John C. Belcher•
Jack O. Swanson
Chester T. Lackey
Terrance G. Lewis
Douglas K. Robenson
Bradley D. Swanson
Belcher I Swanson
LAW FIRM, PLLC
Scoc S. Swanson
Pecer R. Dworkin
Mark A. Lackey
Hugh C. Klinedinsc
Kriscen C. Reid
Colm P. Nelson
·or Counsel
September 30, 2013
The Honorable Dawn Sturwold, Hearing Examiner
City of Bellingham
210 Lottie St.
Bellingham, WA 98225
RE:
Ambling University Development Group ("Ambling")
University Ridge Purpose Built Student Housing (the "Project")
Permit Nos.: Planned Permit (PDC2013-00002)
Design Review (DRC201 3-00008)
Critical Areas Permit (CAP2013-00019)
Variance (VAR2013-00001)
Dear Madame Hearing Examiner:
Following the hearing on September 11, 2013 for the four above mentioned applications
and the Project, you left the record open for public comment (by September 23, 2013) and the
City of Bellingham (the "City") and Ambling to make final submittals (by September 30, 2013).
This letter and the accompanying exhibits are Ambling's final submittal for the Project.
This final submittal includes responses to public comment, addresses Hearing Examiner
questions and offers final clarifying remarks supporting the Project. As there are specific issues
regarding the Project, each heading below discusses a specific issue.
Request:
Ambling requests that the Hearing Examiner approve the Project with the conditions
recommended by staff, as modified below.
Code Compliance and Zoning:
First and foremost, the Project complies with all relevant codes, standards, and
guidelines. For instance, under the Planned Residential Multi zone, this use is permitted
outright. It meets all setback, landscape, and buffer requirements. The Project proposes far
fewer beds than the maximum density allows. The necessary infrastructure is in place or will be
900 DUPONT STREET, BELLINGHAM, WASHIN GTON 98225-3105
TELEPHONE 360.734.6390
FAX 360.67 1.0753
www.belcherswanson. com
Belcher I Swanson
LAW FIRM, PLLC
September 30, 2013
Page2
constructed to suppo1t the Project. Moreover, the City of Bellingham Comprehensive Plan (the
"Comp. Plan") contemplates this use in this location, and the Bellingham Municipal Code (the
"BMC") provides the means to fulfill the Comp. Plan's requirements. 1 Finally, the Project fits in
the character of the neighborhood.2
The City's Staff Report offers a comprehensive discussion of every aspect of the
Project's compliance with relevant codes. Ambling does not see the benefit of reciting it here.
However, Ambling agrees with the City's analysis contained in its Staff Report, and, wilh very
minor exceptions (discussed below), Ambling accepts the City's recommendations and
conditions.
Ambling and the City Staff worked closely and for a long time to prepare, modify, and
resubmit the application for the Project. It is Ambling's intent to fine-tune this with additional
Staff and neighborhood input, prior to submitting for the building permit.
Response to Conditions:
The Staff Report proposes several General Conditions. Each is addressed in turn:
Conditions l, 2, 3, 4, 5, and 8: These are acceptable as written.
Condition 6: The last sentence of this condition requires any block walls to be textured.
Ambling wishes to strike this sentence so that some flexibility is afforded if Ambling wishes to
landscape the face of these block walls instead.
Condition 7: Ambling wishes to modify this condition to allow site grading and
foundation placement with City approved grading and foundation permits prior to issuance of
building permits.
Condition 9: We propose the following language for condition 9. "Approval of the
requested variance rnns with the land so long as the variance is applied to a project that proposes
the same use as is permitted by the permits granted herein."
Condition 10: We propose that this condition be concluded with the following sentence,
which is intended to allow the City and Ambling to agree to the specific language contained in
1
The neighbors claim that the Project is out of character with the neighborhood. The neighborhood character is
established by the Comp. Plan, which includes the Neighborhood Plan. These plans were drafted, updated, and
adopted by the City Council in numerous public processes over many years. If a neighborhood wants to establish or
change its character, it must enter this public process.
