Pete Lorimer (Flickr)
Pete Lorimer (Flickr)

The following ST3 comment letter (PDF) was submitted by a coalition of 10 local progressive nonprofits. 

Dear Sound Transit Board Members,

Thank you for the opportunity to comment on the Sound Transit 3 (ST3) system plan and policies. The Transit Access Stakeholder group is a growing coalition of organizations that strongly supports connecting the Puget Sound region through affordable, reliable, and sustainable transit. Together, we represent environmental, land use, active transportation, social justice, affordable housing, and transit stakeholders, with thousands of members in the central Puget Sound region. We look forward to mobilizing our memberships in support of a Sound Transit 3 system plan that is consistent with the following framework:

Bring light rail to more neighborhoods sooner. Sound Transit should work with individual jurisdictions to find ways to shorten planning processes or identify more funding in order for more communities to have access to affordable, reliable, and sustainable transportation as soon as possible. Our coalition welcomes the opportunity to support you in these efforts.

Increase investments in local transit, walking and biking access to high capacity transit. Demonstrate regional leadership by providing funding to cities to build safe, inviting, and convenient access with appropriate wayfinding, lighting, safety, and other universal design standards within a half mile minimum walkshed of stations. Investments in local transit, walking, and biking access are an affordable, effective, and sustainable way to attract riders.

Focus parking investments on cost-effective, flexible, and priced solutions. We urge Sound Transit to conduct a comprehensive needs assessment for all planned parking facilities to ensure that investments are socially equitable, reflect demand, and accommodate changes in density that will occur around station areas as land use zoning and development changes over time. Parking should be priced, with revenues reinvested to improve connections for people travelling to that station on foot, bike, or transit.

Prioritize affordable housing in the use and disposal of land. By supporting and prioritizing affordable housing, Sound Transit can play a critical role in promoting equitable development in high opportunity transit-connected areas, stimulating infill and redevelopment, increasing ridership, and building much needed affordable homes in a region increasingly challenged by skyrocketing growth.

Maximize potential for equitable transit-oriented development (TOD) and increased density with supporting policies, projects, investments and alignments. Promoting a mix of jobs, services, and housing around transit stations and hubs is, therefore, critical to increasing ridership as well as to ensuring access to opportunity. Prioritizing equitable TOD provides opportunities to create communities that decreases reliance on travel by car by providing services and activities near transit, thereby reducing single occupancy vehicles and greenhouse gas emissions (GHG).

Improve community engagement and outcomes policies to include best practices for expanding and deepening engagement with low-income communities, people of color, immigrants and refugees earlier in and throughout the planning process. Designing an equitable transit system with optimal ridership is only possible if the region’s diverse communities have equal opportunities to participate in and influence the planning process.

The Transit Access Stakeholders look forward to mobilizing our members and supporters to vote in favor of a ST3 system plan and related policies that are consistent with our collective goals. We are the organizations that will be leading the charge to win public support for this measure in November. We were crucial in passing the Sound Transit 2 package, and we are committed to doing the same for ST3.

We propose the following specific changes to the ST3 package:  

