15 September 2017

Lindsay King Lindsay.King@seattle.gov

Seattle Department of Construction and Inspections
700 5th Ave., Suite 2000, Seattle, WA 98124

Subject: Comments on University of Washington Campus Master Plan (CMP)

The Sierra Club recommends a set of policy and program revisions that will strengthen the
University of Washington’s 2018-2028 Campus Master Plan (CMP). Expansion of the UW as
contemplated in the CMP will create impacts that we assess to be inadequately mitigated, and
which will create significant effects to the transportation system thereby increasing the climate
footprint of travel associated with the planned UW expansion.

Sierra Club supports transportation policies that strengthen local communities, towns and urban
centers, and promote equity, while reducing emissions of greenhouse gases (GHGs) and
promoting well-coordinated transit service with convenient intermodal connections. With about
14,000 King County members and a membership of 31,000 in the Washington state Chapter, the
Sierra Club supports an equitable transition to clean energy that protects a recognizable climate,
and will support vibrant urban places that use compact, walkable communities and convenient,
accessible transportation options to reduce the environmental footprint on our air, water, forests,
and adjacent wildlands. We promote better coordination of housing density and low-climate
footprint transportation to make urban areas like the UW more energy and resource efficient.

In consultation with community partners in the U District Alliance, we have concluded the UW
expansion will create impacts affecting our members and the residents in and near the University
District that are not adequately identified in the UW’s Environmental Impact Statement (EIS),
and that are not mitigated in the UW’s CMP. We also believe the CMP is inconsistent with the
Seattle 2035 Comprehensive Plan (SCP) in several key areas, including transportation and
housing. We find it highly unlikely that no negative unavoidable traffic and transportation
impacts will result from growing the UW population by 13,000 people during the next 10 years.
We urge the DCI to require UW to mitigate all 6,195 new single-occupancy vehicle (SOV) trips
created by new development by establishing a target of 12% SOV campus-wide by 2024.

Transportation Management Plan

The City of Seattle should condition the proposed UW Transportation Management Plan (TMP)
to improve traffic, transit, and pedestrian and bike safety; reduce neighborhood, environmental
and climate impacts, and reduce transportation inequities affecting lower wage workers.
Authority
The City of Seattle may require the UW to provide mitigation of additional traffic and other
transportation impacts of additional growth, as a condition of approving the UW CMP, based on
the City/University Agreement, the State Environmental Policy Act, and the Seattle
Comprehensive Plan.
From the City/University Agreement, amended 2004:
Section II. A.1.f. A transportation plan which will include specific University programs to reduce traffic
impacts and encourage the use of public transit, carpools, vanpools, and other alternatives to single
occupancy vehicles. (Emphasis added)
Section II.A.2. The University’s Master Plan and EIS will include information on its proposed
developments. It will include a proposed development schedule in sufficient detail to permit analysis of
impacts on adjacent neighborhoods and City facilities and services.
Section III. B. 1. Traffic. The City, which is responsible for the regulation and control of City streets, has
determined that the university area is substantially impacted by automobiles during peak periods. As
traffic on major arterials in the university area approaches capacity, commuters extend the peak periods
in an effort to avoid congestion or seek alternate routes through neighborhoods by traveling on
residential streets which are not designed for through traffic.
Section III. C. 5. The University will support the City and adjacent communities in improving traffic flow
on street networks surrounding and leading to the University including decreasing the impact of street
parking. The University and the City recognize that streets in neighborhoods in the university area at a
distance from the University may also be impacted by street parking by University-related commuters
who continue their commute trip by other means such as walking, rollerblading, bicycle, carpool, and
transit.
From Seattle’s Comprehensive Plan 2035:
LU 14.3 Establish Major Institution Overlays (MIO) as a designation on the zoning map and the Future
Land Use Map to show areas where development is regulated by the contents of a master plan, rather
than by the underlying zoning. Balance the need for major institutions to grow and change with the
need to maintain the livability and vitality of neighboring areas. Where appropriate, establish MIO
boundaries for better integration between major institution areas and less intensive zones.
LU 14.13 Establish minimum parking requirements in MIO districts to meet the needs of the major
institution and reduce parking demand in nearby areas. Include maximum parking limits to avoid
unnecessary traffic in the surrounding areas and to limit the use of single-occupant vehicles.
LU 14.14 Use the transportation management program to reduce the number of vehicle trips to the
major institution, minimize the adverse impacts of traffic and of institution-related parking on
surrounding streets, and minimize parking demand on nearby streets, especially residential streets. To
meet these goals, seek to lessen the number of single-occupant vehicles used for trips to and from

