BEFORE THE SEATTLE HEARING EXAMINER WATERFRONT LANDINGS OWNERS ASSOCIATION, a Washington nonpro?t corporation, Petitioner, vs. THE CITY OF SEATTLE, through its DEPARTMENT OF TRANSPORTATION, Respondent. 1. PETITIONER Case No. WATERFRONT LANDINGS OWNERS PETITION FOR REVIEW OF ADEQUACY OF ENVIRONMENTAL IMPACT STATEMENT FOR ALASKAN WAY, PROMENADE, AND OVERLOOK WALK Petitioner is the Waterfront Landings Owners Association (?Waterfront Landings?). Its mailing address and telephone number are: Waterfront Landings Owners Association c/o Maureen J. Miller, Board President 1950 Alaskan Way Seattle, WA 98101 (303) 550-5135 w?buardpresf?lmnail.com MILLER NASH GRAHAM DUNN LLP WATERFRONT LANDINGS OWNERS PETITION ATTORNEYS AT LAW FOR REVIEW OF EIS T: 206 624 8300 F: 206 340 9599 2801 ALASKAN WAY. SUITE 300 SEATTLE. WASHINGTON 98 21 represented by: Elaine L. Spencer Madeline Engel Miller Nash Graham Dunn LLP 2801 Alaskan Way, Suite 300 Seattle, WA 98121-1128 (206) 777?7551 Email: elaine.Spencer@millernash.com; madeline.engel@millernash.com Petitioner would like to receive documents from the Of?ce of Hearing Examiner by email attachment. 2. RESPONDENT Respondent is the City of Seattle through its Department of Transportation (SDOT). On October 31, 2016 SDOT issued a Final Environmental Impact Statement (the FEIS) for Alaskan Way, Promenade, and Overlook Walk (AWPOW). 3. INTEREST OF WATERFRONT LANDINGS Waterfront Landings is a 232?unit residential condominium community fronting on Alaskan Way between Pine and Lenora Streets. It is home to nearly 400 residents, who have chosen to live there because of the scenic beauty of the location, the amenity of its pedestrian environment, and its easy access to downtown Seattle. Waterfront Landings Owners Association is the homeowner association for Waterfront Landings. Waterfront Landings was one of the ?rst developments in Seattle for which the City insisted that a signi?cant number of units be small enough to be affordable. As a result, while Waterfront Landings has some lovely homes with privileged owners, it also includes a signi?cant number of very small homes, owned by residents on modest ?xed incomes. Of the 386 people living at Waterfront Landings as of August 2015, 25 percent were senior citizens and retired, 6 percent were children, and 70 percent were adults of working age. WATERFRONT LANDINGS OWNERS ASSOCIATIONS PETITION MILLER DUNN LLP FOR REVIEW OF EIS 2 624 BiitEliF?lbma 340 9599 280l ALASKAN WAY, SUITE 300 SEATTLE, WASHINGTON 98l2 Waterfront Landings explained to the City in comments on the Draft Environmental Impact Statement for AWPOW, its primary concerns about the environmental impacts of AWPOW are: The prOposed elevated roadway on Alaskan Way and Pine Street will create toxic fumes and dirt from the road and subject residents to noise at all hours, as well as cutting off Waterfront Landings? access to downtown Seattle. Signi?cant light pollution from vehicular traf?c, roadway lighting, and traf?c signals located within twenty feet of residents? windows will adversely impact residents? quality of life. Combined with the Overlook Walk (either as originally proposed or under the revised Seattle Aquarium proposal), it will sever the north waterfront from the central waterfront. The new 19-foot (two story) concrete retaining wall and guardrail in Pine Street will make the remnant of Pine Street a shaded, dangerous, and blighted neighbor to Waterfront Landings. Safety and emergency needs of residents will be severely compromised during construction. Project of?cials have made at most vague promises that they will provide access for emergency vehicles during construction, but acknowledge that response time for emergency vehicles may still be delayed. After project completion, safety and emergency needs will be compromised by design workarounds required to prevent transient people from occupying the space at the rear and side of the Waterfront Landings building. Again, only vague promises of mitigation have been provided, not speci?c measures that will assure Waterfront Landings residents that their health and safety will be protected. Removal of on-street parking that is essential in order for family members or other guests to visit residents will cause homes within Waterfront Landings to be isolated from the City. WATERFRONT LANDINGS OWNERS PETITION MILLER DUNN LLP FOR REVIEW OF EIS - 3 T: 206 624 340 9599 280] ALASKAN WAY, SUITE 300 SEATTLE. WASHINGTON 98121 GOONQ The new ?service drive,? which is essential to replace the loss of Pine Street when the grade of Alaskan Way and Pine Street is changed, will subject residents to noise and fumes at all hours. It is likely to result in accidents as trucks are forced to stop for residents turning into Waterfront Landings or residents try to exit onto Alaskan Way. It will degrade the landscaped walkway in front of Waterfront Landings, which has always been a signi?cant amenity of its homes. It will require a security gate between Waterfront Landings and the retaining wall that will create the impression of a medium- security prison. Waterfront Landings has provided comments on both the Draft EIS and the Supplemental Draft EIS for AWPOW on behalf of its members, as well as participating for years in numerous meetings with representatives of SDOT and Waterfront Seattle to express the concerns identi?ed in this petition for review. Public comment cannot be measured by how many hours a public employee spends sitting in a room with concerned citizens. The City?s responses to those meetings have consistently demonstrated that project of?cials will neither hear the concerns of Waterfront Landings nor make any substantive changes in the project to address those concerns. When presented with the opportunity to address Waterfront Landings? greatest concern?the raising of the grade of Pine Street and Alaskan Way, which cuts off the northern waterfront and blights Waterfront Landings? southern building, through the replacement of the Overlook Walk with the Aquarium expansion?project of?cials refused to even consider an alternative that would address that concern. The City?s refusal to make any more than cosmetic change to the project to prevent it from becoming a permanent blight on Waterfront Landings leaves Waterfront Landings with no choice but to seek an EIS that discusses a reasonable alternative that has less adverse impact on its residents. The City of Seattle expects to pay for the improvements included Within AWPOW by, among other things, establishing a Local Improvement District to provide $199 million. The City expects to impose a special assessment on homes within Waterfront Landings. An LID WATERFRONT LANDINGS OWNERS PETITION MILLER DUNN LLP FOR REVIEW OF BIS - 4 T: 206 624 140 9599 ZSUI ALASKAN WAY. SUITE 300 SEATTLE. WASHINGTON 9312 prOper way to ?nance construction of public improvements only if those public improvements provide ?Special bene?t? to particular properties not received by the public at large. As designed, and