  • Improve the timeline of deliverables
    • Make Graham Street Station an early win.
    • Work to deliver the high-ridership Ballard line sooner.
    • Change the following from future investment studies to environmental studies:
      • Ballard to University of Washington
      • West Seattle to Burien
    • Ensure funding for 130th St. Station in a way that doesn’t jeopardize Lynnwood Link, including creative partnerships with the FTA.
    • Accelerate funding for non-motorized system access improvements at existing and soon to be built stations, thereby creating early wins in communities already getting light rail.
  • Increase and improve investments in multimodal access
    • Ensure adequate planning for transit integration and sufficient funding to create seamless connections for riders connecting by bus.
    • Bring non-motorized investments up to $500 million by increasing the allocation to the system access fund, dedicating a portion of parking revenue, or by including specific bike and pedestrian investments in certain projects. For example, on the planned Ballard light rail bridge, bike and pedestrian access should be accommodated.
  • Work with advocates to develop and adopt a Non-Motorized Access Policy that:
    • Ensures planners include non-motorized access into station designs early in design.
    • Adopts design standards for walking, biking, and transit access to stations.
    • Commits to designing stations using principles of universal design, whereby all elements of a built environment should be usable to greatest extent possible by everyone, regardless of their age, ability, or circumstances.
    • Provides specific detail on how the new system access program funds will be prioritized and allocated.
  • Make smarter investments in parking
    • Adopt a resolution that:
      • Requires an access study to be conducted for stations with planned parking before any new parking is built.
      • Explores leased or shared parking before building new parking.
      • Prioritizes building parking as part of TOD, rather than freestanding structures.
      • Builds any freestanding parking so that it can be repurposed as TOD in the future.
      • Prices parking at new or ST-owned and operated stations with high utilization.
      • Enables ORCA as a parking payment method to ensure users are transit riders.
      • Allows ORCA LIFT users to pay reduced parking fees.
      • Reinvests parking revenue in station access improvements to make it safer for riders to walk, bike and take transit to the station.  
  • Decrease funding allocated for new parking, based on anticipated decrease in demand for priced parking and investments in multimodal access.
  • Allow parking investments in all projects to be revised to include a range of strategies for providing rider access to the station, along with or instead of parking.  
  • Clarify affordable housing policies to align with RCW 81.112.350
  • State Sound Transit’s intent to prioritize the construction of affordable housing on surplus property, including through:
    • Using creative strategies that reduce land costs for non-profit developers, land banking organizations and local jurisdictions building affordable housing.
    • Partnering with other public entities with expertise in affordable housing finance and land disposition in order to leverage their affordable housing investments.
    • Accelerating the timeline for property disposition.
    • Including affordable housing in all joint development agreements.
  • Adopt a resolution or policy principles committing to:
    • Minimizing or eliminating assumptions regarding revenue from property sales in annual ST budget processes.
    • Using creative strategies to discount the sale of most surplus property for affordable housing, including some of all of the following: including affordable housing requirements in land valuation and liquidating federal interest in land.
    • Ensuring that organizations with strong ties to local communities (when paired with development expertise) are able to effectively compete in the disposition/bidding process.
    • Updating disposition policies to reflect prioritization of affordable housing on ST surplus property.
  • Commit to improved TOD practices
    • Adopt a resolution or policy principles committing to:
      • Updating the TOD policy to promote better station area planning that facilitates mixed use development, affordable housing and better access.
      • Improve TOD planning to guide alignment decisions which promote best land use practices and facilitate housing in and adjacent to stations.
  • Create job quality standards for large commercial tenants at surplussed TOD sites and sites acquired through the revolving loan fund in order to promote family-supporting jobs.
  • Improve community engagement and outcomes policies and procedures
    • Initiate internal racial equity trainings for Sound Transit planning staff.
    • Invite community representatives alongside local governments to provide input during initial phases of alignment and station location decisions.
    • Continue to work with advocates and community groups to create a specific community engagement policy.
  • Ensure reliability for all neighborhoods by prioritizing grade separation in urban areas

Thank you for the opportunity to share these comments. This is a very important planning process, and we look forward to working with you to ensure the success of Sound Transit 3.


  • Shefali Ranganathan, Executive Director, Transportation Choices
  • Rebecca Saldaña, Executive Director, Puget Sound Sage
  • Rich Stolz, Executive Director, OneAmerica
  • Lisa Quinn, Executive Director, Feet First
  • Christopher Wierzbicki, Interim Executive Director, Futurewise
  • Elizabeth Kiker, Executive Director, Cascade Bicycle Club
  • Marty Kooistra, Executive Director, Housing Development Consortium
  • Tim Gould, Volunteer Chair Transportation & Land Use Committee, Sierra Club
  • Gene Duvernoy, President and CEO, Forterra
  • Keith Kyle, Board President, Seattle Subway

26 Replies to “Progressive Nonprofit Coalition Submits ST3 Comments”

  1. Somebody needs to change the headline of this article. This letter was signed by representatives from ten different organizations, not just TCC.

    1. Yes, and there was an awful lot of effort put in by many people to come up with that letter, the majority of whom do not work for TCC.

      1. Thanks.

        At first glance I was thinking “Everyone truly does have a say in ST3 if the Toronto Transit Commission decided to weigh in.”

    2. TCC is by name and Bylaws is a consortium of organizations with a common goal of reducing our dependance on SOV’s. The first name we came up with was Alt-Trans, but that evolved into TCC.

      1. Maybe, but I know for a fact that many of the organizations on that list are NOT part of any sort of any TCC consortium.

      2. You know, you’re right! I re-read the letter and TCC is but one entity to sign it. I further went to their website to find current members to be transit agencies, transportation related business’, and foundations. I should have done my research before popping off.
        Time for this old dinosaur to sign off.

      3. mic;

        Happy to hear you’re a part of TCC. Gave ’em $30 yesterday as part of #GiveBig.

        Was going to give something to Institute of Flight & Museum of Flight equally but thought… you know those two got big money behind ’em. TCC, not so much. ST3 is a means to getting quality transit to the Future of Flight campus anyway.

        Seattle Transit Blog wasn’t part of #GiveBig, sadly. I really want #ST3 to pass. Because if it doesn’t the next version will be all BRT in 2020 if that. Oh and there will be a pause in high capacity regional transit development…

  2. May want to re-think all the community input for how ST3 should be built out. ST3 is now a sub-optimal solution with many neighborhoods all wanting something for themselves with no regards to how effective their ideas are. Do we really want a major light rail system designed and approved by all these different mayors, committees, councils, boards, neighborhoods, whoever speaks up the loudest? Sound Transit has made compromise after compromise every step of the way. We now have different parts of the region and neighborhoods in panic mode wanting a light rail station in their back yard, not caring a crap about other areas. No one would ever map out a light rail system in the greater Seattle area and have stations and routes in the spots Sound Transit has done or is planning on doing. Why spend billions of dollars and wait decades to get a bad product. ST3 is in serious trouble of not passing, then what happens? Sound Transit is a joke. Need to drastically shorten the timeline for completion and have routes and stations where people want to go. Not everyone wants to or needs to go Husky Stadium, downtown, or Paine Field. Access from neighborhoods where people live to other parts of the city would be a good start.

