We have already received the first response to our recommendations report submission last night. Mr. Greve expresses concern that we need to correct some data and asks that the county be allowed “a read of a near-final draft before circulating, in order to make sure the correct data is represented.”
My thought is that I always consider any submission a kind of work in progress – perpetually subject to correction and improvement upon availability of new facts and data. So I believe data corrections, as I outline below, are a welcome improvement to our report.
Please have a look at his email and my response below, then let me know if the next steps I have outlined below are how you want me to proceed. I especially need guidance on the timing you want as we move forward. I have a whole list of residents in other TDR receiving communities, elected officials in jurisdictions with a stake in this issue, local/county/state staff, community groups, press and planning/architect/other professionals to whom I want to send our report. This issue affects us all, and I want to be sure that they all know about what we have found and that we get to learn from their perspectives. PLEASE send me your feedback!
From: highlands_neighbors@hotmail.com
To: darren.greve@kingcounty.gov; paul.reitenbach@kingcounty.gov; bob.burns@kingcounty.gov; lauren.smith@kingcounty.gov; chandler.felt@kingcounty.gov
Subject: RE: CARE Recommendations Report: Public Review Draft 2012 KC Comprehensive Plan Update
Date: Thu, 17 Nov 2011 14:08:45 -0800
Dear Darren,
Thanks so much for your speedy feedback. Especially when you are headed out of the office, I understand the impact to your day and really appreciate the effort at the last moment.
I am only too happy to make corrections! Thank you for sharing information that makes that possible.
However, I expect that there will be considerable reluctance from our community to wait as long as requested (your return date on 12/7) before moving forward with our planned outreach effort, particularly in light of the current close of the comment period on 12/23. There is a lot of complex information with which to become familiar, consider, and prepare comments. I will discuss a delay with the community and let you know the consensus that emerges when I share your request with them. I believe it may be reasonable to delay any increased distribution – if more data will be made available right away – until Monday, but I know that there is very strong support to reach out to other affected communities and jurisdictions quickly, and I already posted our initial report to the email list last night and the blog this morning. I very much agree on the necessity of correct data to a productive conversation. I believe the discussion below is likely sufficient to continue to move forward.
I will forward these comments to CARE’s email list right away and also post to the blog.
Here are my off-the-top-of-my-head thoughts to the counterpoints you have shared below:
· Sammamish amenity funds is not $1.875 mill (as shown on pgs 1 and 3) it is $375K;
<gh> -The additional dollars include our calculation of the transfer of 25% per TDR price that is quoted in the ILA at $80K per TDR. (Base incentive funding of $375K) + (75 * (80K * .25) = $1.875M.
· The report is missing the TDR receiving site projects built in City of Issaquah (page 2 of report)
<gh> – We are focused exclusively on dwelling units that have resulted from the transfer of development rights. There has been no interest or concern expressed regarding TDR incentives for increased building heights, commercial floor space, etc. Thus, we have not done any analysis of TDR projects other than those resulting in dwelling units. We wanted to keep our comments reflective of the situations with which we have experience. We also want to keep this as much an apples to apples conversation as possible. I will make this focus more clear in our next report release.
· Report cites that 67% have been used in unincorp KC (pg 3), but correct # is 48% – i.e. A total of 253 TDRs have been used in ALL receiving site projects; 52% or 131 of these have been used inside cities (which have the walkable amenities your report is analyzing); I know this # has been a bit of a moving target as we gathered data over the last year, but this is KC’s reported official # based on the data.
<gh> – Our numbers include not only the Built dwelling unit data that you shared with us, but also the additional 99 units that we have found to have been approved by the Hearing Examiner. It is possible that there are more. There appears to be no formal tracking of the vested right to TDR approvals. We searched through the case digest tool available on the Hearing Examiner’s site and listed the HE reports from which we pulled this data in the Appendix of our report. We would very much appreciate a more complete and authoritative dataset from King County. These units are vested to the properties, so we consider them a done deal. They can not be removed from the pipeline at this late date.
· Black Diamond TDR reference (pg 3) is for TDRs that come from WITHIN the city – the 1,929 TDRs are not KC related; this is an in-city TDR program.
<gh> – Thank you for this information. I saw this morning that you had indeed answered this question yesterday afternoon. Thank you for the answer to that specific question. I will add a footnote in the next report release, but I believe there may be more for us to discuss – at the very least so that we understand this aspect of the TDR program better.
· There are not 4,388 units/lots currently available from TDR; you are close, but the correct number is 3,853, here’s how you get there:
o There are 2,053 total TDRs currently available;
§ 253 of these are “Urban” TDRs coming from urban separator sending sites (each one of these = 1 additional unit/lots)
§ 1,800 of these are “Rural” TDRs coming from Ag, F and Rural zoned sites (each one of these = 2 additional units/lots; of these rural TDR, 631 are privately held and the other 1,169 are held by the KC TDR bank)
§ Therefore the total # of units potentially available from TDR in unincorporated urban KC = 253 + (1800×2) = 3,853
§ Much of the 2,053 TDRs available will move into cities; if past data predicts future, you can say half of the 3,853 potential units would land in unincorp KC UGA. However, KC’s ongoing and future goal is to focus the large majority of TDR transfers into cities. Evidence of this is the fact that we now have 3 on-going TDR agreements with cities (compared to only 1 at any given time in the past), and will likely have 5 by 2012 and more as we grow the focus of KC TDR to be with cities.
