May 25, 2010

Covington Planning Commission

City of Covington
16720 SE 271st Street
Suite 100
Covington, WA 98042

RE: Proposed Land Use Code Changes

Thank you for the opportunity to submit this letter. CollinsWoerman is the architecture firm
recently engaged by MultiCare for the purposes of helping them expand the services offered
on their Covington campus. To that end, we have reviewed your proposed new land use code
and offer the following observations, comments and suggestions.

Permitted Uses
The MultiCare Covington campus was purchased and developed by the institution for the
purpose of serving the community with a range of Healthcare services. For nearly twenty
years, they have operated this campus for that purpose and they are now executing a 100 year
building expansion of the site, expanding the scope of services available to the community
dramatically.

Under current zoning, the existing and proposed uses would be permitted outright. Under the
new zoning these uses are conditional. This seems an unintended consequence of the new
code.

In many jurisdictions, Healthcare institutions have a designated zone or overlay. Seattle and
Bellevue come immediately to mind. We strongly encourage you to review the applicability of
applying generalized zone use criteria to sites such as MultiCare’s which have a historical
specific use and provide great benefit to the community.

Height Limits in the MC zone

Under the current zoning ordinance the height limit for the MultiCare property is four stories or
60’. Under the proposed zoning the new height limit is proposed to be 55’. The existing
building on the Covington campus is four stories. We believe the proposed new code height
limit will hurt the potential to develop a hospital facility on the site. We would expect the height
of a new building will be four stories; two Diagnostic and Treatment floors and two Patient
Bedroom floors. Our experience suggests that D and T floors will have a floor to floor height of
16’ to 18’. Patient room floors are generally at least 14’ high. Using the most conservative
numbers, a four story hospital facility on the site would be 60’ high to top of roof.

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Covington Planning Commission
May 25, 2010
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We would propose that you consider a 65’ height limit on the MultiCare campus, or 65’ for
intended medical uses within the City of Covington. We believe this height limit will never
create an additional story for an inpatient hospital facility although it may allow a medical office
building to develop five levels within 65’. Similar to your current code, you could describe both
height and story limits if that served an intended purpose for which we are not yet familiar.

Development Standards
A final observation with respect to your proposed code is that it appears to be written for new
developments, not for expansions of existing development. An example of this is the new
standards for development along street frontages by type. MultiCare’s campus fronts Wax
Road, a type 2 street in Covington’s definition. By standard, 50% of the frontage along Wax
Road is to be building with parking behind the facility. MultiCare’s campus has 1800’ of
frontage requiring a 900’ long building eliminating the existing parking. To achieve a building
that length would almost certainly demand a single story solution which will immediately
challenge lot coverage and impervious surface regulations.

Again thank you for the opportunity to present this letter. We admire the goals and intent of
your proposed land use code changes and agree with the ambitious effort in large measure.
We have written this letter from the perspective of operationalizing the code and raising issues
related to what we believe are unintended consequences. Thank you for your consideration.

Sincerely,

Phil Giuntoli
Principal

cc: Hugh Kodama, Administrator – MultiCare Covington Medical Center

Kristopher Kitz, Director – Strategic Planning & Business Development
Tyler Paytas, Project Manager – CB Richard Ellis/MultiCare Health System

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