2
As an outright permitted use, the Project is, by definition, in the character of the neighborhood. Just because there
are single-family residences in this area does not mean the Project is out of character. Do not forget the
neighborhood already has many existing multifamily projects. See the aerial photo, the Puget Neighborhood Zoning
map, and Samish Neighborhood Zoning maps, which are attached as Exhibits A, B, and C, respectively. Two of the
most obvious are the 184 unit Maple Park Apartments at the foot of Consolidation Avenue less than a quarter mile
from our site, and the 25 acre, 218 unit mobile home project at 1200 Lincoln just around the coroer.
Belcher ISwanson
LAW FIRM, PLLC
September 30, 2013
Page3
the covenant after permits are issued. "The Applicant and the City shall mutually agree on the
final language contained in the covenant so long as the agreed upon language meets the intent of
this condition."
Condition 11: We agree to the design and installation of a pedestrian footpath and
propose that the Hearing Examiner accept Ambling's design recommendations as presented. We
will work with City Staff to finalize the details prior to permit submittal.
The Staff Report proposes several Parking conditions. Ambling accepts all the Parking
conditions as written, except for 2.A.1., which requires 0.5 long term bicycle parking stalls per
bedroom. As discussed above, Ambling proposes to provide 88 long term bicycle stalls. This is
twice the number of stalls that is required by the BMC. Ambling wi ll address any demand
increase in the future. Ambling proposes that Parking condition 2.A. l. be written as follows:
1. Long term bicycle parking stalls: 88 total stalls
The Staff Report proposes several other specific conditions related to separate portions of
the Project (i.e. Variance, Site Plan, Landscaping, etc.). Ambling accepts those conditions as
written.
Variance:
The Staff recommends approval of the variance. The variance meets the variance criteria
and it makes for a better development than would be allowed outright. The proposal provides
both a significantly larger buffer and much greater setbacks than would be allowed outright.
This satisfies concerns raised by the neighbors on Nevada Street and Marionberry Comt. It
decreases the amount of earthwork required fo r the site, allowing large areas of existing
vegetation to remain. It offers a better site plan. The building height increase subject to the
variance is nominai3 and the view impact to Puget Street residents is minimal, if not improved,
compared to the overall benefit to the site.4
Additionally, according to the City Staff, the original intent behind not allowing Height
Definition #2 to be used for a height variance in a situation like the one proposed here (i.e. where
the structure requiring the height variance was within 200' of a single family zone) was
predicated on flat sites. Here, this site slopes such that if Height Definition #2 was used the
Project would not require a height variance and would not impact the single fami ly zones.
Ambling respectfully requests that the Hearing Examiner approve the variance.
3
'
1
See the site cross-section with the variance line shown, which is attached as Exhibit D.
See Exhibit E
Belcher I Swanson
LAW FIRM, PLLC
September 30, 2013
Page 4
Traffic and Parking:
Ambling's Traffic Impact Analysis (the "TIA") was approved by the City of Bellingham
and adequately evaluated and addressed the transportation impacts from the Project. The scope
of the TIA was coordinated with City Staff and followed the City's standard methodology
contained in the BMC and Comp. Plan. The results of the study determined that none of the
studied intersections exceed the City's level of service ("LOS") E standard. It is only when the
intersection exceeds (or is worse than) LOS E, does traffic mitigation, beyond the City's
Transportation Impact Fees ("TIFs"), become required. 5 None of the studied intersections fall
below LOS E after traffic from the Project is using the infrastructure. Thus, no mitigation is
necessary based on the TIA.
Ambling is confident with the results of the TIA, but, based upon recent, specific,
comments submitted by neighbors concerning the TIA, Ambling performed a supplemental
traffic analysis. This supplemental traffic analysis included the previously analyzed intersections
and two new intersections at Byron Street. 6 The results are consistent with the original TIA. As
a result, no mitigation is necessary based on either the original TIA or the supplemental analysis.
Pursuant to BMC 19.06,7 the Project will pay the City's TIFs. Generally, TIFs ensure
that new development and redevelopment contributes it fair share for the cost of new
transportation infrastructure that is deemed necessary and reasonably related to acconm1odating
the impact of new development within the Bellingham city limits. By paying the required TIFs,
the Project will pay its fair share of the cost of new transportation infrastructure.
