ten years



December 9, 2010


Stephanie Van Dyke,

Director of Development and SEPA Official for Yesler Terrace

Seattle Housing Authority
120 Sixth Avenue N.  
P. O. Box 19028
Seattle, WA 98109-1028


Kristen Larson

Project Funding and Agreements Coordinator

City of Seattle Human Services

Community Development Block Grant Program

700 Fifth Avenue, Suite 5800

Seattle, WA 98124-4215


Re:  Our Comments on the Yesler Terrace Redevelopment DEIS


Dear Officials,


The Seattle Displacement Coalition is a 33 year old city-wide low income housing and homeless non-profit organization here in Seattle whose membership is made up of residents of Seattle and representatives of various church, community, and social service organizations within our community. 


Our membership also includes residents of Seattle Housing Authority (SHA) buildings including residents of the 580-unit Yesler Terrace Public Housing Project. As such, we are directly affected by the proposed redevelopment of Yesler Terrace and the accompanying zoning and land use changes that SHA is considering to accommodate their plans.


The Interfaith Task Force on Homelessness was officially convened in December 2001 and has partnered with the Seattle Displacement Coalition, the Church Council of Greater Seattle, the Archdiocesan Housing Authority, and other organizations.  The organization works regionally to bring leadership and members of faith communities together to do advocacy for increased public funding for low income housing and homeless programs. The group also advocates at state, county, and municipal levels to promote legislation that prevents housing losses due to displacement and gentrification.  Our members and supporters include people who live in Seattle and in the area where Yesler Terrace is located.


To remain consistent with requirements for full analysis of significant environmental impacts under both NEPA and SEPA and in order to ensure decision-makers full disclosure of those impacts as well as necessary mitigation measures to address those impacts, it is necessary to revise/amend the DEIS to include the following levels of analysis when the final EIS is drawn up:


1.  There are significant flaws in the DEIS that pertain to each alternative that has been analyzed.  The assessment of impacts associated with each alternative assumes no net loss of public housing on the redeveloped site - specifically units serving the array of public housing eligible households now living on the site whose incomes are at or below 30 percent of area median, especially low income families with children. As has been the case for decades, these are the households now served at Yesler Terrace. The average income of households at Yesler Terrace is about 18% of median – far below even the 30% threshold.  As contained in the DEIS, SHA has conveyed the impression in all of the alternatives that there will be no loss of housing on site serving this low income group.

On the contrary, SHA has made it abundantly clear there will be fewer public housing units serving this “extremely” low income population on the redeveloped site.  In fact, there will be a dramatic reduction – perhaps a reduction by half – in the number of public housing units serving this group regardless of which alternative they pursue (other than the no action option).  The DEIS contains absolutely no assessment of the direct, indirect, and cumulative effect of this loss as it would pertain to the many environmental elements that must be analyzed in the DEIS under each of the options. 

To restate, the DEIS only includes analysis of each option under the assumption that there will be an equal or greater number of units serving this population on the redeveloped site, which is in contradiction to SHA’s stated position on its plans for the site.

In several recent forums representatives of SHA, including Director Tierney, have flatly refused to provide a pledge that all the public housing on site serving public housing eligible households would in fact be replaced on site in the new Yesler Terrace development.  Most recently before a November 8th 2010 briefing given to the Seattle City Council, Director Tierney again was not willing to make such a pledge that all public housing serving the broad cross section of public housing eligible households (meaning those – especially families - with incomes below 30 percent of median) would be replaced on site.

In fact, the materials he provided to the Council on the 8th, including a power point (see reference link #1 below) display - see page six – indicates that SHA will replace only a portion on site with the rest to be replaced “close by”.  As to how many units will be replaced off-site or how far away is “close by” no SHA representative has specified. 

We’ve also attached excerpts from a memo (see reference link #2 response number one below) that Director Tierney forwarded to the City Council on November 15th further confirming that some of the public housing units will be replaced off-site. While he does not say how many will be lost on site, he makes it clear he wants the option of off-site replacement open to them and states explicitly that they will proceed at Yesler Terrace in manner just like their past HOPE VI redevelopments. 

In each of those four HOPE VI projects (Holly Park, Roxbury, High Point, and Rainier Vista), only half the 2000 units that existed on those sites were ever replaced on the redeveloped sites.  SHA alleged that the other half of the former units were replaced off site but most of the units they credit as off-site replacement units actually were built by non-profit entities in the area using tens of millions of existing levy, state trust fund dollars, low income tax credits and other finite local sources already earmarked for the region.  In other words, it simply was a case of robbing Peter to pay Paul.  Those dollars otherwise would have been used to expand Seattle and the areas stock of extremely low income units.  