as described in the FEIS, AWPOW provides no ?special bene?t? for Waterfront Landings. To the contrary, it will permanently blight Waterfront Landings by tucking it in the armpit of an elevated highway, cutting Off its easy access to downtown Seattle, and destroying much of its amenity value. Two of the most important functions of an EIS for a public project are consideration of reasonable alternatives and identi?cation of mitigation that can reduce the adverse impacts of the project. The failure of the FEIS for AWPOW to ful?ll those functions leads to failure to provide any bene?t for owners of Waterfront Landings. Waterfront Landings needs the EIS for AWPOW to seriously consider an alternative that would achieve the stated goals of AWPOW without permanently blighting Waterfront Landings. That requires an alternative that moves the intersection of the Elliott Connector and Alaskan Way to Pike Street and reorients the Seattle Aquarium expansion to accommodate that move. 4. DESCRIPTION OF AWPOW AWPOW was an outgrowth of the removal of the Alaskan Way Viaduct (the Viaduct). Although Waterfront Landings is located and was designed so that the Viaduct had no adverse impact on Waterfront Landings, the Viaduct had been a noisy visual barrier between downtown Seattle and the central waterfront to the south of Waterfront Landings. Removal of the Viaduct will remove that physical barrier and reduce the noise and air pollution that it created to the south of Waterfront Landings, and will provide signi?cant additional open space that can be used to make the central waterfront more attractive. Because Waterfront Landings is not now adversely impacted by the Viaduct and its residents now have easy access to downtown Seattle through the Pike Place Market parking garage elevators, its interest in both the removal of the Viaduct and AWPOW was less than that of properties along the central waterfront. WATERFRONT LANDINGS OWNERS PETITION MILLER DUNN LLP FOR REVIEW OF EIS 5 T: 206 624 sapolt?a?fozoa 340 9599 280] ALASKAN WAY, SUITE 300 SEATTLE, WASHINGTON 9512] The City of Seattle established seven goals for the recon?guration of the waterfront after the Viaduct is removed: 0 Create a waterfront for all II Put the shoreline and innovative, sustainable design at the forefront - Reconnect the city to its waterfront I Embrace and celebrate Seattle?s past, present and future 0 Improve access and mobility (for people and goods) 0 Create a bold vision that is adaptable over time Develop consistent leadership from concept to operations AWPOW is a compilation of several projects that arose from the post-Viaduct waterfront planning process. These include reconstruction of Alaskan Way, construction of a promenade along the waterfront, and new connections to the waterfront, including a major overpass of Alaskan Way below the Pike Place Market. That overpass was originally a grand sweep of concrete coming down from the Pike Place Market to Pier 62/63. The intent was to give tourists a sweeping View of the Olympic Mountains as they walked down to Pier 62/63 from the Pike Place Market. Approximately one-third of the traf?c on the Viaduct coming to or from north of downtown Seattle currently exits or enters the Viaduct at the Pike Place Market by means of Elliott and Western Avenues, to proceed to Ballard, Interbay, and Magnolia. As part of the Viaduct replacement project, it was necessary to build a ?Connector? to extend Elliott and Western Avenues down the hill behind Waterfront Landings to Alaskan Way, so that the Ballard/Magnolia/Interbay traffic can use Alaskan Way to reach areas south of downtown Seattle. As originally proposed by Washington State Department of Transportation (WSDOT), the intersection of Alaskan Way and the Elliott Connector was to have been at Pike Street. That intersection would have provided reasonable grades for trucks needing to ascend the bluff, and would have had no adverse impact on Waterfront Landings. MILLER NASH GRAHAM DUNN LLP WATERFRONT LANDINGS OWNERS PETITION ATTORNEYS AT LAW FOR REVIEW OF EIS - 6 T: 206 524 smut-2,3206 340 9599 280] ALASKAN WAY. SUITE 300 SEATTLE. WASHINGTON 98l2] With the AWPOW design of the Overlook Walk, the Pike Street intersection of the Elliott Connector and Alaskan Way was no longer possible because the grand sweep of concrete directed at Pier 62/63 required that the grades Of the roadway underneath be changed. Instead of placing the intersection at Pike and Alaskan Way, AWPOW moved the intersection of Alaskan Way and the Elliott Connector to Pine Street behind Waterfront Landings. That required it to build a wall in the middle of Pine Street adjacent to Waterfront Landings but only inches from the building at its southeast corner, totaling 19-feet high with the required railings. It also required it to raise the grade of Alaskan Way in front of portions of Waterfront Landings. Without additional mitigation, it would have left Waterfront Landings with no access to the southern entrance to its parking garage, no ability for trash and recycling trucks to access the area where trash and recycling is stored, no place for moving vans to park when needed, and no ability for emergency vehicles to access the rear of the building. To address those circumstances, AWPOW requires that a portion of the sidewalk in front of Waterfront Landings be turned instead into a service road, moving all traf?c that now accesses the south or rear of the building to pass immediately in front of and below the windows of homes that currently face onto the walkway, Alaskan Way, and Elliott Bay. Those changes will profoundly impact Waterfront Landings. The AWPOW project team has been clear that only the design of the Overlook Walk made those impacts necessary. AWPOW of?cials were not, however, willing to alter the original Overlook Walk to reduce the adverse impact of the Overlook Walk on Waterfront Landings. By early 2016 it was clear that the Overlook Walk was not feasible. It was too expensive, offered too little benefit, and would prevent the Seattle Aquarium, the heart of the central waterfront, from implementing its long-term strategic plan for expansion. As a result, in April 2016 the City issued a Draft Supplemental EIS that substituted an expansion of the Seattle Aquarium for the Overlook Walk as originally presented. Waterfront Landings urged the City to WATERFRONT LANDINGS OWNERS PETITION MILLER DUNN LLP FOR REVIEW OF EIS - 7 T: 206 624 J40 9599 280l ALASKAN WAY. SUITE 300 SEATTLE, WASHINGTON 9812] use that occasion to develop and evaluate an alternative that moved the Elliott Connector/Alaskan Way intersection back to Pike Street as originally proposed by WSDOT, but the AWPOW staff refused to do so. A reasonable alternative would include a scheme for the Aquarium expansion that moved the intersection of the Elliott Connector and Alaskan Way to Pike Street, with the Aquarium expansion allowing pedestrian passage across Alaskan Way to the waterfront on top of that intersection. Such an alternative is