Chamber PLUSH Committee submits comments on Bellevue Comp Plan

Advocacy, PLUSH, Press Release,
The Bellevue Chamber's PLUSH (Permitting, Land Use, Sustainability, & Housing) Committee submitted the following letter to the City of Bellevue's Development Services Department on Oct 31, 2022.

Dear Development Services Department:

The Bellevue Chamber PLUSH Committee appreciates the opportunity to provide comments to the Bellevue 2044 Comprehensive Plan Periodic Update (“Comp Plan Update”) and Wilburton Vision Implementation (“Wilburton Vision”) Environmental Impact Statement, Fall 2022 Scoping Handout (“Scoping Handout”). As we write this letter at the end of 2022:

  • Bellevue is seeing incredible growth in office building construction in Downtown and BelRed, with buildings slated to be occupied by some of the world’s largest tech companies, including Amazon and Meta; the continuing post-COVID ‘return to office’ uncertainty requires considering EIS options broadly and flexibly.

  • Light rail construction is nearly complete and scheduled to open in 2024, the state is continuing to advance the I-405 Master Plan improvements, and Bellevue has nearly completed its MI&I plan to create a network of arterials connecting Downtown Wilburton and BelRed.

  • Significant growth in office buildings serving Bellevue’s other economic clusters, such as FIRE, medical, and life sciences has not occurred, in large part due to under-zoned properties in areas like Wilburton and BelRed.

  • Some multifamily residential development has occurred in Downtown and BelRed, but housing development has generally not kept pace with job growth, and affordable housing options are few and far between.

The Comp Plan Update provides Bellevue with a unique opportunity to prepare for the myriad of changes that are certain to occur in the years ahead; to take advantage of the strengths presented by the launch of light rail, highway and arterial expansion, and the ever-burgeoning tech sector, while simultaneously enabling the market both to capitalize on growth opportunities in other economic clusters and create new higher-density, transit-oriented housing options in addition to middle-density choices, all while maintaining the character of the city’s vibrant single-family neighborhoods.

Before offering our comments, we note that the SEPA process and the EIS is intended as a tool to “inform decision makers and the public of reasonable alternatives,” to assist in making these important decisions.

As such, it is necessary to study a meaningful range of reasonable alternatives to provide the City Council and the public with potential impacts, both good and bad, of certain actions and inactions that we may ultimately pursue.

Comprehensive Plan Update comments. We request that you incorporate the following considerations into the Comp Plan Update:

  • Alternatives 1-3 provide an acceptable range of growth alternatives in housing units and jobs. Even the low-end considered in Alternative 1 would result in aggressive growth in housing units in the city, and the consistent level of job growth across the alternatives ensures that sufficient planning for economic growth will occur. It will be important for the city to develop zoning alternatives where these targets can be rationally achieved. If so, the three Alternatives will analyze how much additional density should be provided to create more housing options, as opposed to how much job growth will need to be sacrificed. We believe this to be an appropriate paradigm. 

  • Prioritize density in mixed use centers. Bellevue should continue to concentrate density in the mixed use centers. Placing growth at transportation nodes achieves a variety of goals, including reducing traffic and greenhouse gas emissions. The strategy is also consistent with state and regional planning goals and enables Bellevue to continue to grow in areas where there is infrastructure to support the growth, and where existing residents expect the growth to occur. Specifically, we suggest:
    • Minimum densities of 5.0 FAR be implemented on land within a mixed use center and within the half mile radius of light rail stations or frequent transit stops.
    • Additional density must be allocated to all mixed use centers, not just Downtown, BelRed, and Eastgate/Factoria. Left out of the current Comp Plan are East Main, Wilburton, and Crossroads, each of which provide greater opportunity for accommodating the targeted levels of housing units and jobs.
    • Appropriate building and site dimensions must be provided to enable the density to be achieved, to provide the flexibility to create high quality design, and to enable creation of more affordable housing options. Appropriate building dimensions for mixed use centers include
      • Allowing building heights of 250’+ in high-rise areas.
      • Eliminating the floor plate maximums for mid-rise residential.
      • Increasing floor plate maximums for non-residential to enable more nationally competitive tech, medical, and life sciences buildings.
      • Permitting maximum lot coverage and impervious surface at 100%.
      • Eliminating building stepbacks, particularly for mid-rise residential.
  • Support density in neighborhood centers through zoning adjustments. Within neighborhood centers, consider appropriate urban minimum densities and heights that promote redevelopment of a mix of uses and fit within surrounding communities. Neighborhood centers are scattered throughout the city and are zoned NB and CB. In some cases, land surrounding the centers also includes commercial zoning such as PO, O, or GC; or higher density residential, like R- 10 or R-20, or even R-30. Most neighborhood centers also include transition areas, which significantly limit density within neighborhood centers. We request that the City evaluate each of these areas (the centers and surrounding land) and modify the code to enable redevelopment in a manner that fits well with the surrounding community, but at the same time provides additional residential housing and mixed use commercial opportunities.