SHA simply assigned themselves credit for those off-site ‘replacement’ units after making a small contribution to their non-profit ‘partners’ that actually built the units.  To restate, the bulk of the cost of creating those units was covered or rather “paid for” from existing levy, state, and other local dollars.  The result was a drain of millions in limited state and local housing revenues going toward replacement units that otherwise would have been used to expand the stock of this much needed housing serving those at or below 30 percent of median. 

Further, the so called off-site replacement units for these four projects required and expenditures of millions in extra housing dollars to purchase of land that otherwise would have been used to expand this city’s stock of low income units.  Had all the replacement units been built on site, this expenditure and opportunity (for use of that land to expand our supply of units serving this group) would not have been sacrificed.  Many more extremely low income families could have been served.

(See reference #2 at end of this letter, Nov 15th Director Tierney comments where he references methods of financing saying he does not want to be tied down or restricted in their use of state trust fund and city levy dollars for Yesler Terrace redevelopment.  He say’s they used little of these funds in their previous HOPE VI projects.  Millions were used for those projects – both the on and off-site replacement units draining the city and state of precious limited housing resources.  This DEIS should spell out exactly how much was used in trust fund, levy and 9% low income tax credits for all of their previous HOPE VI projects as well as other finite sources already dedicated to the area in order to give decision makers some idea of what likely will be tapped again for this project)

For the period since 1997 – the period these four projects have been under construction,  and Rainier Vista is still not completed - a significant percentage of the vacancies occurring in what remains of SHA’s public housing inventory have been filled by those displaced and relocated from these four sites.  SHA has effectively been forced to restrict access to public housing for more than a decade, sometimes cutting off all applications, and left to fill vacancies on their remaining stock exclusively with households formerly located at these four redeveloped HOPE VI sites.  This has effectively backed up SHA’s waiting lists and forced many needy eligible families to look elsewhere including out of the city (which also carried significant transportation impacts). 

There also were increased relocation expenses paid out for those displaced, especially  including from federal sources.  Displaced families in some cases received vouchers and were forced into substandard privately owned units far from family, friends, and services they depended upon.  This caused an unnecessary exhaustion of federal housing vouchers going to displaced tenants rather than to serve those on SHA’s long waiting lists. 

Those four HOPE VI projects thus led to a greatly diminished supply of this critical type of housing serving those most in need in our city.  The direct, indirect, and cumulative effects as stated above (particularly but not exclusively related to the socio-economic environment) were enormous.  There also was an enormous fiscal impact to building replacement units off-site – an extra drain of SHA, City, State, and Federal dollars and available land – to tune of tens of millions of dollars.

According to the King County Housing Benchmarks Report, in all of King County, there are only about 300 unsubsidized rentals priced at levels affordable to those with incomes below 30 percent of median. By contrast there are over 100,000 households with incomes at or below this level.  About 40,000 of those households live in Seattle.  This means that any reduction in the stock of public housing or even temporary loss of units that clogs waiting lists carries with it enormous social and economic impacts. 

The loss of these public housing units and subsequent higher end “mixed income” redevelopments also set in motion displacement and gentrification on properties and in the neighborhoods which surrounded those HOPE VI developments.  There was a dramatic indirect and cumulative effect on rents, rates of demolition, and condominium conversions associated with each of these developments.  The demographics of these neighborhoods has changed and continues to change as a result of these SHA projects with low income and minority households replaced by higher income largely white households.

The Yesler Terrace DEIS fails on all counts to assess or offer mitigation for any and all of these real impacts accompanying a net loss of on site public housing units at Yesler Terrace – a condition SHA acknowledges will be an outcome regardless of the redevelopment alternative they choose to pursue.

At the very least in order for full disclosure of impacts associated with their proposal, the DEIS must be more specific about SHA's plans regarding the extremely low income units – where and how many will be replaced on site and where and how many will be replaced off-site and at what cost and with what funding sources for both on and off-sit units.  This should be stated for all of the alternatives included in the EIS.  Absent this, there is no possible way of understanding a host of direct, indirect and cumulative impacts (especially socio-economic effects) associated with the project both with respect to costs and impacts associated with on site development and what will happen off site in the immediately neighborhood. 