feasible, and would result in far less adverse impact to Waterfront Landings and upon vehicular and pedestrian safety on Alaskan Way. 5. DEFICIENCIES OF THE FEIS An adequate EIS for AWPOW was required to consider alternatives that would achieve the goals of the waterfront plan and to identify the adverse impacts of those alternatives, and mitigation that could reduce those adverse impacts. The inadequacies of the Draft EIS and Draft Supplemental EIS were detailed in comment letters submitted by Waterfront Landings on August 12, 2015 and May 18, 2016, Exhibits A and to this petition. Those comments are incorporated in this petition by reference. The FEIS contains no changes or even consideration of alternatives to correct those de?ciencies. Without limiting the foregoing, the FEIS for AWPOW is inadequate in at least the following respects. a. Failure to adequatelv describe the environmental impacts of the Overlook Walk component of AWPOW The FEIS focuses almost entirely on the effect of AWPOW on the central waterfront and fails to adequately describe the impact on either Waterfront Landings or the northern waterfront. b. Failure to consider reasonable alternatives The identi?cation and analysis of alternatives is the heart of an EIS. WAC 197?11- 440(5) requires that: Reasonable alternatives shall include actions that could feasibly attain or approximate a proposal?s objectives, but at a lower environmental cost or decreased level of environmental degradation. MILLER NASH GRAHAM DUNN LLP WATERFRONT LANDINGS OWNERS PETITION ATTORNEYS AT LAW FOR REVIEW OF EIS 8 T: 206 624 812131120206 140 9599 280l ALASKAN WAY. SUITE 300 SEATTLE, WASHINGTON 98121 The FEIS is inadequate because it does not consider reasonable alternatives that would allow AWPOW to achieve its stated objectives with less environmental degradation. For a private project, it may be appTOpriate to consider only a ?no action? alternative. But for a major public project, SEPA expects that the EIS will consider a reasonable range of alternatives. For a project of this character, it is simply untrue that there is only one alternative that could achieve the project?s objectives, and untrue that there is no mitigation that the public can commit to that would achieve the project?s objectives at lower environmental cost. By placing the intersection of Alaskan Way and the Elliott Connector beside Waterfront Landings at Pine Street, the project as designed will permanently blight Waterfront Landings. It will cut Off the northern waterfront from the central waterfront, destroying the View for what is now one of the great pedestrian experiences of Seattle by interrupting the sweeping View of the harbor for pedestrians walking south along Alaskan Way. The State Environmental Policy Act requires that before a proposal with such Signi?cant adverse impacts is implemented, public decision-makers and the public at large have full disclosure of the environmental impacts of the proposed action and the possible mitigation that might achieve the proposal?s objectives at lower environmental cost. c. Inadequate description of possible mitigation An essential element of an adequate EIS is description of the possible mitigation for the adverse impacts of the proposal. Without a description of the possible mitigation, decision- makers do not know how they may be able to mitigate those adverse effects. It is not the function of the EIS to decide what mitigation will be provided; its function is to describe the mitigation that could alleviate the adverse impacts, so that decision-makers can determine what mitigation will be required. As detailed in Exhibits adequate description of either the mitigation that can be provided for the signi?cant adverse construction impacts of the project or the signi?cant adverse impacts of the project once it is completed. The responses to Waterfront Landings? comments simply demonstrate that the FEIS makes no commitments to any mitigation WATERFRONT LANDINGS OWNERS ASSOCIATIONS PETITION MILLER DUNN LLP FOR REVIEW OF EIS - 9 T: 206 624 340 9599 280 ALASKAN WAY, SUITE 300 SEATTLE. WASHINGTON 9812l adverse construction or operational impacts beyond a vague and unenforceable commitment to ?continue working with? Waterfront Landings. That is not the level of detail or precision that an adequate EIS requires. 6. REQUESTED RELIEF Waterfront Landings asks the Hearing Examiner to determine that the FEIS for AWPOW is inadequate under SEPA and to remand the matter to SDOT for preparation of an adequate EIS. DATED this of November, 2016. MILLER NASH GRAHAM DUNN LLP 2%..724743 Elaine L. Spencer WSBA NO. 6963 elaine. spencer@millernash. com Madeline Engel WSBA No. 43884 madeline. engel@millernash. com Attorneys for Petitioner Waterfront Landings Owners Association 70134243.1 WATERFRONT LANDINGS OWNERS PETITION MILLER DUNN LLP FOR REVIEW OF EIS .. 10 T: 206 9599 ZBUI ALASKAN WAY. SUITE 300 SEATTLE. WASHINGTON QBIZI Exhibit A I I I warerfer landings August 12, 2015 EIS Comments c/o Mark Mazzola, Environmental Manager Seattle Department of Transportation PO Box 34996 Seattle, WA 98124-4996 Comments of Waterfront Landings Condominium on Draft EIS for Waterfront Seattle Alaskan Way, Promenade and Overlook Walk Dear Mr. Mazzola, Waterfront Landings is a 232?unit residential community that is home to nearly 400 residents who have chosen to live there because of the scenic beauty of the location, the amenity of its pedestrian environment, and its easy access to downtown Seattle. It was one of the ?rst developments in Seattle where the City insisted that a signi?cant number of units be small enough to be a?ordable. As a result, while Waterfront Landings has some lovely homes with privileged owners, it also includes a signi?cant number of very small homes, owned by residents on modest ?xed incomes. Of the 386 people living at Waterfront Landings, 25% are senior citizens and retired, 6% are children, and 70% are adults, most working. The negative impact of the central water??ont plan as currently proposed will signi?cantly reduce the quality of life and safety for all residents living at Waterfront Landings Condominiums. The following are our major concerns: - The proposed elevated roadway on Alaskan Way and Pine Street will create toxic fumes and dirt from the road and subject residents to noise at all hours, as well as cutting off Waterfront Landing?s access to downtown Seattle. Combined with the Overlook Walk, it will sever the north waterfront from the central waterfront. - The new 25-foot wall in Pine Street will make the remnant of Pine Street a shaded, dangerous, blighted neighbor to Waterfront Landings. . Safety and emergency needs of residents will be compromised during construction due to lack of access to emergency medical and ?re vehicles, and during operation due to increased homeless use and illegal activities in the area next to and behind the building. - Loss of parking for resident's family or guests which will isolate our homes from the City. - The service drive, which is essential to replace cur lost use of Pine Street when the grade of Alaskan Way and Pine Street is changed, will subject residents to noise and fumes at all hours, while also destroying the walkway in front of Waterfront Landings, which is a signi?cant amenity of our homes. Having Focused on only One Alternative, the DEIS Incorrectly Pretends that the Preferred Alternative Achieves the Project Objectives.