Ambling and the City agreed to use 164 units in a mid-rise apartment as the basis for the
traffic generation in the TIA. There is significant confusion regarding this. The City' s adopted
methodology for estimating the volume of vehicular traffic generated by a proposed development
reconunends using data from the Institute of Traffic Engineers (the "ITE") Trip Generation
Manual (the " ITE Manual"). The ITE publishes traffic generation data for a variety of specific
land uses nationwide.8 The ITE Manual does not have a specific land use for purpose built
student housing. As such, the City and Ambling utilized a comparable land use. They agreed on
utilizing the mid-rise apartment land use category (ITE LU #223). This was determined to be
conservative but reasonable to use due to the following factors: 9
•
•
•
5
Each WWU student pays for and possesses a bus pass as part of tuition.
Peak student conmrnte periods are not during the PM peak hour (busiest period when
traffic impacts are evaluated).
The WWU Park & Ride is located very close to the Project.
The City Council established LOS E as the minimum level of service for all intersections in the City. Like the
Comp. Plan (and even as part ofa Comp. Plan update), this was done in a public process.
6
Please fmd the supplemental traffic analysis, which is attached as Exhibit F.
7
RCW 82.02, et. seq. authorizes municipalities to impose TIFs for new development and redevelopment.
8
City Engineering Staff member Brent Baldwin discussed this at length at the bearing.
9
See Staff Report, Section III, Traffic for a greater discussion of these factors .
Belcher I Swanson
LAW FI RM, PLLC
September 30, 2013
Page 5
•
•
•
•
High level of on-site amenities allow for less travel.
Shuttle service is being provided, which will reduce the number of trips.
Parking on campus is more expensive than the rest of Bellingham.
WWU discourages students from bringing cars to school with them.
Ambling is going the extra mile to accommodate the traffic concerns and reduce the
amount of traffic to and from the site. It will provide a shuttle van for residents to and from the
WWU Park & Ride, Western Washington University, retail centers, grocery stores, and
downtown. This is mitigation in itself that will lessen the traffic load on nearby streets, which
was not accounted for in the TIA.
Statistics support Arnbling's asse1tion and the City's acceptance that the traffic from the
10
Project will not adversely affect the nearby streets.
•
•
•
•
•
•
WWU's own recent comprehensive study on types of transportation used by students that
attend WWU three or more times per week (full time) confirms that fewer than 25% of
all students drive alone, 7% car pool, and 69% of students either walk, bicycle or use
mass transit while travelling to and from WWU.
A 2011 publication by Associated Students of Western Washington University
("ASWWU") stated that while two-thirds of students had cars available for use, only 17
percent of full time students drove alone to school.
ASWWU also stated that parking capacity on campus is already maximized, and the
WWU web site states that parking on campus is very limited and parking applications are
closed well before the opening of the Fall Quarter.
On campus parking is expensive, and WWU discourages students from using cars.
There are only 2,031 student parking spaces on campus. All require a permit to park,
which allows only 13.5% of all students at WWU the possibility to pay quarterly for a
parking permit.
Parking passes sell out very quickly, and WWU has no plans to expand parking.
Public comments address traffic safety. On-street parking, narrow streets, and speeders
were mentioned as problems on nearby streets. Ambling understands these concerns, but these
11
are pre-existing conditions that are out of Ambling's control. Moreover, these comments are
pure speculation, and there is no evidence in the record that demonstrates that any of these
12
conditions will be exacerbated by the Project.
The Project will provide 432 parking stalls. This is substantially more than required by
the BMC, but the BMC does not contemplate this exact use. As a result, Ambling proposed this
10
Sources for these facts are attached as Exhibits G, H, 1, and J.
There are other means to solve these problems such as more police presence for speeders and engaging the City
Council on transportation project improvements in the vicinity.
12
Absent specific evidence in the record demonstrating that the Project will cause the nearby streets to fall below a
specific LOS adopted by the City Coun.cil, there is no basis in law to condition the Project.
11
Belcher I Swanson
LAW FIRM,
me
September 30, 2013
Page 6
extra parking because this amount is consistent with industry standards. Ambling has
tremendous experience in this industry. Historically, the ratio of beds to parking stalls in similar
developments nationwide (including Ambling's projects) is between 0.50 and 0.80. Here,
Ambling proposes a ratio of 0.75. This accommodates parking for residents and staff. 13
Ambling proposes to provide 88 covered bicycle parking stalls. The BMC requires 44.
If over time there is a demand for more, then Ambling will be able to provide them at that time.