Such an analysis must be included which assumes a reduction on-site of public housing units especially given SHA has stated that this will be the case regardless of the alternative they pursue. In addition, they have explicitly said (see our attached referenced material for proof especially Tierney’s Nov. 15th comments) they will pursue a plan at Yesler Terrace similar to what they pursued at the other garden communities.  Those plans resulted in a net loss of one half the public housing units on those sites and a host of impacts such as those we’ve sighted above. 

Unless SHA is willing to explicitly state how many public housing units will be replaced on site serving the same income group and do so for all the alternatives being studied (with accompanying impacts clearly identified accordingly for all options), we recommend that for purposes of the EIS analysis, it shall be assumed that under all the alternatives, it be assumed that only one half the existing public housing units will be replaced on site consistent with SHA’s redevelopment of its other garden communities.

(Let’s assume for the sake of argument that SHA is seriously considering full replacement on site of all the public housing they will remove at Yesler Terrace even though this directly contradicts what SHA has placed on the record in public and before the City Council.  This still would not relieve SHA from a legal obligation to include in the EIS – a complete assessment of the impacts accompanying a project that did not include full replacement on site of the existing public housing units.   This is especially true given the fact, that there is no preferred option even included in this environmental document (this fact alone raises its own legal questions). In which case, and given that SHA has said precisely the opposite – that they intend to replace units off-site- there is an absolute legal obligation to include a detailed level of analysis in the EIS which assumes a net loss on site of public housing units especially units serving families at or below 30 percent of median now residing on site. ) 

This assessment must be included for each alternative and it should include an assessment of the direct, indirect, and cumulative effects that will accompany a net loss of half of low income units on site such as the effects we’ve cited above including socio and economic effects, fiscal effects (including a clear description of the additional financing and revenues they would be seeking under each alternative to build replacement units off-site and land that will be used and its price), effects on land costs and values resulting from those off-site plans, effects on surrounding housing and housing prices, transportation, population ie how it will effect the demographic make up of the surrounding community, how it will affect waiting lists, etc.  This analysis also should include an examination of what happens to the displaced populations, where they go, what services they need, and are they going to be available in areas where they are displaced. 

2.  This analysis must also include an assessment of the indirect and cumulative effect a mixed income project of this scale will have on prices and rents, including market rate units on site and especially units that now exist off-site in the surrounding neighborhood and city wide as well as an assessment of current need for this housing at each income level.  Also, an analysis is needed of how a loss on site of public housing units serving public housing eligible families will affect demand for the limited supply of these desperately needed units, and how it will affect those rents and prices city-wide and especially in the immediate neighborhood. 

3. In addition to the information already contained in the “no action” alternative, more detail must be added to the analysis of this option.  There must be especially greater detail provided on the element of this option that involves renovation/modernization.  More description is needed of renovation and modernization and its accompanying impacts such as the cost of that alternative when compared to the other alternatives and its impacts on the built, physical, and social-economic environment.  Such an option would assume preservation of the existing unit count and mix, type and depth of housing subsidy. The number of public housing units serving public housing eligible residents in this alternative should remain essentially unchanged from the current level. As part of this process, a plan with designs should be provided for construction and described for the decision makers with at least the level of detail provided for the other options.

Site and infrastructure improvements would be identified as part of this alternative and it should be accompanied with a list of all remodel, renovation, major repairs, and alteration work performed at Yesler Terrace over the last twenty five years to the units and overall site with reports or references to reports identifying current condition of the units and infrastructure..

This information including the cost of this option is needed to provide a baseline that decision-makers will need to understand the true cost of all other alternatives under consideration.  It also would answer the question of whether there is any basis to the frequently used and unsubstantiated claim by SHA that the current Yesler Terrace buildings are blighted and beyond renovation.  

SHA has offered no proof nor has it referenced any documents in the DEIS to substantiate a claim of blight or that the units or infrastructure have outlived their useful life.  This is a key criteria decision makers must use when determining whether various sources of city, state, and federal funding can be tapped for such a project or whether they are even necessary for the project.

Engineering and architectural reports required by HUD to justify that the buildings at Yesler Terrace are so obsolete as to require demolition must be included as an appendix to the draft EIS. Any appendices, technical memoranda, or other supporting documentation must also be included. In addition, a list of all remodel, renovation, major repairs, and alteration work performed at Yesler Terrace over the last twenty five years must be provided, in the form of a spreadsheet. The spreadsheet must include the date that the work was performed, the total development cost and the construction cost, and a brief description of the work.