- The Preferred Alternative does not propose a ?waterfront for all,? it is a waterfront for tourists or young, fit bike riders, not for people with mobility issues or people pushing strollers, such as many Waterfront Landings residents and their families. It does not ?reconnect the City to its waterfront,? it severs the north waterfront from the central waterfront, and leaves Waterfront Landings tucked behind a new highway overpass, with access to Downtown Seattle much restricted when compared to our current access. It does not ?embrace and celebrate Seattle?s past,? it blocks the views of the historic waterfront and Pike Place Market fer everyone on the formerly-majestic walk of the northern waterfront. The EIS must consider alternatives that w0uld reduce those impacts. The premise of the DEIS is there is only one alternative that could achieve the City?s objectives within the confines of the existing right of way. That is absurd. If the City hired ten world?cl ass design teams it would get more than ten alternative ways to achieve the City?s objectives, because most of the design teams would offer the City several alternatives. And most of the design team would propose alternatives that recognized that the public interest is not served when the City builds something that aggressively damages its closest neighbors then turns a blind to its impacts. The EIS also must consider realistic alternatives that could be implemented if the project as proposed is not feasible. Waterfront Seattle has been opaque about the cost of the AWPOW projects, and where it expects to get the money to build them. At this point the public has no basis to conclude that the Preferred Alternative is feasible. Instead of providing the public with a realistic basis to understand what would happen if the City does not build the Preferred Alternative, the BIS tries to magnify the disadvantages of the ?No Action? alternative by assuming that the City would permanently stand helplessly by and let all of the worst qualities of the No Action alternative continue inde?nitely. Read closely, the EIS shows that modest investments would amdiorate many of what the EIS treats as the disadvantages of the ?No Action? alternative. Once the viaduct is removed, it is likely that a range of approaches to enlivening the Waterfront and truly connecting it to the heart of the city will become more obvious. The EIS does the City a disservice by not considering ways to keep the City moving while that process unfolds. The EIS Must Consider an Alternative that moves the Intersection ofAiaskan Way and the Elliott Extension to Pike Street, as Proposed by WSDOT, the City and the Federal Highway Administration in 2009. The severe long-term impact on Waterfront Landings comes item the Preferred Alternative raising the grade of Alaskan Way in front of its southern building, and then raising the grade of Pine Street so that vehicles pass on a raised roadway a few feet from the southern building, letting people in the cars stare into residents? homes. Access to the Waterfront Landings parking garage will become difficult and circuitous. The gracious walkway in front of the building will be eliminated. The ability to walk down the east side of Alaskan Way to the Central Waterfront will be eliminated. Garbage and recycling and delivery trucks will pass directly under residents windows. Residents making the hairpin turn into the property to reach the garage run the risk of being run down by trucks and other vehicles making a sharp descent and right turn from the new raised intersection. The project has shown the public glossy renderings that minimize the adverse impact on the quality of the space around the building, by distorting the proportions and showing ?owers and sunlight at the base of a north-facing wall. To give decision-makers an accurate understanding of the impact, we built a model, based on the plans and elevations we received from the City. By any reasonable measure, that new road will be a long?term blight to Water?ont Landings and a continuing traf?c hazard for vehicles and pedestrians. In 2009 the Washington State Department of Transportation, the Federal Highwaty Administration and the City of Seattle developed a plan for the Elliott Western Connector that would eliminate the adverse impacts on Waterfront Landings. In meetings with the Project Team we have been told that the only reason that the 2009 plan is not an alternative now is that it would be impossible to have the Overlook Walk connect the Pike Place Market to Pier 62/63 with that plan. Pier 62/63 is a seismically unsound wooden platform, with no historic value, and which the City has no money to put to public use assuming that the federal resource agencies such as the U.S. Army Corps of Engineers would give the City permits to restore Pier 62/63 to public use. The EIS must consider an alternative which reverts to the plan for the Elliott Western Connector, and directs pedestrians to the Central Waterfront rather than to Pier 62/63. The EIS Must Consider An Alternative That Connects the Pike Place Market to the Central Waterfront Without Severing the Connection between the North Waterfront and the Central Waterfront In rare candor, on page 5-25 the EIS says, ?[T]he Overlook Walk would divide the Alaskan Way corridor visually and physically into separate north and south segments and Would serve as the new visual terminus for views from Alaskan Way. This would result in substantial impact on the character and aesthetics of the northern half of the Waterfront landscape unit.? Today, the views of the waterfront, the Pike Place Market, Mt. Rainier and downtown Seattle for anyone walking south along the Alaskan Way from Broad Street, is one of the world?s great pedestrian vistas. The Port of Seattle?s pedestrian overpass at Bell Street was designed so that it did not destroy that view. But the Overlook Walk, in its single-minded zeal to enhance the view of tourists coming from the Pike Place Market to the Waterfront, will be a huge visual barrier severing the north waterfront from the central waterfront. We understand the desire to get pedestrians over Alaskan Way and the new bike path, but the Port?s Bell Street overpass demonstrates that doesnlt require damaging the views of the Waterfront from the north. City environmental policy requires that development protect public views of historic landmarks. The BIS has only one visual depicting how it will hide the views of the historic Pike Place Market. Figure 5-8. But the Overlook Walk will block the views of both the Pike Place Market