Management and Marketing:
Ambling is not new to the purpose built student housing industry. 14 As Ambling testified
at the hearing, the Project will be subject to significant, 24-hour management. Ambling will hire
community assistants, who will live at the Project and be available for student support,
enforcement of community rules and policies, mentoring, and staffing the management office. A
published phone number will be available to speak directly with on-site management staff.
Ambling will endeavor to respond to callers within tlu·ee homs. Quiet hours are established and
enforced. Lease terms and on-site rules and regulations will strictly enforce conduct by the
residents. Background checks will be done on each prospective resident. Ambling will target
upper-class students (i.e. junior, senior, and graduate students). These measures are time-tested
and reliable ways to minimize problems at the Project. 15
Ambling expects that non-students will not be interested in residing at the Project.
Leases are for one year whether or not the student remains in the unit for the smnmer quarter.
All units are fully furnished. Personal guarantees from parents will be required on all leases.
Rentals are by the room, not the pod (or unit). Rates will be similar to those of on-campus
housing.
The result is a well-managed student housing complex, occupied by students, that
provides a safe student environment with the services required for students to succeed in college
while minimally disrupting the neighborhood.
Fair Housing:
The federal Fair Housing Act prohibits discrimination in the rental of housing based on
race, color, national origin, religion, sex, familial status or handicap. The State of Washington
13
Ambling just cannot seem to win when it comes to parking. Some neighbors say there is too much while other
say there is too little. Too much parking means the Project disturbs more native ground than necessary. Too little
parking causes other problems.
14
Ambling has 60 other developments like the Project in 20 states. See the Ambling's fact sheet, which is attached
as Exhibit K.
15
Much of the neighbor's concerns relate to the existing student population in the neighborhood. These are singlefamily residences converted to college rentals where more beds (and people) exist than were intended for the home.
Further, these are largely unsupervised houses where the owner is armmd vety infrequently or not at all. As to the
Project, these concerns purely speculative. The Project will create a very different situation, which is hardly
analogous to the situation presented by the neighbors.
Belcher I Swanson
LAW FIRM, PLLC
September 30, 2013
Page?
extends the prohibition on discrimination to the additional classes of marital status, sexual
orientation, and honorably discharged veteran or military status. 16
Students, or more particularly, non-students, are not a protected class under federal law or
under Washington law, and it is not discriminatory for a landlord to rent only to students.
Ambling has managed hundreds of properties, which have limited occupancy to matriculated
students at a particular college or university. With one exception, Ambling has never been
challenged under state or federal fair housing laws because they have limited residency at a
fac ility to students. The one exception occurred in New York in 20 l 2, when a non-student
attempted to rent a bedroom at a student housing facility and was denied because of his nonstudent status. This non-student subsequently :filed a discrimination complaint with the New
York Human Rights Conunission (the "Commission") and HUD, alleging discrimination based
on disability and age. The complaint was dismissed by the Conm1ission and subsequently by
HUD. In its opinion, the Commission stated that the complainant was not allowed to rent a
bedroom because of his non-student status, and not because of his age or disability. The
Commission noted that the prope1ty had in fact leased to older students as well as disabled
students.
There are other similar cases in which the courts have held that plaintiffs did not have
standing to bring claims under the Fair Housing Act because, as non-students, they failed to meet
a legitimate, non-discriminatory requirement for obtaining the desired housing. 17
It is not illegal to advertise and rent apartments or bedrooms specifically to students and
to deny non-students residency, so long as the student requirement is objectively applied to all
applicants.
Drainage:
The site has existed in its present condition for over 20 years since the developments
suITounding the site, including the residences below the site, were constructed. Other than the
public comments, no problems relating to drainage have been documented by any residents, and
the 18 inch diameter storm drain that was extended to the site has not been utilized. 18 The pipe is
still below ground at the lowest corner of the site. During this same 20 year period, residents
below the site have channeled runoff from the site through their lots into the public storm sewer
system, especially within Marionberry Comt. The Project will incorporate this 18 inch diameter
storm line into the final engineered drainage system. All affected owners will be invited to
participate in the design of the Project's drainage system as it concerns their specific property.
16
See RCW 49.60.222.