  • Expand mixed use centers to capture transit areas and corridors. To follow on the above bullet, mixed use centers are most viable when they are added or expanded where growth occurs organically—near transit. We suggest that all areas within frequent transit areas be included in mixed use centers. Areas for opportunity include many areas of Eastgate, the Bellevue Way Corridor (north of 12th and south of Main), and other transit-rich environments that to date have been excluded from mixed use centers.

  • Address the “missing middle” within viable residential areas. Residential areas should be evaluated for locations that can viably support “missing middle” housing solutions. The existing Comp Plan calls for “providing, through land use regulation, the potential for a broad range of housing choices to meet the changing needs of the community”4 but this policy has not yet been met in Bellevue’s residential areas. This should be prioritized to meet current and future demand.

  • Re-evaluate the boundaries. Throughout the city there are areas that are viable for higher density housing or nonresidential development but have not been included in an area-wide rezone. The entire city should be explored for pockets of land that are appropriate targets for additional density. We see particular opportunity on the edges of BelRed near Redmond’s Overlake neighborhood where Redmond is planning for significant additional density and growth, in Eastgate, in Factoria, and within all of the city’s neighborhood centers.

  • Include BelRed as a continuing center for job growth and housing. BelRed should be considered a blank slate for development with ample opportunity for growth; consequently, we request that a greater emphasis be placed on this subarea. It was an area slated for significant growth in the last Comprehensive Plan update, but it has not realized its potential because of zoning standards and a street grid that has been a barrier to feasible development. While Alternative Three includes a higher focus on BelRed than the other alternatives, we also suggest maximizing mixed use density for residential and commercial development within the half-mile radius surrounding all light rail stations, as stated above.

  • Eliminate barriers to housing and jobs production. As stated, increasing FAR and minimizing zoning constraints are necessary mechanisms to fully realize development potential. As such, we ask that you consider identifying the specific regulations that have reduced development capacity, including upper level stepbacks, floor plate limitations, open space/play area requirements, and lot coverage and impervious surface maximums. Eliminating these limitations in mixed use centers will allow for development to flourish in these areas and for growth tools, such as full use of FAR, not to be hampered in the process.

  • Streamline the ability to obtain contract rezones. The existing process for obtaining contract rezones typically requires two separate City Council actions, which is incredibly challenging and hinders the ability to provide viable uses on land where the existing zoning is inadequate. We ask the City to adopt solutions that have worked well in Seattle, including the creation of general land use map designations within the Comprehensive Plan that can be zoned to a range of urban zoning designations5 and the adoption of standards that allow for greater density if a project can demonstrate compliance. General land use map and urban zone designations will streamline the process to allow for a one-step approval process that still has appropriate City Council oversight and public engagement.

  • Maximize development through incentive-based programs. Alternatives Two and Three include voluntary incentive-based programs which provide industry with the necessary flexibility to develop widely in our community. We support incentive-based programs to support community priorities like affordable housing. With housing demand outpacing supply across the nation, the market has become more competitive in attracting quality development and high development exactions will jeopardize perceived development opportunity in capital markets. Incentive programs prove more durable and take into consideration the key financial components that are necessary to produce housing at all affordability levels. To that end, we encourage the city to do the following:

  • Maintain the 80% AMI incentive for affordable housing requirements. Bellevue’s MFTE, Downtown FAR exemption, and BelRed, East Main, and Eastgate mandatory incentive zoning requirements are all predicated on the 80% AMI standard. This rent level can work for private sector development, depending on the percentage of units and the duration of the affordability requirement, and has been proven to work in some areas of the city, such as Downtown’s MFTE and BelRed’s mandatory incentive.

  • Create incentive zoning requirements consistent with state law (RCW36.70A.540), in that they need to be voluntary and an incentive. To that end, the affordable housing requirements should be derived from a reasonable base FAR for the area, and the affordable housing percentages need to be set at a level that creates an incentive for the developer to provide the basic financial justification.

  • Adopt a reasonable fee-in-lieu for both residential and nonresidential developments that enables the flexibility to fund even greater levels of affordability while still being able to take advantage of the incentive zoning.

  • Maintain the Downtown and BelRed market rate FAR bonuses for on-site affordable units as a means of equalizing the on-site vs. fee-in-lieu structure.

