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Steve Klein 071808IPM.Note 2 comments on the Thurston Highlands Draft EIS Grant Beck Steve Klein Grant Beck SMTP srklein@fairpoint.net 2 comments on the Thurston Highlands Draft EIS EX /O=CITYOFYELM/OU=FIRST ADMINISTRATIVE GROUP/CN=RECIPIENTS/CN=GRANT EX /O=CITYOFYELM/OU=FIRST ADMINISTRATIVE GROUP/CN=RECIPIENTS/CN=GRANT Microsoft Mail Internet Headers Version 2.0 Received: from psmtp.com ([64.18.0.108]) by server1.ci.yelm.wa.us with Microsoft SMTPSVC(6.0.3790.3959); Fri, 18 Jul 2008 08:23:34 -0700 Received: from source ([137.118.16.57]) by exprod5mx284.postini.com ([64.18.4.10]) with SMTP; Fri, 18 Jul 2008 10:21:00 CDT Received: from [127.0.0.1] (unknown [74.209.55.10]) (Authenticated sender: srklein@fairpoint.net) by smtp1.av-mx.com (Postfix) with ESMTP id A639A290315 for <highlands@ci.yelm.wa.us>; Fri, 18 Jul 2008 11:20:32 -0400 (EDT) Message-ID: <4880B4C0.2000308@fairpoint.net> Date: Fri, 18 Jul 2008 08:20:32 -0700 From: Steve Klein <srklein@fairpoint.net> User-Agent: Thunderbird 2.0.0.14 (Windows/20080421) MIME-Version: 1.0 To: highlands@ci.yelm.wa.us Subject: 2 comments on the Thurston Highlands Draft EIS Content-Type: multipart/alternative; boundary="------------030201020909080202050605" X-pstn-neptune: 0/0/0.00/0 X-pstn-levels: (S: 0.18675/99.74845 CV:99.0000 R:95.9108 P:95.9108 M:77.7652 C:99.7951 ) Return-Path: srklein@fairpoint.net X-OriginalArrivalTime: 18 Jul 2008 15:23:34.0062 (UTC) FILETIME=[3E05D4E0:01C8E8EA] --------------030201020909080202050605 Content-Type: text/plain; charset=ISO-8859-1; format=flowed Content-Transfer-Encoding: 7bit --------------030201020909080202050605 Content-Type: text/html; charset=ISO-8859-1 Content-Transfer-Encoding: 7bit --------------030201020909080202050605-- Steve Klein SMTP srklein@fairpoint.net Thurston Highlands 2 comments on the Thurston Highlands Draft EIS Dear Mr. Beck, I am writing to include my comments on the Yelm Community Blog of & July 18th respectively for public comment on the Thurston Highlands Draft EIS: 1. July 9th, 2008 http://yelm.com/2008/07/716.html This document took two years to produce and is huge. Were going to triple the size of the city and the pubic is supposed to understand this and comment all within 45 days by July 28th? SEPA rules state the maximum number of pages in an EIS is 150, not including diagrams & maps. <http://apps.leg.wa.gov/wac/default.aspx?cite=197-11-425> Thurston Highlands is over 325. SEPA also states: (2) Environmental impact statements shall be concise and written in plain language. EISs shall not be excessively detailed or overly technical. EISs shall explain plainly the meaning of technical terms not generally understood by the general public (4) The text of an EIS (WAC 197-11-430(3)) normally ranges from thirty to fifty pages and may be shorter. The EIS text shall not exceed seventy-five pages; except for proposals of unusual scope or complexity, where the EIS shall not exceed one hundred fifty pages. The WAC (WA. Admin. code) 197-11 sec. 400 (3) about purpose <http://apps.leg.wa.gov/wac/default.aspx?cite=197-11-400> says "larger documents may hinder the decision making process." That means THIS draft EIS is going to have to change, and big time as this draft EIS does NOT meet the criteria of the mandate of 150 pages maximum! The WAC says <http://apps.leg.wa.gov/wac/default.aspx?cite=197-11-455> : (6) Any person or agency shall have thirty days from the date of issue in which to review and comment upon the DEIS. (7) Upon request, the lead agency may grant an extension of up to fifteen days to the comment period. Agencies and the public must request any extension before the end of the comment period. So, why should there be more extensions? This draft EIS does not follow the rules and is way too long. There should be at least another month extension to make comments. HERE WE HAVE A PROPOSAL THAT IS SUPPOSED TO BE IN NO COMPETITION WITH THE DOWNTOWN CORE, YET THURSTON HIGHLANDS' COMMERCIAL AREA HAS 825,000SQ' OF RETAIL COMMERCIAL DEVELOPMENT AND 135,000,000SQ' OF PROFESSIONAL OFFICES. YELM'S SUPER WAL-MART HAS 184,368SQ' FOR