4. For the EIS to claim, as it does in section 1.3, that the options considered are “representative”, while completely ignoring whole-site modernization, is remarkable, to say the least, especially considering the large number of and wide variety of substantial renovation / whole-site housing modernization projects that have been completed by SHA and many other housing authorities and non-profit developers in the City and throughout the northwest (and throughout the country) over the last thirty years. It can be said that the Pacific Northwest has some of the best development, design and construction talent and expertise in the country in this field. Such a project would include but not be limited to modernization of all units and buildings, including additions where appropriate; abatement of hazardous materials (which would be required prior to demolition in the four schemes discussed in the EIS); codes upgrades; accessibility improvements; infrastructure replacement where required; and landscape improvements; as well as sensitive insertion of new structures where appropriate. For the EIS to be considered truly “representative” of the alternatives, it must include a thorough analysis of a whole-site modernization / substantial renovation project.  

5.  When the “no action” option is fully and completely described including its financial cost and its other impacts, then each of the other redevelopment options should be more fully developed, and most importantly, those alternatives should include a estimate of total cost plus a breakout of what funding sources and resources are likely to be tapped/needed to complete that option.  Further, if additional land is needed to ensure completion of the off-site units under a given option, then that and other added cost associated with building replacement units off-site should also be included. Funding sources for off-site activity should also be identified. 

If Housing Levy funds, state or county funds, or Federal funds, including Section 8 project-based and LIHTC are used to fund construction of the replacement units built on or off-site, then these funds would not be available to construct new housing elsewhere. While this may be considered a “financial” as opposed to “environmental” impact, it is clear that depletion of such funds to replace demolished housing instead of construct new housing would have a serious negative impact on housing affordability throughout the region. This is clearly a serious negative socio-economic and environmental justice impact under NEPA, and under the City’s SEPA guidelines, and must be addressed in the EIS. For each of the options, use of such funds must be enumerated in spreadsheet form and discussed in terms of the impact on the availability of these funds for construction of subsidized housing elsewhere in the city and in the region.

Comparison to the baseline “no action” option then should be made with clear charts and spreadsheets for decision-makers. This is necessary to inform decision makers of revenue balances and impacts associated with each option on our limited low income housing funding sources.  It is information critical to understanding the effect of each option on our city’s ability to maintaining and maximizing resources available to expand our stock serving these very low income populations in great need in our community. 

For each option considered, spreadsheets must be presented enumerating the following: Total number of housing units, unit mix (studio, one bedroom, two bedroom, etc), unit sizes, open space per unit (deck or ground-related), ground-related open space per unit, ground-related units, unit type (townhouse, one-story walk-up, ground-related flat, elevator access apartment, etc.), accessible unit mix. In addition, information in the form of spreadsheets must be provided to enumerate which unit types are subsidized and the type of subsidy provided (Public Housing, Project-based Section 8, Senior Housing, LIHTC, combinations of the former, etc.)

6. More analysis is needed of indirect and cumulative environmental impacts on the surrounding neighborhood set in motion and resulting from the Yesler Terrace Project and the various options under consideration.  The project would dramatically increase densities under all but the no action option.  Major upzones, alley vacations, and a planned development is slated for the site under all the last two options. What is conspicuously absent is a level of analysis to understand the significant impacts on the immediate neighborhood associated with these major land use changes and changes to level of allowable density and types of uses planned for the site.

With respect to the area immediately east of the site, SHA has been acquiring property, negotiating to acquire even more sites, and even displacing residents already from existing buildings it has acquired.  This activity is pursuant and directly related to their plans at Yesler Terrace. They’ve applied for grants, and have already laid out plans for these areas that will be set in motion in tandem with their plans for the Yesler Terrace site itself.  This EIS must include a much more detailed delineation of these plans off-site and their environmental impacts. And it should include a detailed examination as to the direct, indirect, and cumulative effect of these plans when combined with their major onsite plans.  The offsite plans in fact are set in motion only if Yesler Terrace proper is redeveloped so environmental law requires such a level of detailed analysis for this off-site activity as well. We’re really talking about not only the development of Yesler Terrace but plans for development east of the site – an area with 2-3 times the acreage as on-site.

