March 6, 2018
Sound Transit TOD Division
401 S Jackson St
Seattle, WA 98104
Dear Brooke Belman,
We appreciate the opportunity to comment on Sound Transit’s draft TOD policy update. Your department
has spent the last year listening to our concerns and thoughtfully preparing this policy document. We have
a handful of comments that would help ensure strong implementation and equitable TOD outcomes.
Puget Sound Sage improves the lives of all families by creating shared prosperity in our regional
economy. We bring together community, labor, faith, and environmental leaders to advance a common
agenda for racial and social equity, a stronger democracy, better jobs, a clean environment, and thriving
communities.
South Communities Organizing for Racial/Regional Equity’s (South CORE) vision is sustainable multiracial neighborhoods in the Rainier Valley and South King County where all community members are
socially included, economically self-sufficient, politically engaged, and are at the forefront of shaping the
future of our city, county and region. We want to ensure that our members, clients, and neighbors benefit
from the light rail investment and promised economic, environmental and health benefits for our
communities. That is why we came together in 2013 to be an organized voice for community controlled
and inspired development.
There are three overarching comments that apply throughout the document:
1. We believe that the solution for true equitable engagement lies within the expertise of
community. Therefore, we have outlined principles we hold about equitable and meaningful
community engagement below. By using an equity frame to undo a system that reinforces
systemic oppression, the Agency must center its community engagement in social and racial
equity and leadership from communities of color, including African Americans, low-income
communities, women, LGBTQ community, immigrants, and refugees. A new Agency framework
for community engagement an opportunity to outline strategies that will help the Sound Transit
get closer to doing community engagement that is rooted in a racial equity. It is our intent to
ensure accountability to this outcome.
We are pleased with the agency’s new emphasis on deep and thorough community engagement,
but urge you to consider how the agency will:
a. Demonstrate how you plan to achieve these new engagement goals. We have developed a
set of principles for authentic community engagement including:

 i. Tailor and resource outreach to the least accessible and most excluded
communities.
ii. Grant power to set policy agenda to communities most impacted by current
issues.
iii. Create an effective coordinated engagement structure that streamlines
collaboration across constituent groups.
iv. Identify and communicate short-term and/or long-term goals to community.
v. Make sure that every opportunity for engagement has true opportunity for
change, which can be achieved by reaching out before the plans have been
developed.
vi. Guarantee that the new system of community engagement is inclusive of each
and every neighborhood.
vii. Meet people where they are at in terms of the time of day, location, basic needs
(i.e. food, childcare, translation, and transit).
viii. Engage with trusted advocates of faith/community groups.
ix. Resource community organizations to do outreach with no strings attached.
x. Utilize relevant communication mediums, including: ethnic media, social media,
and in-person outreach.
xi. Do not overly rely on technology.
b. Measure the impact of engagement and outreach. Specifically how will you demonstrate
accountability to those you have engaged with- you need to be able to report back to
stakeholders and show them how their suggestions and feedback were incorporated into
plans and policies.
2. Define Equitable Transit Oriented Development: Ensuring that TOD results in real equity
outcomes requires a sharp focus on what equity means and a steady determination to achieve
those outcomes. By including a racial justice framework in TOD planning and policy in Rainier
Valley, and beyond, we can help break the cycle of historical disenfranchisement and institutional
barriers to prosperity. TOD planning must tackle the threat of displacement head-on by
addressing the structural challenges that place low-income people and communities of color at
higher risk of being forced out. Furthermore, efforts to ensure racial equity in Rainier Valley must
be proactive – we cannot wait until after displacement has taken place to act on the negative
impacts of gentrification.
Puget Sound Sage’s definition of equitable transit oriented development hinges on five factors:
Existing low-income communities and residents of color should benefit from TOD investment
and be able to thrive in place; creating quality jobs for existing residents should be elevated as
equity strategy equivalent to creating low-income housing; Affordable housing should be
incorporated into TOD that meets the needs of low-income families and communities of color and
scales to create adequate opportunity; community-serving institutions and businesses are needed
to stabilize existing low-income communities of color as gentrification occurs; Racial equity
outcomes, not racial diversity goals, should drive TOD planning.
3. Policies and goals should indicate a clear path for implementation, monitoring, and evaluation.
Throughout the plan, lack of specificity in goal and policy language will likely result in the plan
being unenforceable, unmonitorable, and undermine the effectiveness of the Agency’s goals to

