PC038 Jerry Basler 09-18-2015From:jerry basler
To:Christina Janssen
Subject:Painted Hills SUB2015-0001/PRD 2015 0001
Date:Friday, September 18, 2015 9:35:03 AM
Attachments:Christina Janssen Planner.docx
Please confirm receipt.
thanks.
Jerry Basler
Christina Janssen Planner
City of Spokane Valley
11707 E. Sprague Avenue #106
Spokane Valley WA 99206
RE: Painted Hills (SUB-2015-0001/PRD-2015-0001
Thank you for the opportunity to comment on the Painted Hills Planned Unit Development. This
proposed project appears to have several questions associated with environmental aspects, built
environment, safety, and health.
First, the area inside the City of Spokane Valley is zoned either low density residential, or medium
density residential. As this project is adjacent to the Urban Growth Boundary with Spokane County, the
zoning in Spokane County is rural zoning. Although this project is being submitted as a Planned Unit
Development under City of Spokane Valley code, it contains several questionable aspects.
1. Normally du/acre is used to determine density. In this case we also subtract the 30% open
space, so the actually density is approximately 4.3 units per acre. This would be considered the
“high end” of a normal single family residential zoning, of 1-5 units per acre, and above any type
of County rural zoning of a 1 unit per 10 acres minimum. It becomes obvious that this dense of
a development does not fit into the current built environment and surrounding zoning.
2. Using the standard of 2.5 residences per unit, = 757 individuals, the surrounding roads are not
equipped to handle the projected traffic. Unfortunately the traffic study submitted by the
developer, does not take into account University High School, Horizon Middle School, and
Sunrise Elementary, and the traffic it projects into the surrounding area. Mainly the traffic
congestion that will occur at S. Pines Rd. and 32nd, E. Thorpe Rd. and Dishman Mica, Bowdish
and 32nd , and the traffic that will cause serious impairment at 16th and Pines. Currently it is a 5
way unmarked intersection functioning at a level “F”. This project will overwhelm this 5 way
intersection. Additionally, there are several other intersections that will be seriously impacted
by this development that were not included in the traffic study.
3. There is an identified “fish” bearing stream on the southwest of the property, this development
will seriously degrade the stream in temperature and function, due to the increase in runoff
contaminants from the development, and the increase in water temperature that will occur due
to the development of open space into heat absorbing/reflecting of pavement and buildings.
4. The traffic study failed to “count” traffic at specific locations at specific times, especially at 32nd
and Pines, and 32nd and Hwy. 27, at peak hours when students are arriving and leaving
University High School. Additionally, the traffic counters were only counting traffic in certain
directions, which gives the impression of less traffic at specific locations in the area, in an effort
to avoid the “peak” hours of University High School, Horizon Junior High, and Sunrise
Elementary. This is of major concern.
5. Most of the subject area is a floodplain. Which will require extensive “stormwater planning”,
including how stormwater will be handled. At the time of this letter, there has been no solid
coordination plan as to where and how the stormwater is going be handled in relation to the
developer owning or leasing nearby land to be used in stormwater management, and has not
shown any (lease paperwork), (sales agreements), or (easement paperwork), allowing them to
use adjoining property for stormwater dispersion.
6. How is the dirt associated with the project going to be handled, I didn’t get a clear indication
from the SEPA checklist. As you know, any fill dirt over 100 cubic yards moved off-site requires
permits, and must comply with standards on how it is to be disposed of, if moved off-site, and is
regulated by the Department of Ecology.
7. The plans as presented by the developer show a mix use of housing incompatible with the
surrounding uses. To the north is single family house. To the east, single family housing
blending into open space. To the south, single family housing, blending into open space and
large tract residential. To the west is open space.
8. The proposed development does not match the current comprehensive plan, (not any future
comprehensive plan), but the current comprehensive plan of Low Density Residential, which
translates into the zoning of 1-5 units per acre, which generally consists of single family
residential, not townhouses, apartments, and zero-lot line development as proposed.
9. The developer does not show any “enhanced” pedestrian improvements including enhanced
sidewalk or bike paths along Madison, and further north along Pines, south of 32nd. A project of
this size will increase traffic, posing a threat to the safety & welfare of pedestrians in this area,
and to surrounding neighborhoods.
10. Due to the size of the project at full build-out, the Central Valley School District’s three schools,
University High School, Horizon Middle School, and Sunrise Elementary will be beyond full
capacity due to the influx of students from this development, based on current and projected
infrastructure needs in the Central Valley’s School Districts Capital Facilities Plan.
11. As you know, concurrency and consistency are required under the Growth Management Act.
The City does not show in it’s capital facilities plan, or future road plans, improvements that will
be required to surrounding roads, due to the impact and the size of this project.
12. As you know, concurrency and consistency are required under the Growth Management Act.
The the City does not show it can effectively provide police services to meet the demands of the
increased population. Currently the City has 11 officers per 10,000 residents, well below the
City of Spokane at 18 per 10,000 residents. (per 2012 Uniform Crime Reporting Program). As
police services are contracted with the Spokane County Sheriff’s Department, and due
continued budget constraints, this number per capita has not increased substantially since 2012.
13. As you know, concurrency and consistency are required under the Growth Management Act.
The City, and the developer, have not effectively shown that there is the infrastructure, or
future identified funding sources to effectively facilitate the processing of sewage and
wastewater with a project this size, without large future financial outlays, including bond sales,
to fund these improvements. Again these funding sources need to be identified by the City.
Additionally, there is the issue of the cost’s associated with agreements with the City of
Spokane, or Spokane County, depending where the sewage and wastewater is going to be
treated, that will be needed in the future.
In regards to the above, which I’ve listed below,
1. stormwater,
2. sewage and wastewater,
3. traffic,
4. built environment,
5. inconsistency between the comprehensive plan, the zoning ordinance, and the development
plans and size,
6. impact to 3 schools in the immediate area,
7. Wildlife and environmental concerns,
8. Safety
9. Lack of identified current and future funding sources by the City of the Valley, required by the
Growth Management Act,
-which combined together, all relate to health, safety and welfare of the nearby neighborhoods, and the
students at University High School, Horizon Junior High, and Sunrise Elementary School. This project
rises well above a standard Environmental Determination of Non-Significance (DNS), or even Mitigated
Determination of Non-Significance, (M-DNS).
Combining all the questions still unanswered with the application and SEPA checklist, the size of the
project, and all the impacts associated with the development, (current and future), this project will
require an Environmental Impact Statement to be prepared by the developer to further investigate and
discuss the many “unresolved” issues associated with this development proposal.
Thank you for your consideration,
“SIGNED”
Jerry Basler
13011 E. 27th Ave,
City of Spokane Valley, WA 99216