See Interfaith Housing Center of the Northern Suburbs v. Barry Bernsen; Barbara Bernsen; and Bernsen
Management. Inc., Case No. l l-Cv-01146; United States District Court for the No1thern District oflllinois, Eastern
Division, (2011); Wilson v. Glenwood Intennountain Properties. Inc., 98 F.3d 590 (C.A.10 (Utah), 1996).
18
This 18 inch pipe connects to existing City storm drainage infrastructure.
17
Belcher I Swanson
LAW FIRM,
me
September 30, 2013
Page 8
Ambling prepared a preliminary stormwater report, pursuant to the BMC. The City
accepted this repo1i. The report demonstrates that the site can accommodate a final storm
drainage system that meets or exceed all City and Washington State stormwater requirements
such that the runoff conditions following construction of the Project will not exceed the
predeveloped runoff conditions.
Specifically, the final storm drainage system will intercept drainage entering the site,
collect runoff from all impervious surfaces and convey it to an enclosed vault system installed
below parking areas. The vaults will have restricted outflow controls, which will distribute
drainage to a rain-garden feature where "enhanced" treatment will occur. Ultimate discharge
from the rain-garden to the public storm system within Nevada Street will be tlu:ough the
previously installed 18 inch storm drain. In addition to smface runoff, all ground water
encountered during the grading and foundation excavation will be intercepted and chaimeled into
the Project's final storm drainage system.
It is likely that the final storm drninage system will actually improve the presently
unregulated stormwater runoff. 19
Need for this Type of Housing:
Ambling has done its homework. It expects the Project to succeed because its market
analysis indicated there is a need for purpose built student housing in Bellinghan1. Several local
factors lead to that conclusion, as follows: 20
•
•
•
•
•
•
•
19
WWU is home to approximately 15,000 students.
There is approximately 4,000 beds available on-campus, which are 100% reserved each
fall quruier.
WWU overbooks the available beds each year to account for loss of students through
attrition during the school year. 21
WWU has approximately 2,700 to 2,800 incoming freshmen each year.
All incoming freshmen to the university are guaranteed availability of a dorm bed on
campus by WWU.22
92% to 94% of the each year's freslunan class (over 2,500 students) chose to live on
campus.
Bellingham has an apartment vacancy rate of 1.8%. A Bellingham managernent company
lhal currently manages 653 units in town recently confirmed a 0.46% vacancy rate for
their properties, and stated that figure means that they are viliually 100% occupied.
More importantly, there is nothing in this record conclusively stating that the drainage problems on which the
neighbors commented will increase as a result of the Project.
20
Sources for these facts are attached as Exhibits L, M, N, 0 , P, and Q.
21
The Director of University Residences informed Ambling of this at a meeting between Ambling and the Director.
22
See Footnote 21.
BelcherI Swanson
LAW FIRM, PLLC
September 30, 2013
Page9
•
There is presently no purpose built student housing in the City of Bellingham, and very
few, if any, fully furnished units.
These facts suggest that there is a need for purpose built student housing in Bellingham.
Every year over 2,500 students who may wish to remain living on campus must move off
campus to some other form of housing. Moreover, Ambling met with the Director of University
Residences at WWU, and Ambling made it clear that it will be marketing to the more mature
23
students. Ambling agrees that priority for younger students to live on campus is a great benefit
to the younger students and the university. However, as a result, older students must fend for
themselves to find accommodation anywhere it is available.
Neighboring Property Values:
Purpose built student housing is a relatively new phenomena. As a result, there are few
references to studies regarding their effect on neighboring property values. However, the
concerns raised by neighbors were strikingly similar to those raised by neighbors when
affordable housing was proposed in their neighborhood. Forttmately, there are numerous studies
on that subject. Please find two such studies, which are attached as Exhibits R and S. Each
study annom1ces that a well-managed development will not depress neighborhood property
values or otherwise tmdermine the communities.
Questions and Clarification:
There were several questions posed directly to Ambling. Many were answered in the
discussion, above. However, some were not. Below, Ambling addresses these additional
questions.
•
•
•
•
23
Public Testimony: One member of the public testified that the average grade of the site
was 22 degrees. This is incorrect. The average grade of the site is 22%. The distinction
is important because 22 degrees is much steeper than 22%. For reference, a 45 degree
grade is equivalent to a 100% grade.