 increase transit ridership p. Specific, quantifiable equity measures should be identified and
monitored throughout the life of the plan.
4. Local and regional stakeholders as defined in Section 3.1.c should set a precedent for all places
where local and regional stakeholders are mentioned. We ask that Sound Transit add LGBTQ
community to the list in Section 3.1.c
Please find more specific notes below, by section.
Section 1
Policy goals should be specific and measurable. In section 1, we advise the agency to be as specific as
possible to ensure strong Equitable TOD outcomes. Specifically,
1.3 How does the agency define equitable outcomes at TOD and what are the measures to ensure
integration.
1.4 Similarly, how does the agency define community engagement and what does success look like?
1.5 It is well documented that when low-income transit dependent communities are able to afford to live
near transit they are more likely to use it than their wealthier counterparts. If Sound Transit wants to
‘increase the value and effectiveness of transit’ than the agency must prioritize the creation of familysized housing options for extremely low-income households, with goals around production of units at
30% of median income and below. The market in Seattle has shown that it can fill in the gaps by
producing market rate and luxury housing.
Section 2:
2.1 Again, we urge you to reference a shared definition of Equitable TOD.
2.2 See overarching comment regarding community engagement (see overarching #1 and #4).
2.4 Specifically, how will the agency facilitate community Equitable TOD? It seems like part of this is
about coordinating with local jurisdictions, but when jurisdictions don’t share the agency’s vision for
equitable TOD, how can Sound Transit take a more pro-active role? And again, we urge you to reference
a shared definition of Equitable TOD.
Section 2.5 refers to partnerships as allowed by law, what does allowed by law refer to?
2.6 We would like you to reference a shared definition of Equitable TOD here and outline a plan for how
the small properties along MLK Way South will be disposed of according to community equitable TOD
goals.
Section 2.7 refers to a Regional Equitable TOD strategy, which strategy is this? Similarly we have
concerns that the only two guiding documents are federal law and state law, how is the agency planning
to codify community input as guiding principle?

 Section 3:
3.1.d Please refer to overarching comments regarding (see #1 and #4)
Section 5: Generally, we are pleased with the direction of Section 5, but have specific feedback we
believe will strengthen equitable development outcomes of the Agency’s TOD plan.
5.1 Please refer to overarching comments regarding a shared definition of Equitable TOD (see #2)
In section 5.3.d the Agency lists out the qualifications of a successful development of Sound Transit
Surplus Property. We urge you to re-evaluate the assumptions in your listed qualifications to include the
following language from the City of Seattle’s Equitable Development Initiative: will prioritize applicants
who are best able to demonstrate a thorough organizational commitment to equitable development as both
practice and outcome in the relationship between their organization and the community whose interests
they seek to represent.
5.4 e. This section must be amended to include language around community ownership of land and
permanent job quality.
We believe that successful Transit Oriented Development is only possible when Equitable Development
is centered in the plans and policies. The draft Sound Transit TOD policy begins to center equity, but
requires additional specificity when it comes to how: how the agency will do better on community
engagement, how the agency defines equitable TOD and what levers you have to implement and advocate
for ETOD, and how the agency will measure these outcomes and benefits. Thank you for the effort you
put in to listen to those most impacted by displacement from regional transit expansion, we look forward
to working with you on the final policy.

Sincerely,
Jessica Ramirez and Giulia Pasciuto, Puget Sound Sage

Land for Justice Steering Committee:
Puget Sound Sage
Rainier Beach Action Coalition
Got Green
Horn of Africa Services
Eritrean Community of Seattle
Somali Health Board
Tenant’s Union of Washington