The AIA Seattle Urban Design Committee offers these comments. During the past two years, the design community of AIA Seattle, numbering some 2,000 design professionals, has engaged in a range of discussions and events initiated by the SMP, the City of Seattle, and the Committee. Many of us have devoted considerable time to becoming informed about the project; enabling Members and others to freely present opinions and positions; and to providing suggestions and comments to the SMP and the City. Our colleagues from other disciplines, represented by APA and ASLA locally, have joined in this dialogue so that all benefit from the diverse perspectives that each discipline offers. While we have used these perspectives in drafting this response, we wish to make it clear that in these comments, we represent only AIA Seattle.

Within the AIA Seattle membership, the views of architects on the monorail differ, and range widely. For this reason, AIA Seattle adopted a neutral position relative to last year's ballot measure, including a resolution to take an active role in helping to make the project be the best it can be. To that end, the Committee has shared its recommendations for creating an open, inclusive process of community-based urban design that will deliver sensitive, lasting, infrastructure and make us all even prouder to be Seattleites. The joint Committee on Monorail Design developed and posted design guidelines and principles, published widely and included in a letter to SMP this May. We have also reviewed and commented on the design guidelines and standards that are being promulgated by the SMP and the City.

Through these discussions, we anticipated that the DEIS would provide a clear and reasoned basis for the public to understand and compare the strengths and weaknesses of the many options facing the decision-makers. And, we also expected the DEIS would provide the technical wherewithal to inform those decision-makers - particularly of the relative seriousness of the significant adverse environmental impacts and the associated mitigation measures that should be used to address them. In this regard, we have focused our review on the Land Use and Neighborhoods, Visual Quality and Aesthetic Resources, and Economics sections of the DEIS.

Overall, we find that the DEIS does a very good job of describing the proposal and the alternatives. However, we believe that it falls short in addressing the impacts and even shorter in providing even a basic menu of mitigation measures that should be committed to bridge between the current rudimentary level of the project proposal as described in the DEIS and the next steps of planning and design. We find it particularly curious that the DEIS does not describe the ongoing process for station planning and design and the integration of the stations into the community fabric. While Section 4.5.3.1(p.4-218) lists 6 "actions" that speak to this concern, we believe that this is insufficient in detailing how the "community design process" will "determine design solutions that are appropriate . . ." The second "action" listed: "Design Guidelines discussed with stakeholders, including the Monorail Review Panel, could guide project design issues such as architectural expression incorporating a balanced approach of systemwide elements and contextual elements, systemwide signage for customer ease, and a systemwide art program." (emphasis added) We are not convinced that this statement is an action that will mitigate design concerns, nor that it expresses commitment on the part of the SMP to delivering appropriate design through the kind of community design process that is warranted. We agree that "The subjective nature of visual change makes it challenging to draw conclusions concerning significant visual impacts." (4.5.4, p.4-218) However, the identification of, and commitment to, mitigation measures in the form of design principles and guidelines that establish the level of quality expected to result in attractive, pedestrian-oriented facilities is a necessary responsibility of the SMP and should be part of the EIS.

In the remainder of this letter, we cite some specific examples to illustrate this overall comment.

Downtown Neighborhood Plans (4.3.1.4, p.4-131 and Appendix U) - The DEIS is inconsistent in accurately citing the neighborhoods or urban villages that comprise the Downtown Urban Center.

Station Design (3.4.1, p.3-10) - A "planning objective" is to "ensure unobtrusive integration of subsystems". This language is very unclear. What is "unobtrusive"? What subsystems? Further, this section goes on to state that the "Station size will be determined based on system operating needs as well as design work (emphasis added). "This EIS does not incorporate station design work, but rather assumes conservatively large station footprints and station platform lengths . . ." How can the decision-makers determine station locations based on such limited knowledge? While the footprints are indicated in Appendix L, we do not believe that these station footprints and platform lengths are adequately illustrated in context clearly enough for most people to understand their implications. Separating the illustrations from the text is a disservice.

Context-sensitive design (4.3.2.1, p.4-141 and 4-146) - This is a term that has not been defined in this application. How does it relate to the pending design principles and guidelines?

Alternative 3.1 (4.3.2.1, p.4-146) - "The alignment will pass north of the International Fountain . . . and would not cause significant impacts to the passive enjoyment and community gathering uses that characterize the space" (emphasis added). Please clarify the "will and would" conflict. We do not find analysis that supports this conclusion.

Alternative 4.1 (4.3.2.1, p.4-151) - "Although an adverse impact on the historic resources within the district has been identified, the overall impact on land uses and neighborhood vitality could be positive, given the access improvements, site improvements, and the potential to create public space connecting to nearby parks." (emphasis added). Does this imply SMP commitment to mitigation through improvements outside of the station footprint? If so, please elaborate.

Mitigation (4.3.3, p.4-158) - These mitigation measures are so general as to be virtually incomprehensible.

Visual Quality and Aesthetic Resources (4.5, p.4-170) Use of the FHWA methodology is far too general to apply to dense urban contexts. Characterizing the monorail as a "lineal transportation facility, like a highway" (4.5, p.4-170) is disingenuous. Explanation of the use of the "low-", "moderate-", and "high contrast" measurement scale (p.4-194) needs considerably more elaboration to be useful in assessing impacts. While the "key view simulations" provide a means for the reader to understand and evaluate visual impacts, their location in Appendix M, not with the text, makes if difficult for the reader to follow the analysis. We are also concerned that a number of "key" locations have not been simulated. For example, there are none showing the impact of the proposal on Second Avenue adjacent to the Seattle Art Museum and Benaroya Hall, nor near the King Street Station - all three are certainly "key" buildings that are architecturally important and should be addressed in this analysis.

We believe that before SMP and the City can make alignment and station location decisions, the true environmental impact of these decisions must be more carefully addressed through design principles and guidelines that are promulgated through open public process. This may require further environmental review. We are curious about the November 18 and 19 All-City Forums where the SMP "will be presenting our initial recommendations on where the Green Line should run and station locations". Since these forums will be conducted long before the FEIS is completed, we do not understand how these recommendations can be made.

We appreciate that the SMP has been working diligently to address these issues, and we are prepared to help in any way that we can.

Sincerely,
/s/
Roger K. Wagoner AIA, FAICP
Peter Hockaday FAIA
CoChairs, Urban Design Committee

Reference: AIA Seattle Advocacy