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January 8, 2008

Michael Dorcy, Senior Land Use Planner
Department of Planning and Development
700 - 5th Avenue, Suite 2000
P.O. Box 34019
Seattle, Washington 98124-4019

RE: Downtown Project #3007582: Availability of Addendum to Environmental Impact Statement for Development and Downtown Height and Density Changes, for 811 5th Avenue (Seattle First United Methodist Church)

Dear Mr. Dorcy,

The Seattle Community Council Federation, a coalition of community groups throughout the city, asks that the Department of Planning and Development's Design Review Board to consider the following seven points for assuring historic preservation of the First Methodist Church Sanctuary Building. The project description now includes development of a 43 story, 760,000 sq.ft. office tower with below-grade parking for 290 vehicles. The project also includes demolition of the education/human services wing of existing church (First United Methodist), as well as removal of significant open space courtyard. Existing sanctuary portion of church and private club (Rainier Club) are to remain. The following seven points include SCCF testimony on January 8th and address concerns regarding the Addendum to Environmental Impact Statement as provided for 811 Fifth Ave. Development and Downtown Height and Density Changes.

1. On January 8, 2008, we learned of several departures from our last public comment meeting of September 11, 2007. For the first time the Department of Planning and Development informed the public that the Daniels Development Company has now replaced Nitze Stagen as the legal developer for the site at 811 5th Avenue.

2. Another departure update included a new plan to slightly uplift the proposed office tower building in order to provide more substantial separation from the historic sanctuary building. As public comment we want for the developer to respond to the scale of the church and modify the skyscraper's close proximity to the church. Our public input supports even more separation of space between the sanctuary building and the office tower, in order to preserve the architectual integrity of the sanctuary with its two sources of pedestrian access to the sanctuary from both 5th Avenue and from Marion Street. Any office towers' cantilever development that would overhang and violate access to the 1908 church sanctuary building should be rejected because such overhanging violates the historic site.

3. SCCF has indicated that the current access to the existing church sanctuary building entry doors on both 5th Avenue and by way of Marion Street needs to be maintained and to function for historic building presence, use, and integrity, or as shown by a comparable development next to an historic site in the example of the downtown Washington Mutual Tower still preserving the Brooklyn Building's original access doors off of both 2nd Avenue and University Street.

4. Another departure from the earlier MUPs of 2004 and 2006 involves removal of the Rainier Club from the Daniels Development Company's interpretation and use of the former MUP that included the Rainier Club. What is unresolved, by excluding the Rainier Club's expansion of approximately 1,500 square feet (MUP #2004), becomes the pedestrian access to avoid destruction of the original sanctuary building doors that exit on Marion Street. The Daniels Development Company has not addressed how public interest would be served for historic preservation. Nor has the developer addressed adverse environmental impacts from two vehicular driveways for the new underground parking garage (MUP 2004 and MUP 2006). An entrance-only driveway can be located on Columbia Street. Yet, how can an exit-only driveway be located on Marion Street, when DPD has failed to address the developer's transportation impacts to both historic buildings? DPD and the Daniels Development Company could seek an amendment alternative for a partial change to the 1885, City Ordinance #656 that vacated the public alley space between the church and the Rainier Club.

Furthermore, the Rainier Club withdrawal of its health/exercise addition from Project: 3007582, further questions the surrounding environmental impacts by the developer's setback departures of both the "living wall" and the developer's Columbia Street driveway access to the large underground parking garage adjacent to the historic Rainier Club.

5. On January 8, 2008, the Daniels Development Company announced another departure from the City's guidelines for required setback space. The proposed compromise is to offer an eight feet high and 20 feet long south wall buffered with year round plants, a so-called "living wall." While plants can provide visual interest and natural contrast to concrete, the developer wants the City to compromise legal space requirements. After the public will lose the open space between the sanctuary and the education/human services wing of the church, the developer seeks for DPD to redefine open space as an "artistic concept" of a wall with flowers and vines. Apparently, the Daniels Development Company seeks to abolish a courtyard and a large old-growth redwood tree, in exchange for the developer's so-called "sculptural water" and "living wall" as suggested by the developer's California artist friends. If the City signs off on legal open space requirements, at the very least, DPD could stipulate a 2% local arts competition fee to re-design any so-called public art to replace open space.

6. As soon as possible, the Daniels Development Company still needs to address public safety issues for seismic upgrade and structural engineering to the remaining sanctuary building. Because of the Design Guideline priorities for this site, as established in the Early Design Guidance Board meetings, there should be a more clear description and a specific plan for moving thousands of cubic yards of dirt for construction of both the vehicle parking garage and the foundation for the 41 floor office building. How has DPD's responsibilities for upholding SEPA guidelines addressed heavy construction related impacts to the historic sanctuary's priceless windows, pipe organ, and legendary architecture, as well as related construction impacts to the historic Rainier Club?

7. Since the project application's address, 811 5th Avenue, applies to DPD's Project No. 3007582, the Design Review Board for Seattle Department of Planning and Development must address another departure of significant environmental impacts to the entire property at this address and provide more specific information on land uses of the sanctuary building. This developer's addendum fails to include the sanctuary's actual property address of 811 5th Avenue, because the Daniels Development Company and DPD omit analysis and reference to the uses of the sanctuary building. The Design Review Board must address uses of the sanctuary building, such as a public performing arts center, to work in a complementary way with Town Hall. In fact, public groups rallied to stop destruction of the church sanctuary, as supported by public money from the National Historic Trust and King County. Where is DPD's application of design guidelines for the actual property land uses represented by the address of 811 5th Avenue? Prior testimony suggests outreach for many variable nonprofit community connections.

Sincerely,

Marietta Foubert

SEATTLE COMMUNITY COUNCIL FEDERATION
2511 West Montlake Place East
Seattle, Washington 98112