For example there is no adequate estimate of current housing and land use conditions and demographics (socio-economics) of the surrounding area, and then no assessment at all of the potential risk to those existing low income properties and land uses in the surrounding areas associated with on and off-site plans.  There are no estimates of housing that may be lost due to gentrification forces set in motion by the project, no risk assessment associated with each of the redevelopment option from lower density to higher density alternatives – impacts on the surrounding community – its stock of housing that may be removed due to demolition, higher rents etc, set in motion under each option.  This level of analysis is typical of other EIS’s but in this EIS, it’s not even acknowledged.  These cumulative effects on transportation demand, parking, view blockage and other elements of the environment also are given scant or inaccurate attention in light of these larger plans beyond the Yesler Terrace site. 

7. New buildings in each of the redevelopment option will likely be constructed to Built Green, LEED Certified, or higher standards. However, merely claiming that new construction is more energy efficient per unit does not provide a complete analysis of the energy and resource use impacts of a proposal. Also to be taken into account are the total life-cycle energy use, obviously larger for a significantly denser development, as well as the energy embodied in manufacturing new construction materials, the energy used to transport them to the site, and the energy used in construction of the new project. Therefore, the only way to compare the alternatives,  including the “no action” option, would be to prepare a complete life cycle energy use assessment for each one, including an assessment of embodied energy associated with demolition and construction of new buildings. The point is that the reader is left with the impression that the list of sustainable features of the proposed alternatives makes them somehow more “sustainable”, in terms of energy use, than the no-action alternative or (see above) the whole-site modernization project. That isn’t necessarily the case, and only a detailed energy analysis can demonstrate that.      

8.  Phasing:  There needs to be a much more thorough elaboration of how SHA under each of the alternatives intends to ensure a process of phasing that does not leave whole blocks and tracts as vacant expanses of dirt for extended periods either on site or immediately off-site (on areas off-site where SHA also plans redevelopments contingent on their on-site plans) and under each option.  Huge tracts have remained for years in an undeveloped state at each of their previously redeveloped HOPE VI sites.  SHA’s HOPE VI Rainier Vista project is perhaps the most notable example, where some 8 years after plans were announced and at least five years after the existing public housing units were removed, half the site still has not been developed.  At that site, SHA has not yet even fulfilled their on-site public housing replacement obligation.  Such site clearance harkens back to the urban “removal” strategies of the 60’s employed by the federal government simply leaving entire tracts empty and affordable housing gutted in these communities.   SHA has not adequately described and should commit to a plan that ensures no appreciable gap - if any at all - between the time of housing removal and housing replacement of the public housing units – whether the units are replaced on or off-site.  The DEIS does not provide detail or adequate plans to mitigate these impacts, nor does it describe the negative impacts if this gap is long. This is of particular concern, given that, as noted in the DEIS, it could take up to twenty years to complete the project. If all the units are demolished at the outset, worst case, then those residents will need to be relocated to other very low income units throughout the area, effectively removing those units from the housing stock temporarily… for up to twenty years.  That’s the worst case, but the DEIS gives us no idea of what SHA would do to prevent this from happening. The cumulative impact on the City’s housing resources could be enormous, far worse than Rainier Vista, where half the site has remained abandoned for at least five years.

9.  The DEIS fails to adequately consider the historic significance and landmark status of the current Yesler Terrace. A project’s historic status is measured against the following criteria, 1) Is it more than 25 years old and does it "have significant character, interest or value, as part of the development, heritage or cultural characteristics of the City, State or Nation?" 2) Is it associated in a significant way with an historic event, which has had a significant effect on the community, city, state or nation? 3) Is it associated in a significant way with a significant aspect of the cultural, political or economic heritage of the community, city, state or nation? 4) Does it embody the distinctive visible characteristics of an architectural style, period or method of construction? It is an outstanding work of a designer or builder?  5) Is it is an easily identifiable feature of its neighborhood or the city due to the prominence of its spatial location; contrasts of sighting age or scale? and  6) Does  it contribute to the distinctive quality or identity of its neighborhood or the city? 


Yesler Terrace – the current site and housing units – easily fulfills all these landmarking criteria. The EIS fails to accurately or adequately document this fact.