and the historic piers on the Central Waterfront, inserting a swath of glass, steel and concrete into one of Seattle?s most ?ne-grained historic urban settings. The EIS Must Disclose How the City Will Keep the New Raised Pine Street from Being a Magnet for Homeless Camping and Illegal Activity Immediately Adjacent to Waterfront Landings. Over many years, many police chiefs and many mayors, the City has become increasingly unwilling or unable to deal with homeless individuals camping in its public spaces, and engaging in a range of illegal activities. Waterfront Landings residents have endured that phenomenon with camping under the Viaduct. With the removal of the viaduct, that population will need to ?nd new places to camp. We understand the City hopes to keep people from camping in the new park, but the planters at the base of the new wall for Pine Street, or the area under the new Elliott Way extender that must be available to service vehicles behind Waterfront Landing will be prime spots for homeless camping. They will not be readily visible from Alaskan Way, will be sheltered from southwest winter winds, and will be relatively quiet. The EIS needs to disclose how the City will prevent that outcome. Whatever happens in the rest of the Project, the intrusion of the new Pine Street on Waterfront Landings will be magni?ed unless the City keeps it free of homeless camping and illegal activity. The EIS Must Consider a Redesign of Overlook Walk that Would Not Doom the Seattle Aquarium to Mediocrity The Seattle Aquarium is one of Waterfront Landing?s closest neighbors. It is the largest draw to the Waterfront, and it has gone through an extensive master planning process, with the goals to, among other things, ?build on [its] role as an authentic and uniquely Seattle aquarium at the center of Seattle?s great new waterfront? and ?make the Aquarium the single most compelling and fun element of the new waterfront.? That Master Plan de?nes the way the Aquarium can achieve those goals. But to achieve those goals, the Aquarium needs nearly 76,000 square feet of new building. One of its options likely the only realistic option - for where to put that space is on the block the Preferred Alternative instead consumes with the Overlook Walk. According to the EIS, pp. ES-8 and 2'-15, the Overlook Walk will leave the Aquarium with only 22,000 square feet of new space, or less than a third of what it needs. Providing the Aquarium with the space it needs would require moving the new Aquarium to the north end of the block between Pike and Pine where the Preferred Alternative instead puts the new raised Pine Street, and putting the intersection of Alaskan Way and Elliot Way at Pike Street. The roof of a new Aquarium on that block could provide a landscaped greenspace path down from the Pike Place Market to the Waterfront. It could provide an overpass of Alaskan Way that landed both Aquarium visitors and the general public on the west side of Alaskan Way and the new bike path. Redesign to accommodate the Aquarium?s needs could also resolve the concerns of Waterfront Landings with Pine Street. Waterfront Seattle?s. failure to consider such an altemative is inexplicable. Public records show that through October 2014, Waterfront Seattle had spent nearly $39 million on the design, without SEPA review. That?s an enormous amount of money, when compared to the $53 million Seattle voters agreed in 2014 to spend on universal preschool, the $13 million cost of a new ?re station, or the $2 million per mile cost of sidewalks in neighborhoods which have none. One has to believe that the City?s refusal to consider alternatives has much more to do with the Project Team not wanting to admit it spent $39 million on design of the project and had to redesign it than it has to do with any real limitation on alternatives. Waterfront Seattle Must Provide Speci?c and Effective Mitigation for the Construction Impacts Disclosed in the EIS. The EIS states that construction of Waterfront Seattle will occur from 2017 through mid- 2020. It also says that Alaskan Way will be closed for ?a short period (assumed to be up to 4 months for the purpose of analysis)? in front of Waterfront Landing. The EIS acknowledges that closing Alaskan Way will require all vehicles, including emergency vehicles, to cross the Burlington Northern tracks at Wall, Vine, Clay or Broad Street. The incorrectly suggests that the delay would be between 1 and 5.5 minutes, which they say is the ?typica time for gate closures. The author clearly hasn?t crossed at those locations often. Burlington Northern trains sometimes stop while blocking the crossing, presumably to switch tracks at the grain terminal. A second train sometimes comes before the ?rst one clears. Closures can last 20 or 30 minutes or more. That is an unacceptable time for emergency vehicles to be delayed. If it seems a ?moderate? impact to the EIS dra?ers, it is a life-threatening impact to someone who needs the emergency vehicle. At a bare minimum, Alaskan Way must always be open to emergency vehicles. The EIS must also provide much more speci?c mitigation for the other construction impacts. Water?'ont Landings has endured half of the three-year construction window for the s'eawall replacement. Another three years of construction, including multiple shifts and traf?c disruption, requires signi?cant mitigation, in keeping with the signi?cant impact. The City must address the loss of parking on the waterfront. The EIS makes it clear if you can?t walk the grades between First Avenue and the Waterfront, you?re out of luck. The EIS suggests that AWPOW will enhance transit. That is true for people taking buses between West Seattle or Burien and downtown. But there is no transit on the waterfront. The City removed the Waterfront Trolley, and there is no assurance it will ever be replaced. Today Waterfront Landing has easy accessible access to Downtown Seattle; we can walk south on Alaskan Way and then take the elevator of the Market parking garage to the level of First Avenue. The Preferred Alternative will eliminate that access. This summer the Pike Place Market parking garage and all available on street and off street parking off of Alaskan Way has frequently been 100% full. That is the ?Jture, according to the EIS. That has a signi?cant adverse impact on living at Waterfront Landings. The EIS says, p. 4-16, ?