2
major institutions at peak times. Allow short-term or long-term parking space requirements to be
modified as part of a transportation management program.
LU14.16 Require a master plan whenever a Major Institution proposes development that could affect
the livability of adjacent neighborhoods or has the potential for significant adverse impacts on the
surrounding areas. Use the master plan to:
• Provide the basis for determining appropriate mitigating actions to avoid or reduce adverse
impacts from major institution growth.
• Describe a transportation management program
T. 3.6 Make transit services affordable to low-income residents through programs that reduce
household transportation costs.
T 3.22 Assess the affordability and accessibility of existing and potential transportation options in order
to better inform decisions affecting the equitable provision of transportation services.
T3.8 Provide high-quality pedestrian, bicycle and bus transit access to high-capacity transit stations, in
order to support transit ridership and reduce single-occupancy vehicle trips.
T3.9 Develop and maintain pedestrian and bicycle facilities that enhance the predictability and safety of
all users of the street and that connect to a wide range of destinations.
T 4.3 Reduce drive-alone vehicle trips, vehicle dependence, and vehicle-miles traveled in order to help
meet the City’s greenhouse gas reduction targets and reduce and mitigate air, water, and noise
pollution.
T 9.2 Provide a menu of transportation-demand management tools for future development to meet
non-drive-alone mode share targets, provision of transit passes, carpool benefits, and improvements to
pedestrian and bicycle facilities.
GS 1.6 - Plan for development in urban centers and urban villages in ways that will provide all Seattle
households, particularly marginalized populations, with better access to services, transit, and
educational and employment opportunities.
GS 1.7 - Promote levels of density, mixed-uses, and transit improvements in urban centers and villages
that will support walking, biking, and use of public transportation.

From Seattle 2035 Equity Analysis:

Promote Transportation and Connectivity - Prioritize investment in effective and affordable
transportation that supports transit-dependent communities.

Transportation Recommendations
Sierra Club recommends that the City of Seattle condition the CMP to require the following
actions:
1. Overall TMP Performance Measure - SOV Trip Mitigation - The UW should commit to
adjust its single-occupancy vehicle (SOV) performance measure from 15 percent to 12

3
percent to completely mitigate 6,195 new SOV trips (including visitor trips) anticipated in
the CMP by 2028.
Rationale: The UW plans on adding 20 percent to its campus population by 2028 adding
6,195 new SOV trips, which will result in an unsustainable increase in congestion.
a. Increased Congestion to LOS F and 4.7 times more vehicle delay - Presently, 6
out of 13 key U District intersections are at LOS E or F with 420 cumulative seconds of
delay. With a reduction to 15 percent SOV by 2028, 11 out of 13 key U District
intersections are at LOS E or F with 2,394 cumulative seconds of delay. The UW TMP
must completely mitigate these 6,195 new trips by 2028 to maintain existing traffic flow.
See Table 10.1 - SOV Sensitivity Analysis at Key Impacted Intersections Note: This is
the only information in the entire TDR which models what would happen at a 15 percent
SOV rate as well as 20 percent SOV rate, which is the ongoing assumption in the EIS.

4
b. Transit Speed and Reliability Degraded - In the seven transit corridors serving
the U District, delay will range from six percent to 63 percent with an average delay of 21
percent in six of the seven corridors. Only Stevens Way Westbound registers no delay in
2028. See Table 5.13 Comparison of Transit Speeds (TDR P. 5-16)

This transit speed delay from U District congestion will result in greater difficulty for the
UW to attract new riders to the transit system to help meet the SOV reduction required
for mitigation.