Sufficient original building fabric is present to convey YT's historical and architectural significance. While the east portion - about a quarter to one third of the project - was removed to make way for I-5, the character of the garden community layout remains. Thus, YT still conveys what was at the time a groundbreaking more human-scaled and healthful approach to public housing than was being developed at the time. Likely, due to all the demolitions under HOPE VI and other HUD programs, YT is now one of the oldest remaining models of this type in the country, possibly the oldest, though it's impossible to know without a thorough review of the existing stock nationally. It's possible that YT is one of the most historic housing projects in the country now, far more so than is understood, simply because it's one of the only ones left standing.


Yesler Terrace was the first integrated public housing development in the nation, making it profoundly significant locally and nationally. It's also one of the first of the garden communities in the country, possibly one of the only early models - if not the only one - remaining in the country.


If Jesse Epstein, founder of the Seattle Housing Authority and creator of the Yesler Terrace layout and housing model, were more of a national figure, and it could be argued that he should be by virtue of having built the first integrated public housing project in the nation, then Yesler Terrace would have more national significance in this respect. He should be seen as nationally significant civil rights leader and an urban planning visionary at the level of a Clarence Stein or Robert Moses. Still he remains one of the State's most historic figures, and even at the state and city level, should be recognized with more prominence than he has been. Designation for Yesler Terrace is consistent with and serves that purpose.


There are claims that Yesler Terrace also the first wood-framed public housing project in the country (See “History Link” article discussing this). If this is the case, then it adds to YT's historic status. Also, if it is the first wood-framed public housing project of any size and significance, then this could be evidence that it's the first low-rise project of its type.  On this basis alone, Yesler Terrace should be preserved.  

Getting back to YT being the first integrated public housing project in the country, this is of course profoundly significant, enough to qualify the project for landmark status. BOLA, SHA’s landmarks consultant, acknowledges that it's the first integrated project, but they don't go into detail on how this came to be. The EIS should elaborate and provide these details.  Who in Washington D.C. was involved in those decisions? What was the history leading up to the decision? A report on historic character of Yesler Terrace should summarize that history as well.  When it does, its significance on this level will be made even more clear.


If landmark status should be assigned to one of the earliest models of HUD's vision to build lower-rise, more healthful and human scale public housing - as embodied in the "garden community" principals being forwarded by renowned planners of the time, such as Clarence Stein, doesn't it make sense to assign such status to such a development that was also - profoundly significant in its own right - the first integrated public housing development at the time? Not to mention that Yesler Terrace could possibly be one of the only remaining examples of these early models, given how many have been torn down under HUD's HOPE VI program over the last ten years? Is there even a list of these early projects and their current status?  The DEIS should include this kind of information and provide a much greater level of detail in this regard as to its historic significance.  


Yesler Terrace also is listed on the Washington State Heritage Register as a landmark.  More details about why it is listed here should be provided in the DEIS as well.


10. The non-energy-related sustainability standards which any new buildings will be designed to meet will likely be used to promote SHA’preferred option (regardless of which redevelopment and higher density option it chooses). Therefore, the direct and indirect environmental benefits of the “no action” alternative and a whole-site modernization option must be considered in detail as a means of providing a complete comparative picture of these other options. If a redevelopment and higher density development option is built to green standards as is suggested in the DEIS, it may still be more energy consumptive and create a larger carbon footprint, whether “green roofed” or not, than no-action or modernization options which conserve existing buildings and their embodied energy spread thru a longer lifespan than these denser so-called green options.

A list of such benefits of the modernization and  no-action options would include but not be limited to preservation of existing Public Housing; preservation of the historic resource; preservation of local low income housing development funds for use in other areas of the City and region;  preservation of existing open space; preservation of tree canopy (there is in the DEIS a wholly inadequate discussion of environmental impacts associated with removal of most of the existing tree canopy) and other existing habitat; elimination of all impacts associated with demolition of buildings; and elimination of all impacts associated with constructing new buildings (including materials used, resources depleted to manufacture building materials, energy used to construct buildings, energy used to transport building materials to the site, pollution impacts during construction, etc. 

The DEIS must provide a more thorough elaboration of the no action and whole-site modernization options’ effects on these green and environmental variables (such as impacts on climate change, carbon reduction, etc) not yet provided in order to provide this basis for comparison.