[T]he Action Alternative would remove parking spaces primarily along Alaskan Way and in the current Alaskan Way Viaduct right of way. A few spaces would also be removed on east? west streets. Parking patterns may shift, as motorists accustomed to parking on the street in a particular location may have to travel several blocks farther to ?nd available parking.? Those ?motorists? are our elderly parents, our friends with mobility limitations, sometimes our children bringing our grandchildren to visit. Our guests are often not capable of walking ?several blocks further to ?nd available parking,? then walking the grades proposed by the Preferred Alternative. If that is their choice, the people most important to us will not be able to visit our homes. It is hard to imagine a more signi?cant adverse impact. The stated goal of a ?Waterfront for all? becomes a cheap jingle. Conclusion We want to be clear. We do not Want to be at war with the City. We want a Waterfront Seattle that we can be enthusiastic about. But the project team?s adamant refusal to consider our concerns, and its insistence on its way, has led to a project that will be severely damaging to us. The good news is that the SR 99 replacement tunnel is not expected to be open until. spring of 2018. That gives the City time to start over and get this right. We look forward to working with the City to accomplish a great waterfront, and ask the City to give us that opportunity, not simply insist on proceeding in a way that will fundamentally blight Waterfront Landings. Thank you for considering these comments. Very Truly Yours Waterfront Landings Board of Directors Marir?en J. Miller, President ?i?m 1y, Vice FEW Robert Stevens, Secretary Treasurer ?Wyckofd Mean?rge Stephan Fjelstad, Member at Large ?aw/(AK Daniel Mathis, Member at Large muf?n Frederick, Member at Large Wa fre tLandings Residents Unit @512 ?e?wg? Unit M135 Unit 313-8 g; $ng UM Unit 5/518" Unit ?cj a ??in WW4. Unit Lia Unit ?3 M3 MM Leif?OW \1'5 j" Unit ?j?a Unit ?35 Unit 515 ?3414. fUmt Unit .33 0 Unit 43.? Unit 347 a?ggw wk Unit Aam cama- Urntm2?5 Unit?_ Mm Cl 141M214 M4. Umt 572? Unft 35g, $de 9W0 Unit1_9_'+ Unit Cl UnitED :3 Unit 13:? 0 ff: . a Unit 52?? Unit Mir-76? Unit jg; GLW 4&1;ch [311% - umtgg' Wm Sum wQ/Mf Un iti?i! Unitil WM Unite?0% Qm?zw/ Witioa? Un 057 WM 75?: Lu . QLM Umt +57 ?53,an Unit Umt'?jf] AMQ um??Lg? :DW/g/mw Unit/5&7 3 ., Uniti' Im?ggf Unit 2439;; Unit 111 Unit Unit 4 (5/494 5 i? Unit ?ag; Wh?br Mommas) Unit . nitw WQWL. \3 mm Unitm Unit I WW gm ?ag Un 112% Unit mm Unitua Unity??5- (Egg Unitlla Umt 24% Unlt I ?lm ?gv Unit gag Unit Jim: I we Unit Unit Unit Unit Unit Unit? Unit? Unit Unit Unit Unit Quart z??ww Unit?JIfg?" Unit Unit Unit Unit Unit Unit Unit ,9 Unit Unit Unit Unit (1.6qu Kiwi/I: C. Craiq UnitEiZ? UnitlL Unitlj_ UnitD? Unitgh Unit UnitIIl__ UnitL Unit Unit ELM UnitD_ 7' Unit ?o_9 Unit Unit Unit Unit Unit Unit Unit Unit Unit Unit Unit Elizabeth Kanny, Vice President Robert Stevens, Secretary Treasurer Paul Wyckoff, Member at Large Stephan jelstad, Member et Large Daniel Mathis, Member at Large Brian Frederick, Member at Large Waterfront Landings Residents Elizabeth Kenny, Vice Fresident Robert Stevens, Secretary Treasurer Paul Wyckoff, Member at Large Stephan Fjelstad, Member at Large Daniel Ma?lis, Member at Large Brian Frederick, Member at Large Waterfront Landings Residents FJmanL LLC. Un'rt 7544+ Unit Unit Unit Unit Elizabeth k??ny, Vice President Robe? Stevens, Secretary Treasurer Paul Wyckoff, Member at Large Stephan Member at Large DanielT/Iathis, Member at Large Brian Frederick, Member at Large: Waterfront Landings Residents Unit Uliit Unit Elizabeth Kanny, Vice President Robert Stevens, Secretary Treasurer Paul Wyckoff, Member at Large Stephan Fjelstad, Member at Large Daniel Mathis, Member at Large Brian Frederick, Member at Large Waterfront Landings Residents Wabb- (fat-50b6, Wm 7 ?th Unit 41/ Unit Unit Unit Elizabeth Kanny, Vice President Robert Stevens, Secretary Treasurer Paul Wycko??, Member at Large Stephan Fj elstad, Member at Large Daniel Mathis, Member at Large Brian ?rede?ek, Member at Large Waterfront Landings Residents pm_4w 133111404 Unit Unit Unit Unit Ur 33?me Unit Unit Unit cc: Honorable Ed Murray, Mayor Council President Tim Burgess Councilmember Jean Godden, Chair, Central Waterfront, Seawall and Alaskan Way Viaduct Replacement Program Councilmember Sally Bagshaw Councilmember Bruce Harrell Councilmember Nick Licata Councilmember Mike O?Brien Councilmember John Okamoto Councilmember Tom Rasmussen Councilmember Kshama Sawant Exhibit MILLER Pier?!) 2801M "t 300 AS RAHAM seatuiivikhii?m?'gem] 85 NLLP OFFICE: 206.624.3300 ATTO EYS AT LAW 206.340.9599 Elaine L. Spencer elaine.spencer@millernash.com 206.777.7551 direct line May 18, 2016 BY FIRST-CLASS MAIL AND ELECTRONIC MAIL AWPOW Supplemental Draft EIS Comments c/o Mark Mazzola, Environmental Manager Seattle Department of Transportation PO Box 34996 Seattle, WA 98124-4996 Subject: Comments of Waterfront Landings on Supplemental Draft Environmental Impact Statement for Alaskan Way, Promenade, and Overlook Walk Dear Mr. Mazzola: These comments on the SDEIS are submitted by Waterfront Landings Condominium, a 232-unit residential community immediately abutting Waterfront Seattle?s rerouting of Pine Street, the change of grade of Alaskan Way and Pine Street, and the Overlook Walk components of In its August 12, 2015, letter commenting on the signi?cant adverse impacts of AWPOW, signed by 110 residents, Waterfront Landings identi?ed the following major concerns with the environmental impacts of the proposal: a- The proposed elevated roadway on Alaskan Way and Pine Street will create toxic fumes and dirt from the road and subject residents to noise at all hours, as well as cutting off Waterfront Landings? access to dormtown Seattle. Combined with the Overlook Walk, it will sever the north waterfront from the central waterfront. The new 25-foot wall in Pine Street will make the remnant of Pine Street a shaded, dangerous, and blighted neighbor to Waterfront Landings. - Safety and emergency needs of residents will be compromised during construction due to lack of access to emergency medical and ?re vehicles, and Portland. OR Seattle, WA Vahcolwer, WA Bend, OR Long Beach. CA MILLERNASHJZOM NASH GRAHAM ATTO RN EYS AT LAW AWPOW - Supplemental Draft BIS Comments May 18, 2016 Page 2 during operation due to increased homeless use and illegal activities in the area next to and behind the building. Loss of parking for residents? families and guests will isolate residents? homes from the City. a The service drive, which is essential to replace the lost use of Pine Street when the grade of Alaskan Way and Pine Street is changed, will subject residents to noise and fumes at all hours, while also destroying the walkway in front of Waterfront Landings, which is a signi?cant amenity of their homes. None of those concerns are addressed by the SDEIS. All of them must be addressed. When the City announced that it would be preparing a supplemental EIS, Waterfront Landings hoped that meant the City was ?nally going to take its comments seriously. So long as the City insists on raising the grade of Alaskan Way and Pine Street adjacent to Waterfront Landings, it is not clear that Waterfront Landings property owners can ever accept the project. Nonetheless, Waterfront Landings leadership met with the Waterfront Seattle staff to outline the minimum mitigation that would be necessary in order for Waterfront Landings? leaders to consider recommending acceptance of the project. None of the mitigation measures that they consider