c. Problem of the Peak in the U District - Ross Tilghman, traffic consultant to the U
District Alliance, summarizes the peak hour issue in the U District:
“The number and location of trips occurring in the Peak Hour greatly affect intersection
levels of service. As UW expands its West and East campus areas, it adds trips to
intersections that now handle relatively modest volumes. Many of these intersections
lack signal control, so delay increases greatly.
Furthermore, the largest growth in population occurs in staff, who drive more and travel
more in the peak hour than students and faculty. Extra efforts will be needed to reduce
staff vehicle trips in the peak hour, including stronger incentives to use transit. This
would entail a lower SOV rate than 15%.
Accordingly, a twin goal of not increasing campus trips coupled with more aggressive
transportation management and mitigation of individual intersections to maintain No
Action levels of service would allow the University growth without impeding University
District traffic and transit circulation.”
Precedent for a SOV Goal Adjustment by City comes from the Swedish Cherry Hill
MIMP/TMP (2016), and the Children’s Hospital MIMP/TMP (2010). Supporting

5
 policies include: CUA Sec. III.C.5, and SCP Policies LU 14.3, LU 14.14, LU 14.16, T
4.3.
2. Enforcement: UW proposes denial of further building permits for the University in 2028,
after all CMP development if a reduction of SOV from 17.3 percent measured in 2017 to 15
percent in 2028 is not achieved. The UW will exceed the morning trip cap in 2025 with no
effective mitigation. The City should delay successive building and occupancy permits over
the 10 year period should the University not show continuous progress toward the following
milestones:
Date SOV Milestone Notes
2018 17% Actual - 17.3% in 2017
2020 15%
2022 13% (Sound Transit Light Rail open U District/ 45th St. to Northgate)
2024 12% (Light Rail open to Lynwood and Redmond)

Precedent for mitigation milestones comes from the Swedish/Cherry Hill MIMP/TMP.
Precedent for measurement of performance comes from the Children’s Hospital MIMP/TMP.
Precedent for an enforcement mechanism comes from the UW 2018 CMP/TMP proposal.
Policy Support comes from CUA Sec II.A.2, Sec III.C.5, and SCP Policies LU 14.3, LU
14.14, and LU 14.16.
Rationale: Without effective enforcement, there is a high likelihood that these
recommendations and mitigations would be only partially completed, based on past
performance. We urge the City to insist on CMP commitments measured through
milestones, and backed by sanctions including holding up permits until milestones are
completed.

3. Trip Mitigation Measures - Sierra Club requests that the TMP be specific and detailed in
terms of the Transportation Demand Management (TDM) strategies to be implemented, the
implementation timing, and the anticipated impact each will have on SOV mode split. Given
CUA Section IIA1F, the following specific TDM strategies are proposed for the UW to
achieve 12 percent SOV rate by 2024:
a. UPass Enhancement - UW must join Seattle area major employers in providing
a free Orca card to achieve a fully-mitigated 12 percent SOV rate and to improve equity
for low-wage workers. The TMP cites the development of the UPass in 1991 for the
successful management of growth of trips to the campus. The UW is justifiably proud of
this long-term accomplishment. However, the last five percent reduction of SOV from
17.3% to 12% will represent the biggest challenge. The existing UPass program needs
enhancement to continue to be an effective incentive to SOV trip mitigation.

6
• The staff drive-alone rate was 38 percent in 2002 and was still 36 percent in 2016
and remains relatively flat even with the arrival of Light Rail.
• Staff represents 46 % of the projected SOV rate in 2028 and should be the major
target for UPass usage.
• UPass user cost for staff was $27 per quarter in 1991 and now is $150 per quarter.
Applying a cost of living increase from 1991 would make the UPass $48 per quarter in
2018.
• Transportation Choices Coalition reports that recent information supplied to
SDOT shows the combined subsidies (faculty, staff and students) are currently only 30%.
The standard MIO subsidy is 50%.
• Microsoft, King County, Children’s Hospital, and Adobe all provide a free Orca
card to employees while City of Seattle, Seattle University, Swedish and Boeing
(downtown) provide an Orca card for $10-$20 per month user fee or $30-$50 per quarter.