Public Testimony: There were public comments about hot tubs and fire pits: These are
very popular amenities and are important in providing on-site activities. There were
concerns about noise and safety. The hot tubs and fire pits will be located away from
neighbors and screened by the clubhouse. The fire pits will be gas fired, which is the
same as all fire pits in public places throughout the northwest.
Public Testimony: There were comments about the single entry/exit. The site was
platted with a small connection to Nevada Street that assumed ingress and egress for
vehicles and utilities. Ambling and City Staff determined that it would not be appropriate
to use this for those pmposes. Ambling and City Staff also studied an access point to
Puget Street, but the grades proved too steep to make this a practical solution.
Public Question: What is the relative scale of the whole site cross-section?
Ambling will market mainly to juniors, seniors, and graduate students.
Belcher I Swanson
LAW FIRM,
me
September 30, 2013
Page 10
•
o Answer: I to 1. The horizontal and vertical scales are identical. Thus, neither the
vertical nor the horizontal scale is exaggerated.
Hearing Examiner Question: Are there other purpose built student housing projects in
Washington?
o Answer: Yes. As expected, these are located in Ellensberg, Pullman, and Cheney
near college campuses such as Central Washington University, Washington State
University, and Eastern Washington University, respectively. Student Housing
Business Magazine stated in a recent edition that two new purpose built student
housing projects are also underway in Seattle and Spokane.
Conclusion:
Thank you for your careful consideration of the Project. As discussed above, the Project
complies with all relevant codes. As such, Ambling requests that the Hearing Examiner approve
the Project with the conditions recommended by staff, as modified by Ambling herein.
Very truly yours,
BRADLEYD.
Attorney at Law
BDS:hc
Enc.
Cc:
Client
City of Bellingham Planning and Development Services
Ron Jepson and Associates
Humphreys & Partners Architects
Patrick MolTill
Transpo Group
EXHIBIT
''A'' .
EXHIBIT
''B''
PU GET
NEIGHBORHOOD
ZONING
AREA ZONING DESIGNATION*
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Industrial, Planned
Residential Multi, Planned
Residential Multi, Duplex
Residential Multi, Mixed/Multiple
Public, Recreation
Residential Single
Residential Single
Public, Open Space
Commercial, Planned
Public, School
Commercial, Planned
Residential Multi, Multiple
Residential Single
Commercial, Planned
Residential Multi, Planned
Residential Single
Residential Multi, Planned
Commercial, Planned
Residential Multi, Planned
Commercial, Planned
Commercial, Auto/Mixed
'SEE SEWN~ lolJNCPAl CODE TI1l.E 20
TABLE OF ZOHNCREGULATIOHS FOA
MODIACATIDNS INTHEUSTDF PERMITTED
USESAND OTHER SPEC"'t.PltOVISIONS
FOR EACH NUMBERED AREA
zI:>
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0
500
1000
1500
2000
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City of Bellingham
Planning Department
201 1
4'15l200Ktil
EXHIBIT - . ·
''C''
SA MISH
NEIGHBORHOOD
ZONING
AREA ZONING DESIGNATION*
1
2
2A
3
4
5
SA
6
7
8
9
Commercial, Auto
Commercial, Planned
Residential Multi, Planned
Residential Multi, Planned
Residential Single
Residential Single
Residential Single
Residential Single
Public, Open Space/
Park/Recreation
Residential Multi, Planned
Commercial, Planned
•SEE BEU,Jr.,I~ MUJ.ICIPAL CODE TlllE 20
TABLE OF ZONINGREGUlATJO>IS FOR
IM>OlFtCA.TIONS M THE UST OF PERMITTED
USESANDOTIER SPEC'"1.PAOVISIO«S
l'Olt EACH ...,MBERfDAAEA
u •.e-P..
7
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I
I
I
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0
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2000
3000
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City of Bellingham
Planning Department
2011
"11512011 ..N
· EXHIBIT
''D''
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90
80
70
60
*User Note: Setbacks, Heights and Overlay Areas have
been added for illustration by City of Bellingham Staff
50
40
30
20
410
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390
380
370
360
350
340
~
200' Height Restriction Overlay Area ~
330
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310
Q
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360- 7ll-S760 ru l60-6'7- S9l9 WWWJ !l'SOltCllCIH£!lllHG.COll
NOT FOR CONSTRUCTION
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