essential are included in the SDEIS. Overlook Walk Alternative 2, replacing an expansion of the Seattle Aquarium for the unidenti?ed user of the former Building C, which was just conceptual in the ?rst place, is not a genuine alternative. So the EIS for this very public project considers no Lea; alternative, other than "no action." The City has never considered any alternatives to the Corner Plan. We believe SEPA expects more from the City. While Waterfront Landings will likely prefer the Aquarium as a neighbor to whoever else might have occupied Building C, and the Aquarium is less likely to countenance as much of the uncivil behavior tolerated at Steinbrneck Park as would whoever is ultimately responsible for the Overlook Walk, Waterfront Landings still believes that the City must consider a genuine alternative that does not change the grade of Pine Street or Alaskan Way abutting Waterfront Landings. The SDEIS gives only conclusory reasoning for why the City has not developed an alternative that moves the intersection of Alaskan Way and the Elliott Connector to Pike Street (or south of Pike Street if needed). See SDEIS at 2-11. Portland. OR Seattle. WA Vancouver, WA Bend, OR Long Beach, CA MILLERNASH.COM MILLER NASH GRAHAM AITORN EYS AT LAW AWPOW - Supplemental Draft EIS Comments May 18, 2016 Page 3 It says that an intersection at the base of Pike Street would be elevated approximately ?ve feet above ground level. That suggests that the natural location for the intersection is perhaps south of Pike Street, which is ?ne with Waterfront Landings. Presumably the project has both the existing Alaskan Way right-of?way and the existing SR 99 right-of?way to work with. There is no reason why the intersection can?t be as far south as it needs to be so that the entire intersection is built on grade, which will be both cheaper to build and easier for vehicles, particularly trucks, to negotiate.1 . It says that the west crosswalk would increase in length from approximately 70 feet to 90 feet. While Waterfront Landings agrees that this is wide, it notes three things: First, a 90-foot crosswalk pales in comparison to the convoluted route that Waterfront Landings residents will be expected to take in order to reach the Pike Place Market and downtown Seattle if the Overlook Walk is built. Second, it is still ten feet shorter than the proposed crosswalk at South Washington Street under Main Corridor Alternative 1, where Pioneer Square residents would cross Alaskan Way to enjoy the restored historic Washington Street Beat Landing. The City cannot rule out a go-foot?wide crosswalk as being too wide for pedestrian access, while imposing a too-foot crosswalk on a key intersection in Pioneer Square. Third, the whole purpose of the Overlook Walk was to create a pedestrian route over Alaskan Way to ful?ll the objective of reconnecting the city to its waterfront. If Overlook Walk is actually as effective in funneling all the people who want to get from downtown Seattle to the waterfront across the Overlook Walk as the project seems to expect, the crosswalk at Alaskan Way level underneath the Overlook Walk should not be too signi?cant. We do not believe the design team has given meaningful thought to how people will actually move through the project, particularly people with limited mobility. But a 90-foot crosswalk is not an excuse to not consider a reasonable alternative in Every sketch the Waterfront Seattle staff has provided of moving the intersection of the Elliott Connector and Alaskan Way south to Pike Street has assumed that Elliott Connector and Alaskan Way must be a straight street going up the hill under the Pike Place Market, with Alaskan Way north of the intersection heing relocated to bend east to intersect that new, straight street. That con?guration relegates Alaskan Way north of the intersection to a minor side-street, and permanently damages the views for pedestrians walking south along Alaskan Way. 11 is not clear what motivates that destruction of Alaskan Way as the boulevard along the entire downtown waterfront not just the portion of the waterfront adjacent to the new seawall. It may be a traf?c engineer?s effort to give primacy to maximizing the speed of traf?c coming to and from BallardJMagaolia; it may something else. But there is no reason why the Elliott Connector cannot come down to grade level, and there bend to intersect the existing path of Alaskan Way. Portland, OR Seattle. WA Vancouver, WA Bend, OR Long Beach, CA MILLERNASH.COM MILLER NASH GRAHAM ATTORNEYS AT LAW AWPOW - Supplemental Draft EIS Comments May 18, 2016 Page 4 this project when a larger crosswalk is accepted as the norm in another part of the project. Because the SDEIS simply refuses to consider an alternative that moves the intersection of Alaskan Way and Elliott Connector to the south, the SDEIS itself provides no basis for the public to understand whether that is reasonable or not. Waterfront Seattle staff has shown Waterfront Landings leadership two sketches of designs that would move the intersection to Pike Street. Both appear to be based on assumptions that are not valid. The ?rst is an assumption that trucks must be able to reach the Port of Seattle?s cruise ship dock at Pier 67 from the north, coming down the Elliott Connector. Trucks cannot now reach Pier 67 from the north without crossing the railroad tracks at Broad Street, and once the project is built, they will still be able to reach Pier 67 the same way. The stated purpose of the Main Corridor (SDEIS at is to ?accommodate safe, efficient, and reliable travel between the south downtown area and Belltom." (emphasis added). While we believe the purpose of the Main Corridor is and should be much broader than that, that stated purpose is necessitated by the fact that the deep-bore tunnel does not have any entrance/exit comparable to the entrance/exit to the viaduct at the Pike Place Market. We understand that the Port might like the option that it does not now have of bringing trucks to Pier 67 from the north. But nothing requires that the desires of the Port be met to Waterfront Landings? detriment. At the very least, the desire of the Port for access it does not now have cannot be the basis to restrict the alternatives considered. The second assumption seems to be that the ?Main Corridor? is not Alaskan Way (both north and south of the Aquarium), with a new intersection of Alaskan Way where the Elliot Connector intersects with it. Rather, the traffic engineers seem to have assumed that since the stated "purpose? of the Main Corridor is to move traf?c from Belltown to SoDo, the ?Main Corridor? is a new street consisting of Alaskan Way south of the Aquarium and the new Elliott Connector, with Alaskan Way north of the Aquarium becoming the street that intersects the ?Main Corridor.? 