Precedent for Conditioning the UPass is found in the Swedish/Cherry Hill and Children’s
MIMP/TMPs. Policy Support is found in the CUA Sec II.A.1.f, Sec II.A.2, and SCP
policies LU 14.14, LU 14.16, T 3.6, T 3.8, T 3.22, and T 9.2.

b. Parking Management - Parking supply and pricing are extremely strong factors
in reducing the SOV rate. The existing parking cap and introduction of the UPass
program in 1991 depended on a simultaneous increase in parking rates as well as a
decrease in the cost of HOV alternatives. However, given the relatively flat participation

7
of faculty and staff in the last 20 years, the existing UW TMP has captured the “low
hanging fruit” and needs to develop new and enhanced strategies to fully mitigate the
planned CMP SOV growth.
• The TMP should commit to adjust the 1984 Parking Cap (12,300 spaces)
downward to 9,000 spaces to reflect the mitigation of trips from the two most recent
TMPs and the 6,195 new SOV trips that need to be mitigated in the proposed 2018 TMP.
• The Parking Cap should include the 750 parking spaces serving the UW Tower
not now counted under the current Parking Cap.
• The TMP should commit to NOT replacing parking supply lost to new
development on a one to one basis. This would be an important element of a new, lower
Parking Cap. The TMP envisions need for up to 5,000-7,000 structured parking spaces to
replace existing surface lot spaces needed for building development. Operational savings
from reduced financing costs for structured parking bonds should be recognized and
shifted to support mitigation programs to meet the 12 percent SOV rate.
• The TMP should commit to end the monthly “discount” parking rate and shift to
pay per use for all parking, with an incentive system similar to Children’s Hospital.
• Parking pricing should be based on demand, with higher parking rates for lots
with higher usage and lower rates for night-time usage when transit options are fewer.
• Night parking should be geared to employee ability to pay for employees working
night shifts with less frequent transit access.
Precedent for conditioning for parking comes from the Swedish/Cherry Hill and
Children’s Hospital MIMP/TMPs. Policy support comes from SCP policies LU 14.13 and
LU 14.14.

c. Transit Access - The TMP puts a major emphasis on Transit to help reach the
SOV goal. However, there is no specific plan for how the UW will facilitate the
increased access to transit as demand grows. The following measures can improve transit
access:
• Develop, implement, and sustain a Mobility Framework for the campus in
partnership with King County Metro, Sound Transit, SDOT, Community Transit, and
WSDOT to manage expanded facilities and services required to handle the increase in
transit services. See example in the Mobility Framework proposed in the current UW
Bothell Campus TMP.
• Follow the example of the 1991 UPass agreement with King County Metro and
develop transit service partnerships funded in part by the University to supplement transit
services that KCM isn’t able to completely fund on its own. This service partnership was
a critical part of the success of the 1991 UPass agreement.

8
• In partnership with SDOT, King County Metro, and Sound Transit, develop
passenger load zones adjacent to northbound Montlake Blvd. by the UW Light Rail
Station between Husky Stadium and the UW Medical Center, particularly for services
coming from SR 520 to facilitate safe and convenient transfer to Light Rail.
• Maintain the two-way functionality of Stevens Way as an efficient and safe transit
and bicycle circulator by excluding SOV traffic in the peak. We understand that the UW
seriously considered removing transit access to Stevens Way in 2016 thus removing the
one transit corridor out of seven which shows no transit delay in 2028 westbound and
minimal delay eastbound.
Policy Support comes from CUA Sec. II.A.1.f, Sec. III.B.1, and Sec. III.C.5, and SCP
Policies LU 14.3, LU 14.14, LU 14.16, T 3.6, T3.8, T 4.3, and T9.2.

d. Bicycle Program Development – Sierra Club supports Cascade Bicycle’s call for
a UW bicycle mode share of 15 percent to keep pace with the City of Seattle at large as
well as help the UW meet its 12 percent SOV goal. Presently nine percent of the UW’s
population commutes by bike, one of the highest rates in the City. The TMP calls for a
one percent increase by 2028, which is lower than the City’s overall goal of 14.4 percent
by 2030. To reach the 15 percent milestone, the TMP must require the UW to:
• Commit to improve quality and security of bike parking by investing in expanding
covered and high-security parking by 50 percent in each campus quadrant. Adding
bicycle parking in new buildings alone is insufficient to meet current and future demand
for bicycle parking. Although the TDR states that bike parking capacity in existing
locations is sufficient, a recent UW bike report indicated that demand for both short term
racks and long-term/secure bike parking is already greater than currently available in
many places on campus, particularly on the South Campus. The report also identified
concerns of bike theft and lack of safe bicycle access as key barriers to growth.
• Commit to fund the complete upgrade of Burke-Gilman trail to separate bike and
pedestrian paths within campus by 2020. This project has not been completed due to a
“lack of funding”. Funding should be prioritized requiring a date certain for completion.
• Maintain the two-way functionality of Stevens Way as a safe bicycle and transit
circulator by excluding SOV traffic during the peak
• Funding and building the East Campus Greenway - This is the only active
transportation connection east of Montlake to connect the expanded East Campus, Link
Light Rail, South Campus and campus housing and University Village with the Northeast
campus.
• Commit to maintaining campus roadways and paths for bicycle safety.
• Build the South Campus protected bike lane for safe and convenient biking.