  • Increase the flexibility of the transportation/grid system. The transportation “grid system” that was envisioned for BelRed was well-meaning but, in many cases, did not consider developability or property ownership. There is an emphasis on moving cars within the current grid system, however, within a transit-oriented area the movement of people should be prioritized. We request that you consider allowing more flexibility in the grid system by allowing pedestrian paths in the place of auto-centered roads where appropriate. A grid system may not be appropriate in Wilburton where uses with larger block sizes (such as medical, biotech) may be needed.
  • Reduce or eliminate parking minimums in the TOD areas of mixed use centers. Parking minimums have a range of negative consequences, including decreasing financial productivity and shifting finite resources from the creation of housing units. Increases in urbanization, transportation technology, and transit service all reduce the need for parking at buildings in these areas. Rather than requiring more parking than necessary, we ask the city to allow the market a greater degree of flexibility to make this determination. Additionally, we understand the state legislature may consider a bill related to this topic in the upcoming legislative session.

  • Eliminate the critical area penalty in all mixed use centers. Critical areas are currently well- protected through the use of buffers and other regulatory mechanisms. Reducing density in urban areas will not better protect critical areas but can lead to nonfunctioning lots in key urban areas. We also suggest creating the ability to obtain a steep slope exemption from critical areas for manmade and isolated slopes. In addition, we request that a manmade retaining wall not be considered a “critical area.”

  • Exempt mixed use centers from tree protection ordinances. In the places where growth is being incentivized (around transit), tree protection ordinances actively hamper industry’s ability to achieve the city’s collective development goals. An effective alternative would be to increase the city’s tree canopy replacement ratio for trees cut down to make way for urban development.

  • Increase speed of permitting and permitting flexibility. To prepare for Bellevue’s coming growth, an administrative system that can support increased volumes of permit requests is necessary for both those seeking permits and those reviewing requests. To increase efficiency in permit review:

  • Consider a new online permitting/information system that makes it easier for applicants and the public to review information without having to call the City.

  • Hire more planners for review (we understand this is already underway) and ensure review consistency across staff tenures through employee training and preset interdepartmental communication processes.

  • Permit the wide use of departure sand Development Agreements within mixed use centers to increase project flexibility and number of projects that provide additional public benefit.

  • Allow a 2-year ADR extension to consider current market conditions and maintain flexibility.

  • Increase SEPA thresholds to the maximum exemption levels allowed by state law.

  • Allow extensions for building permit applications, utility permit applications, and issued building permits to reduce staff burden and increase predictability.

Avoid policy pitfalls that hinder growth. While we do not reject affordability policies out of hand, programs that add fees to development or require specific performance rather than incentives can be too rigid or poorly calibrated to our quickly changing economic conditions. We have seen many examples of well-intentioned housing policies leading to a complete shutdown of residential development in areas, exacerbating our already dire housing crisis. We encourage flexible, market-based incentives that promote the profitability of creating the types of housing stock that address the city’s greatest needs.

Wilburton Vision comments. We request you incorporate the following comments into the Wilburton Vision:

  • Increase residential heights in Wilburton. Through increased height allowances, high-rise residential developments in Wilburton can be maximized to achieve desired high growth targets. Specifically, the City should increase the areas where it is considering the tallest buildings to encompass the entire area between NE 8th on the north, Eastrail on the east, and the boundary of the Wilburton subarea to the south. Failing to increase Wilburton’s residential heights and rezone sufficient area to heights that support cost-intensive high-rise residential development will push growth to less appropriate areas that have fewer employment and transit opportunities.

  • Continue to maintain Wilburton as the natural extension of Downtown Bellevue. Few downtown environments are supplied with acres upon acres of adjacent lower density development as Bellevue has in Wilburton. While the market currently is not prioritizing traditional office development, the Wilburton neighborhood should be utilized as the natural extension of the downtown office/jobs core. In addition, the larger block sizes in Wilburton could lend themselves to uses like medical office/biotech that need larger floor plate sizes. Encouraging these uses to locate near Overlake could create a mixed use/biotech hub, further diversifying the Bellevue economy.

  • Maintain the emphasis on medical uses along the 116th Ave. NE corridor. Alternative 3 proposes to study the northwest corner of Wilburton as a Mixed-Use Node instead of Office-Residential. Given the large number of residential opportunities being proposed throughout Wilburton in all Alternatives, we believe the emphasis across the street from the hospitals should remain focused on medical. In addition, since a 1.2 million SF life sciences hub is being proposed on the west edge of BelRed, we believe the 116th corridor should encourage life sciences buildings as well. The BR-MO zoned land located north of NE 12th Street up to Northup Way should be included in the medical/life sciences discussion.

  • Thank you for the opportunity to provide our comments, which aim to promote sustainable, market- responsive growth. We truly appreciate your diligence in facilitating this feedback process and for navigating a range of highly complex policy issues. We look forward to our continued collaboration as we work in tandem to build a more viable Bellevue; one that will house its workers, empower its industries, and ensure its sustainability.


    Jodie Alberts Jessica Clawson
    Vice President, Government Affairs PLUSH Committee Chair