2 Indeed, the City 2 The DEIS stated the goals of the project as a whole as being: i) create a waterfront for all, 2) put the shoreline and innovative, sustainable design at the forefront, 3) reconnect the city to its waterfront, 4) embrace and celebrate Seattle?s past, present and future, 5) improve access and mobility (for people and goods), 6) create a hold vision that is adaptable over time, and 7) develop consistent leadership from concept to operations. DEIS at ES 1. The speci?c focus of each ot?the four components of must be understood to be in that context and subject to those overarching objectives. The main corridor cannot focus on north-south throughput at the expense of the larger purposes of the project as a whole. Portland, OR Seattle, WA Vancouver, WA Bend, OR Long Beach, CA MILLERNASH.COM NASH GRAHAM NW ATTORN EYS AT LAW AWPOW - Supplemental Draft EIS Comments May 18, 2016 Page 5 apparently intends to abandon nearly 50 feet of the existing Alaskan Way right-of?way so that the Aquarium Ocean Pavilion can be built on what is now Alaskan Way. The result will be a loss of one of the great views in Seattle, that experienced by pedestrians walking south from the Olympic Sculpture Park or one of the northern piers to the central waterfront. The third assumption is that the City must create a public open space that it calls ?Aquarium Plaza? in order to achieve its objectives for Waterfront Seattle. While we understand that the City would like all the open space it can get (whether or not it can maintain it), the removal of the Viaduct will enable creation of acres of additional public open space along the Promenade. The City already has Pier 62/63, which would be usable public open space. The City claims it has plans to rebuild it so that it is structurally sound concurrent with the next phase of the Seawall project adjacent to those piers, although where the money to do that is to come from has not been disclosed. The City has Waterfront Park, which it does not have money to rehabilitate. It has not explained how it will fund the maintenance and supervision required in order to keep the new public open spaces created by Waterfront Seattle from becoming overrun by the sort of antisocial behavior that has plagued Steinbrueck Park and other downtown open spaces. The City has many ?gathering? spots, including but not limited to Westlake Park, Seattle Center, Edwards Park, and the new South Lake Union Park. There is nothing essential about creating a public open space at ?Aquarium Plaza? for Waterfront Seattle to achieve its purposes and objectives. It appears that those three assumptions, or some variation on them, not only are the excuse for not considering moving the Elliott Connector to Pike Street or south of Pike Street, but also will restrict the Seattle Aquarium?s expansion to only 48,000 square feet rather than the 76,000 square feet that its recently adopted master plan says it needs in order to achieve its long-term vision. By moving the Elliot Connector south, the Aquarium likely could have the additional building size it needs. Using the Aquarium?s expansion?s roof as public open space, as the Aquarium has proposed, is certainly a reasonable alternative to the jerry-rigged Aquarium Plaza provided by either Overlook Walk Alternative 1 or Alternative 2. To have an adequate EIS, the City needs to consider an alternative that moves the intersection of the Elliott Connector to the south without regard to Port truck traf?c to Pier 67, that continues the open space and transportation functions of Pine Street and Alaskan Way without alteration or intrusion, and that makes the Elliott Connector intersect into Alaskan Way at grade level. With those criteria in place, it then needs to determine whether the Aquarium expansion, south of existing Pine Street and [Portland OR Se attle, WA Vancouver, WA Bend. OR Long Beach. CA MILLERNASH.COM MILLER NASH GRAHAM 8c DUN NM ATTORNEYS AT LAW AWPOW - Supplemental Draft EIS Comments May 18, 2016 Page 6 east of existing Alaskan Way, can be large enough to actually meet the Aquarium?s long- term needs. If it can be, that would be a genuinely viable alternative. If the Aquarium expansion needs to extend into the Alaskan Way right-of?way in order to have enough space for its expansion needs, that intrusion should be as small as possible. Because Waterfront Seattle has made not serious effort to show whether an alternative that moved the intersection of Alaskan Way with the Elliott Connector could be viable, Waterfront Landings asked a transportation engineer to see whether it was possible to move the intersection of Alaskan Way and Elliot Connector to Pike Street, while still leaving room for the Aquarium?s Ocean Pavilion as it is presented in the SDEIS, and having the Overlook Walk incorporate the roof of the Ocean Pavilion and allow pedestrians to pass over Alaskan Way between the Pike Place: Market and the Waterfront Park and the Aquarium. Attached is his work, demonstrating that it is indeed possible.3 His work, like the sketches in the SDEIS, is schematic and undoubtedly requires further development. But it demonstrates that an alternative that reduces the harm to Waterfront Landings and produces better traf?c planning for the City is entirely possible. The City should now develop that alternative to determine whether the Aquarium could get the space it actually needs for its expansion, and whether it could do so without intruding into the Alaskan Way right-of-way, so that the views of the City for pedestrians walking south on Alaskan Way from the Olympic Sculpture Park and the northern piers will be preserved. This letter is restricted to commenting on the new alternatives presented in the SDEIS and the need for consideration of real alternatives. We want to emphasize that the SDEIS responds to none of Waterfront Landings? comments on the DEIS, and that those comments must receive a substantive response. 3 He was forced to work with plans that were dif?cult to scale, as a result of which some of his dimensions make the Preferred Alternative seem less harmful than it actually is. Waterfront Landings will have a claim for damages against the City from raising the grade of Pine Street and Alaskan Way. That damage claim will include all the damages to access, damage to the canopy of the Viaggio Building Lobby if service and garbage trucks cannot negotiate the turn without hitting it, the loss of emergency access, as well as damages due to loss of light and air, light pollution from the strobe effect of vehicles on the raised highway, and noise, dust and contaminant pollution to units within the project. Portland, OR Seattle, WA Vancouver. WA Bend, OR Long Beach, CA MILLERNASHLOM MILLER NASH GRAHAM ATTORN EYS AT LAW AWPOW Supplemental Draft EIS Comments May 18, 2016 Page 7 Very truly yours, NASH GRAHAM LLP o- Elaine L. Spencer Enclosure Waterfront Landings 70099293.1 Portland, OR Seattle. WA Vancouver, WA Bend. OR Long Beach. CA MILLERNASH.COM AQUQRIW. . .. 3? WWI we now. naszau CONCEPT 2 (Preferred): Realign Intersection 270 Feet South to Accomodate Current Layout of Ocean Pavilion mm? I YO feet . 4 35km . . fem at": i EN 2C 193! Currenl WATERFRONT ENTRANCE .