9
 Precedent for conditioning bike policies in the TMP comes from the Children’s Hospital
MIMP/TMP. Policy Support comes from the SCP Policies T 3.8 and T 3.9.

e. Pedestrian Program - The projected 16,000 person growth of the University

population will result in more pedestrians reaching campus by transit, vehicles, biking
and walking, and they should enjoy a safe, secure and accessible system approaching and
on campus.
• The University should develop a Mobility Framework to accommodate this
growth in population. It should engage the Transportation Agency Stakeholder Group it
proposes in the TMP to help steer such a Framework which can be used to help integrate
the facilities and services of the various Stakeholders to manage this unprecedented
growth. The UW should follow the example of UW Bothell, which has proposed such a
Mobility Framework in its TMP.
• Commit to identify and completely fund projects identified in the 2017 Pedestrian
Master Plan and Vision Zero in the primary impact zone or in partnership with the city in
the secondary zone.
• Commit to fund sidewalk improvements identified in the 2017 Pedestrian Plan in
five locations in the primary impact zone.
• Establish a specific goal of reducing the pedestrian accident rate as a measure to
inform priority pedestrian improvements.
• Maintain the two-way functionality of Stevens Way as a safe Transit/Bike
circulator by excluding SOV traffic during the peak as a strategy to enhance pedestrian
safety and movement.
• The UW should commit to partnering with the City of Seattle in funding
greenways radiating from the Campus and Burke Gilman trail.
• The UW should commit to partnering with the City in funding construction of
ADA-compliant wheel chair ramps in substandard sites within the primary and secondary
impact zones.
Precedent for pedestrian conditioning of the TMP comes from the Swedish/Cherry Hill
and Children’s MIMP/TMPs. Policy Support comes from SCP Policies T 3.8 and T 3.9.

Housing
Overall, the CMP fails to mitigate the need for additional demand for affordable housing for the
UW’s additional cost-burdened employees and is inconsistent with Seattle Comprehensive Plan
housing policies. The UW fails to analyze the future affordable housing supply needed for low
and moderate income employees, or provide an estimate of future employees who are housing-
cost-burdened. The housing cost burdens created by the expansion have a disparate racial
impact, since workers of color are concentrated in the lowest-paid UW jobs.

10
The U District Alliance estimates that nearly 14,000 current and future UW employees earning
less than 80% of Area Median Income (AMI) will face additional housing cost burdens
associated with the UW expansion. There is clear nexus between a growing UW campus with
more low/moderate income employees and the need for more affordable housing for those
employees. Revisions to the CMP are needed to ensure these actions:
a. The City should condition the CMP to require that the UW provide at least 1,000 units of
affordable housing near campus and in areas such as Southeast Seattle, where many
employees currently reside.
b. The UW should be required to pay MHA affordable housing fees on all new construction
authorized through the CMP until 2028.
c. The City should condition the CMP to require that UW provide appropriate housing,
hygiene, and medical support for UW homeless students.

Open Space
The CMP should be conditioned to require the UW to negotiate with the U District Community
Council to identify and secure an appropriate parcel in the U District to serve as civic open
space. Provision of public open space is crucial when the housing stock is becoming more
densely developed and is especially concentrated near major transit hubs as is appropriate for a
walkable, transit-rich urban center.

Sierra Club appreciates the opportunity to comment on the UW CMP and offer recommendations
for improvements that will help move the UW campus toward a more sustainable and equitable
future. Our vision of a vibrant urban neighborhood with low climate impact is consistent, we
feel, with the educational and research mission of the UW in our climate-constrained future. We
look forward to having the 2018-2028 CMP help the greater University community achieve such
a future.

Sincerely,

Tim Gould
Transportation & Land Use Chair
Sierra Club Washington

11