COMPARISON. <http://walmartstores.com/FactsNews/NewsRoom/6604.aspx> SO, YELM IS SUPPOSED TO ACCEPT ALMOST ONE MILLION SQUARE FEET OF NEW COMMERCIAL SPACE WITH NO EFFECT? COME ON! LET'S PUT OUR THINKING CAPS ON? IS THE ZONING FUNCTION OF THE CITY TO CREATE AN ALL NEW COMMERCIAL AREA AWAY FROM THE EXISTING TOWN? ARE WE GOING TO HAVE MORE MULTI-NATIONAL CHAIN STORES AND BIG BOX STORES THAT EXPATRIATE FUNDS OUT OF HERE BEING BUILT IN THURSTON HIGHLANDS? IS OUR DOWNTOWN COMMERCIAL CORE GOING TO BE SUSTAINABLE WITH A HIGHLANDS? CITY HALL WAS GETTING READY TO CHANGE THE COMPREHENSIVE PLAN TO ACCOMMODATE NASCAR -- WHAT'S IN THE PLAN? IS THE CITY GOING TO CHANGE THE PLAN TO ACCOMMODATE WHATEVER MONEY IS THROWN AT IT? THE EIS MUST BE CONSISTENT WITH THE COMPREHENSIVE PLAN. WHAT IF IT IS NOT? THE COMPREHENSIVE PLAN IS SUPPOSED TO BE THE WISHES OF THE COMMUNITY? IS THIS DEVELOPMENT FOLLOWING THE PLAN? IS IT? THINK ABOUT THE EFFECT OF ONE MILLION SQUARE FEET OF NEW COMMERCIAL SPACE FOR THURSTON HIGHLANDS ON YELM'S CURRENT COMMERCIAL AREA? WHY ISN'T EVERY COMMERCIAL BUSINESS IN THIS CITY RAISING A RUCKUS ON THIS ISSUE? EVERY MERCHANT IN THIS TOWN SHOULD BE HOLDING THE CITY'S FEET TO THE FIRE REQUIRING AN EXTENSION TO DEAL WITH THIS ISSUE. I FORMALLY REQUEST AN EXTENSION OF 30 DAYS TO HAVE THIS DRAFT EIS REWRITTEN TO COMPLY WITH THE RULES, MR. BECK! Stephen R. Klein P. O. Box 1971 Yelm, WA. 98597 2. July 18th, 2008 http://yelm.com/2008/07/thueston-highlands-draft-eis-g.html Some things to keep in mind: 1. The EIS must be consistent with the Comprehensive Plan. The purpose of the EIS and The Comprehensive Plan is to insure the wishes of the community are reflected in these documents. "The Vision Plan is adopted by reference in the Yelm Comprehensive Plan, and became a guiding document in the creation of development regulations such as the Yelm Design Guidelines." 2. The Yelm Vision Plan <http://www.ci.yelm.wa.us/_data/forms/vision.pdf> was instituted on January 5, 1995 by a group of people to reflect the will of the community. This states on page 6, #B: "Develop retail and commercial services to meet the needs of Yelm’s growing population. Focus new commercial services in existing commercial areas. on page 8: Improve Yelm’s historic downtown (roughly between Solberg St. NW/SW, Stevens Ave.NE/NW, 4th St. NE/SE and Mosman Ave. SW/SE). a. Provide more street amenities and pedestrian oriented businesses, such as open-air restaurants. on page 12: Each district would allow the full spectrum of uses as defined by zoning (Zoning will not be changed.) but will also feature guidelines to encourage specific activities and take advantage of special opportunities. For example, the “village retail” district will create an attractive pedestrian-oriented retail center to serve new residents in the southwest annexation (as well as providing a unique shopping experience in the city). The downtown district targets visitors’ service businesses through historic preservation, street improvements, and by encouraging small cottage industries in existing structures. on page 15: Land Use and Design 4. Implement master plan for proposed SW Annex Development to form a high-quality residential community integrated with the rest of Yelm. Restrict new commercial development outside the current commercially zoned area along Yelm venue. on page 18: Village Retail District [current downtown] b. Make the site accessible from the Southwest Annex and Yelm Avenue. This will reduce congestion on Yelm Avenue by providing alternate access to the development. Easy access from the Southwest Annex will encourage residents to shop in the Village Retail District. on page 19 Proposed Southwest Annex District [Thurston Highlands] a. Higher density development, involving a mix of multifamily and single-family units should be located near Yelm Avenue to encourage pedestrian trips to the Village Retail District [current downtown]. and: c. Commercial development should be kept to a minimum. Allow only small neighborhood-oriented commercial, such as small grocery stores. PUT ON YOUR THINKING CAPS... DOES ANYONE SEE THE CONNECTION HERE? IS THURSTON HIGHLANDS' EIS CONSISTENT WITH THE WISHES OF THE COMMUNITY, AS