Pierce County

Office of the County Council Derek M. Young

Councilmember, District No 7
930 Tacoma Avenue South, Room 1046
Tacoma, Washington 98402-2176
(253) 798-6654
FAX (253) 798-7509
1-800-992-2456
E-mail: derek.young@piercecountyway.gov
www.piercecountywa.org/council

April 29th, 2019

Mr. Josh Brown

Executive Director
Puget Sound Regional Council
1011 Western Avenue, Suite 500
Seattle, WA 98104-1035

Re: Vision 2050 DSEIS Comments

Dear Mr. Brown:

Thank you for the opportunity to comment on the Vision 2050 Supplemental Environmental Impact
Statement (SEIS). I want to make clear from the outset that unlike my role representing Pierce County
on the Growth Management Policy Board (GMPB), I am commenting here on behalf of only myself.

I would also like to thank the excellent work by Puget Sound Regional Council (PSRC) staff preparing
the SEIS and working with the GMPB throughout this process.

Preferred Alternative
Staff’s analysis makes clear that the Transit Focused Growth Alternative aligns with our stated
objectives in favor of protecting rural working and wildlands, Puget Sound recovery, building healthy
and sustainable communities, while decreasing greenhouse gas emissions and commute times.

That said, I agree with the comments made by the Council Chair and Executive on behalf of Pierce
County that there is concern about this alternative’s consistency with what we know about vested
development rights and buildable lots in the rural and unincorporated urban growth area.

If we treat those targets on the upper bound as guidance rather than a rule that could result in
compliance problems for our comprehensive plan, there should be no issue. However, we can reduce
market demand being pushed to outlying areas by setting firm minimum density requirements around
High Capacity Transit (HCT).

Jobs-Housing Balance
I do appreciate the extra attention paid by staff and the GMPB to the issue of Jobs-Housing Balance.
Though Vision 2040 anticipated a multipolar economic development model with jobs and housing
growth throughout the region, I would expect everyone can agree that we’ve failed to deliver on that
promise.
The jobs-housing index utilized by staff (see Figure 4.1-1) shows each alternative anticipates
imbalance throughout the region. This appears to be due to staff accepting growth forecasts from the
State’s Office of Financial Management. I believe this is backwards. Our plan for where to distribute
that growth in the region is a matter of policy. We should have a Transit Focused Growth (B)
alternative that starts with an index of 1.0 in each subarea, and work backwards from there.

While the market will gravitate to demand, housing prices are a tool we can use to show where it is
constrained by land use policy. Right now it’s signaling very strongly that there is unmet demand for
housing in areas that have experienced the most significant amount of job growth, specifically in “Sea-
Shore” and “East King” subareas. This constraint displaces those unable to compete with higher
salaries and are forced to commute ever further away into parts of the region that have benefitted least
from the economic growth experienced in King County. Our regional plan should counter, rather than
exacerbate this inequity including consideration of policies that promote job creation outside the
subareas with the highest jobs-housing index to help address the existing imbalance.

Further, if those housing demands are not addressed, and the jobs-housing imbalance accepted and
even anticipated within Vision 2050, then our regional growth strategy is internally inconsistent with
the goals stated within the plan. Without jobs-housing balance throughout the region we will
encourage more growth away from transportation infrastructure and into smaller communities and
rural areas increasing CO2 emissions, stormwater pollution, reducing habitat and open space, while
displacing lower-income people least prepared to handle additional transportation costs.

It’s difficult to think of a major social problem we have in our region unrelated to the concentration of
employment and wealth in jurisdictions unwilling to allow for enough housing to accommodate that
economic growth. Increased homelessness, transportation costs, impacts to health, and even time spent
away from communities and families are all harmed by the jobs-housing imbalance.

We need to think about housing the same way we do roads and transit — as infrastructure for jobs.
We must establish a standard ensuring that each county plan for enough housing to accommodate job
growth projections, otherwise I don’t understand the purpose of having a regional growth strategy or
multicounty planning policies at all. It's the most important reason for doing the work. I would further
recommend that we consider using the subregions identified in the jobs-housing balance section.

Unincorporated geographies

I appreciate the attempt to develop some nuance within the unincorporated area by allowing for
designation as High Capacity Transit Communities. However, this still leaves ambiguity for the
remain areas. Allowing for designation by community planning area, similar to our cities, would be a
more logical way to differentiate unincorporated areas from each other.

For example, the UGA surrounding the City of Gig Harbor and planned for annexation there is
generally similar in development pattern and zoning to the City as a small outlying community
surrounded by rural area. Meanwhile, South Hill, adjacent to and similar in zoning and development to
Puyallup designated as a Core City, would have the same geography assigned to it as the Gig Harbor
UGA.

Health Impact Assessment

As we’ve become more aware of the public health benefits of smart planning policies, it's essential to
include a Health Impact Assessment in our environmental analysis. HIA’s are recommended as
potential mitigation within the draft SEIS (see Table 4.9-1). This request probably should have been
made during EIS scoping, but since this is an EIS for a public plan rather than a private development, I
thought it was worth making. I’m sure our public health departments could assist PSRC staff in
developing an HIA.

Conclusion

Thank you again for the opportunity to comment. Based on discussions at the GMPB I think we’ve all
recognized, to one degree or another, the issues and concerns I’ve tried to address here. I hope these
comments help move the process forward in a productive manner and, as always, I’m available to
discuss them in greater detail at any time.

Sincerely,

Derek Young
Pierce County Councilmember