11.)  The DEIS appears to inflate the amount of open space that will be provided under the each of the redevelopment options, especially when compared to the no action alternative.  The DEIS for example does not include an assessment of how much open space will be taken up with rooftop gardens and other spaces not accessible to most people.  Absent the park space identified as the “commons” how much open space also will be available elsewhere on site?  How far will residents have to walk from their place of residence to the commons or nearest children’s’ play area? How does that compare to the status quo?  Also, the DEIS describes the backyard spaces as “private” and semi-private in the current Yesler Terrace and then does not include all that space in the calculation of open space.  This artificially reduces the amount of true open space that currently exists on site and makes it appear to be less than what would existing under each of the redevelopment options.  How much space is taken up in backyard, courtyards and space between units in those courtyards? This should be added into the calculation of open space under the status quo, while a calculation should also be provided of how much so called open space under each option will be given over to rooftop and/or more semi or private space. 





John V. Fox

Seattle Displacement Coalition

5031 University Way NE

Seattle, Washington 98105




Bill Kirlin-Hackett

For the Interfaith Task Force on Homelessness

3030 Bellevue Way NE, Bellevue WA 98004






1. Link here to PDF File: Powerpoint from SHA presented Nov. 8 to City Council – See page six indicating it is SHA’s intent to locate a portion of public housing replacement units off-site.


2.  Excerpts taken directly from SHA Director Tierney’s November 15th letter to City Councilmembers (full letter accessible through Councilmembers):


Question 1 – regarding where Yesler housing will be replaced

When the Yesler Terrace Guiding Principles were drafted, most Citizens Review Committee members (all but two) agreed that housing should be replaced on the site or in the immediate neighborhood. All of the alternatives being studied through the EIS process include replacing all units on site. We expect that the vast majority of the existing 561 units will be replaced on the site. However, we believe it would be unwise at this point to make a specific commitment about exactly how many of these units will be replaced on site in order to remain flexible for opportunities that may arise as we go forward.

In previous redevelopments we have preserved similar housing patterns (i.e. mix of bedroom types) and have tailored the new rental housing to meet the needs of a range of demographic groups, from low-income seniors to families to people with disabilities. We plan to do the same at Yesler Terrace.

We do not expect that the cost of replacing units in the neighborhood is substantially higher than replacing them on the current site. Land values on- or off-site are comparable.

Question 2 – regarding how housing at Yesler Terrace will be financed

We hope any and all financing options will be available for rebuilding Yesler Terrace. Traditionally we have not used substantial amounts of Housing Levy funding or Housing Trust Fund monies, but we do not believe it is in the public interest to rule these sources out. This issue came up about six months ago as the City Council considered the administrative plan for the most recent Housing Levy. The Council chose then not to categorically restrict Seattle Housing Authority’s access to Levy funds. As you know, we have also contributed 500 Housing Choice Vouchers for use with Levy funds both in the current levy and in the prior one.

While we have made use of Low Income Tax Credits, we have generally used the less competitive four percent credits as opposed to the nine percent credits used by nonprofits. Often, the fact that we offer Project-based Vouchers to our partners helps them to compete more successfully for tax credits.

The larger question here is how we all, as the Seattle community, can pool our resources to create the best low-income housing possible for the residents who need it. Creating artificial constraints about which organization can use which funding source, or seeking to maintain rundown housing beyond its useful life, does not create great communities or meet the needs of low-income residents over the long term.

Question 3 – regarding apartment buildings acquired east of Yesler Terrace

Seattle Housing has acquired two apartment buildings and one commercial building east of Yesler Terrace. The Ritz, which provides 30 units of low-income housing at 1302 East Yesler Way, was acquired in 2003. At that time, it was about to be in foreclosure. We have completed a tax-credit supported rehab of The Ritz and it remains in service as low-income housing. Because it is already serving low-income people and will do so into the future, we do not intend to count this as replacement housing for Yesler Terrace units.

The building at Twelfth and Yesler contained some illegal apartments above the retail property. Neither we nor the City ever considered them as viable low-income housing. We bought this building, along with others on Twelfth Avenue, to ease the blighted conditions caused by them in the neighborhood. It has recently been demolished and awaits funding for further housing and mixed-use development.

The Baldwin (31 housing units at 124 13th Ave) was in significant disrepair when we purchased it in 2007. While it was considered “market-rate housing,” it was serving lower-income residents. We took The Baldwin off line last year due to serious roof and heating system failures, and relocated those tenants. We hope to rehab it and have applied for funds through the Choice Neighborhoods program. We intend to use this as early replacement housing for Yesler Terrace. We expect to replace The Baldwin’s original “market-rate” units with apartments that will serve low-income residents with incomes between 50 and 80 percent of AMI.

November 15, 2010