EXPRESSED IN YELM'S VISION STATEMENT ON THE CITY'S OWN WEBSITE? AFTER ALL, THE VISION PLAN WAS DEEMED TO BE THE DESIRES OF THIS COMMUNITY! WE ARE SEEING THIS DRAFT EIS PROPOSE ALMOST 1 MILLION SQUARE FEET OF NEW COMMERCIAL SPACE IN A DEVELOPMENT AWAY FROM THE YELM'S CURRENT DOWNTOWN, WHERE THE VISION STATEMENT SPECIFICALLY STATES: Focus new commercial services in existing commercial areas And: "Commercial development should be kept to a minimum [in Thurston Highlands]. Allow only small neighborhood-oriented commercial, such as small grocery stores." The Draft EIS States in Chapter 3, section 7-4: Yelm Vision Plan In the same time period during which the City of Yelm was adopting its Comprehensive Land Use Plan consistent with the Growth Management Act, the Yelm Chamber of Commerce and the local community created a Vision Plan designed to improve the economic vitality, convenience and appearance of the downtown commercial area by: focusing on industry, retail and commercial uses, and tourism; building community pride and involvement; enhancing the City’s identity with a directed sense of character, downtown improvements, and coordinated improvement efforts; improving vehicular circulation; and promoting efficient and high-quality land use. The Vision Plan is adopted by reference in the Yelm Comprehensive Plan, and became a guiding document in the creation of development regulations such as the Yelm Design Guidelines. Relationship of the Thurston Highlands Master Planned Community to the Yelm Vision Plan The Yelm Vision Plan will be utilized by the City during the Thurston Highlands application review process for final Master Site Plan approval, and during formulation of a Development Agreement (or similar instrument) that will establish project-specific development standards and requirements for construction within the proposed Master Planned Community. OH, REALLY???!!! ISN'T THE YELM VISION PLAN SUPPOSED TO REFLECT THE DESIRES OF THE COMMUNITY & BE FOLLOWED? WHY IS IT NOT BEING FOLLOWED WITH THIS DRAFT EIS? The Thurston Highlands Draft EIS States in Chapter 3, section 7 - 3: Relationship of the Thurston Highlands Master Planned Community to the Comprehensive Plan The Thurston Highlands Master Planned Community must be consistent with policies of the Yelm Comprehensive Plan as part of the Master Planned Community approval. The Draft EIS States in Chapter 3, section 7 - 1: Relationship of the Proposal to Plans and Policies Yelm Comprehensive Plan The primary criteria for conceptual approval of a Master Plan Development is consistency with the goals and policies of the Comprehensive Plan. IS THIS DRAFT EIS FOLLOWING THE COMPREHENSIVE PLAN & VISION STATEMENT? WHY NOT? DOES THE COMMUNITY CARE IF CITY OFFICIALS CARRY OUT THEIR WISHES OR NOT VIA THESE DOCUMENTS? IF WE MAKE A NEW COMMERCIAL AREA IN THURSTON HIGHLANDS OF ALMOST 1 MILLION SQUARE FEET [EQUIVALENT TO 5 SUPER WAL-MARTS] , WHAT IS GOING TO BE THE EFFECT ON YELM'S CURRENT COMMERCIAL AREA? WILL THE COMMUNITY SHOP AT ALL BRIGHT, SHINY AND NEW BUSINESSES OR GO TO THE CURRENT DOWNTOWN AREA? IF YOU HAD A BUSINESS IN YELM'S DOWNTOWN CORE, HOW DO YOU FEEL ABOUT YOUR BUSINESS LOCATION BEING SHOVED ASIDE WHILE A NEW COMMERCIAL AREA IS DEVELOPED IN THURSTON HIGHLANDS? WHY DID THIS CITY GO TO ALL OF THE TROUBLE TO CREATE A VISION STATEMENT AND THEN NOT FOLLOW IT? WHERE IS THE PLANNING COMMISSION ON THIS ONE? ALL THREE ALTERNATIVES SUGGESTED FOR THE HIGHLANDS OFFER LARGE COMMERCIAL ACTIVITY. THERE WAS NO ALTERNATIVE PRESENTED WITH LIMITED COMMERCIAL ACTIVITY THAT FOLLOWED THE VISION STATEMENT. THIS IS UNACCEPTABLE AND THIS DRAFT EIS SHOULD BE REWORKED TO INCLUDE AN ALTERNATIVE PLAN WITH LIMITED COMMERCIAL DEVELOPMENT! I FORMALLY REQUEST AN EXTENSION OF 30 DAYS TO HAVE THIS DRAFT EIS REWRITTEN TO COMPLY WITH THE RULES, MR. BECK! Please have Thurston Highlands draft an alternative with limited commercial growth! Stephen R. Klein P. O. Box 1971 Yelm, WA. 98597 <4880B4C0.2000308@fairpoint.net> Grant Beck Thurston Highlands EX /O=CITYOFYELM/OU=FIRST ADMINISTRATIVE GROUP/CN=RECIPIENTS/CN=THURSTONHIGHLANDS ThurstonHighlands highlands@ci.yelm.wa.us SMTP highlands@ci.yelm.wa.us