§ Thus, on pg 15 of your report, I think it is misleading and inaccurate to state “We have as many as 4,388 TDR units sitting on the shelf today with no place for them to go except the Urban Unincorporated Areas.”
<gh> – Thank you for the clarifying information. We could not find the clear statement of conversion rates for the on-the-shelf TDRs. I believe we need to see a clear and complete dataset at some relatively near point in time. Perhaps we should discuss that in more detail in person. That level of technical discussion can be frustrating in email. Until we have that data, I will update our next report release acknowledging this new information.
A final interesting stat related to the intro TDR policy in the current comp plan, Policy R- 313 which states: “The Priority of the TDR program is to reduce development potential in the Rural Area and Resource lands by encouraging the transfer of development rights into the Urban Growth Area.”
· 99% of all development right transfers in KC’s TDR program have relocated development into KC’s UGA
Your report raises the question about where in the UGA, and under what criteria (eg walkability etc); current comp plan policy is relatively silent on this.
<gh> – The need for policy and law to articulate adequate receiving site criteria to ensure appropriate siting of TDR receiving sites is indeed one of the top issues we hope to address, but please know that equitable amenity funding is also of critical importance.
This is a great opening to the next phase of our collaborative efforts on the King County TDR Program. Thanks again for your fast and thoughtful response. Have a great vacation!
Happy Thursday!
Gwendolyn
From: Darren.Greve@kingcounty.gov
To: highlands_neighbors@hotmail.com; Paul.Reitenbach@kingcounty.gov; Bob.Burns@kingcounty.gov; Lauren.Smith@kingcounty.gov; Chandler.Felt@kingcounty.gov
Date: Thu, 17 Nov 2011 12:27:06 -0800
Subject: RE: CARE Recommendations Report: Public Review Draft 2012 KC Comprehensive Plan Update
Thanks Gwendolyn –
I’ll be out of town until Dec 7th, but wanted to convey a couple points after a quick read through your report.
Overall, I think your report and analysis is good, and can lead to some good policy discussions.
In the spirit of cooperation and coordination, as articulated on page 1 of your report, I would hope you would want to allow KC a read of a near-final draft before circulating, in order to make sure the correct data is represented.
In the short time I had to review, below are a few points that I think you should correct in your report to convey accurate data and information – doing so will lend more credibility to your analysis than if the #s are incorrect, especially if your plan is to circulate this broadly.
I look forward to further discussions when I get back.
-Darren
Here’s what I think you should quickly revisit in your report:
· Sammamish amenity funds is not $1.875 mill (as shown on pgs 1 and 3) it is $375K;
· The report is missing the TDR receiving site projects built in City of Issaquah (page 2 of report)
· Report cites that 67% have been used in unincorp KC (pg 3), but correct # is 48% – i.e. A total of 253 TDRs have been used in ALL receiving site projects; 52% or 131 of these have been used inside cities (which have the walkable amenities your report is analyzing); I know this # has been a bit of a moving target as we gathered data over the last year, but this is KC’s reported official # based on the data.
· Black Diamond TDR reference (pg 3) is for TDRs that come from WITHIN the city – the 1,929 TDRs are not KC related; this is an in-city TDR program.
· There are not 4,388 units/lots currently available from TDR; you are close, but the correct number is 3,853, here’s how you get there:
o There are 2,053 total TDRs currently available;
§ 253 of these are “Urban” TDRs coming from urban separator sending sites (each one of these = 1 additional unit/lots)
§ 1,800 of these are “Rural” TDRs coming from Ag, F and Rural zoned sites (each one of these = 2 additional units/lots; of these rural TDR, 631 are privately held and the other 1,169 are held by the KC TDR bank)
§ Therefore the total # of units potentially available from TDR in unincorporated urban KC = 253 + (1800×2) = 3,853
§ Much of the 2,053 TDRs available will move into cities; if past data predicts future, you can say half of the 3,853 potential units would land in unincorp KC UGA. However, KC’s ongoing and future goal is to focus the large majority of TDR transfers into cities. Evidence of this is the fact that we now have 3 on-going TDR agreements with cities (compared to only 1 at any given time in the past), and will likely have 5 by 2012 and more as we grow the focus of KC TDR to be with cities.
§ Thus, on pg 15 of your report, I think it is misleading and inaccurate to state “We have as many as 4,388 TDR units sitting on the shelf today with no place for them to go except the Urban Unincorporated Areas.”
A final interesting stat related to the intro TDR policy in the current comp plan, Policy R- 313 which states: “The Priority of the TDR program is to reduce development potential in the Rural Area and Resource lands by encouraging the transfer of development rights into the Urban Growth Area.”
· 99% of all development right transfers in KC’s TDR program have relocated development into KC’s UGA
Your report raises the question about where in the UGA, and under what criteria (eg walkability etc); current comp plan policy is relatively silent on this.
Appreciate your work on this, and I look forward to discussions when I get back.
-Darren
Written by gwendolynhigh
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