    1. Here’s a look back to a similar letter from many of those same organizations from nearly 20 years ago to the day.
      I found it fascinating to look in the rear view mirror when Sound Move was ramping up for it’s November election, and we cautioned that a bad plan was worse than no plan at all.
      Some things came true, others, like the tunnel risks did not, and many of the letters concerns for our regions investments and fundamental changes to SOV’s and VMT’s have yet to be realized.
      Global warming, CO2, sea level rise, prosperity and growth in the Puget Sound were not household terms. Transit funding as a percentage of total transportation spending was wishful thinking to be at 50%. I think we’re there now.
      Anyway, it’s a good read from 20 years ago.

      1. Wow, great find, mic. While I disagree with some of the ideas — a tunnel under Capitol Hill was of course the best thing ST ever did (although the lack of stations make it way less cost effective) — it is amazing how much it applies now.:

        3) The Plan is based on a parochial definition of equity that undermines its usefulness.

        4) The RTA’s plan appears to be the product of regional deal-making and efforts to buy the support of powerful special interests, rather than a strategic effort to resolve the region’s transportation dilemmas as efficiently as possible.

        … its consumption of economic and political capital forestalls the pursuit of other, more effective efforts — possibly for decades.

      2. The Capitol Hill/U-District tunnel was my highest priority for Link, with stations near Broadway-John-Pine and University Way-45th-43rd. So I would have disagreed with that item (and I didn’t heard about the letter or coalition at the time). I’m so happy ST built the tunnel that it dampens my concern about Federal Way, Tacoma, Everett, etc. And now UW Station has opened and its ridership immediately exceeded expectations, even though bus transfers set a new level of badness.

        #3 and 4 are certainly still accurate. What we really needed was an initial comprehensive plan, with phases for all the extensions, and integrated plans for joint plan for feeder and local transit like Metro finally released this year. But in order to get that in the 1990s, we would have needed somebody to articulate the vision and a coalition to demand it, and there was none. So the responsibility for not doing that belongs to the then-coalition and transit fans as well as to Sound Transit and the politicians. Everyone was inexperienced, including those who had lived in transit-rich areas.

        Changing #4 in ST3 is very late in the day. The balance of interests and deals has been established for twenty years now. They’ve achieved a level of consensus between the cities, counties, voters, legislature, businesses, and NGOs to build some commonly-supported projects and some tit-for-tat projects. If you try to fundamentally restructure ST3, the consensus will fall apart. Then we have to go to the legislature in a tax-hostile, urban-hostile environment to ask for equivalent tax authority for the cities and counties, or a federated Sound Transit where each subarea is a separate tax district and ST merely provides planning/coordination/construction/operation services for the districts. It’s also only seven months till the election, of four months before the ballot measure mist be finalized. So there isn’t enough time to fundamentally change ST or ST3 right now. The only way forward is incremental improvements. If ST3 fails and a followup looks equally unlikely or a worse system plan, then we’ll have to fall back to plan Bs. But at this point blowing ST3 away or insisting on a fundamental restructure now sounds like a bad tactic. (Although the number of transit fans who have turned against it is unprecedented, not just the three you’re probably thinking of but another I spoke with yesterday who said basically the same thing, which surprised me.)

      3. The opposition to U-District station may have been when the alternative east of 15th (Burke Museum parking lot) was alive. That would have put 15th between the station and the University Way pedestrian area. It would be physically walkable but with a car-dominated landscape (like the path between the Federal Way transit center and the Commons mall, although not as bad). That may have been what the coalition was hesitant about.

      4. I think the only station with good bus/rail transfer opportunities is Capitol Hill and the tunnel stations downtown. All the rest of them are either not directly connected, as with mt baker, are dark and relatively rider unfriendly due to conditions (tibs) or in the case with sea-tac you have an incredibly wide and busy road separating the platforms. UW is just a long hike. The legacy of the mentality of early ST 1 planning Lives on.

      5. I agree, Mike — good comment. There was no organized alternative, and that is a problem. But that doesn’t mean that you can’t hire a firm to find one. What gets me is that folks assume they know transit well, when they don’t. The spine is a silly idea, and just about any transit expert would tell you so. But the folks in charge keep pushing for it, and ignore opinions that question that, along with other assumptions. For example, the NE 130th station is still in doubt because it wasn’t part of the original plan, or the grant proposal. But why? It is pretty obvious when you look at a map. Again, just about any outside agency would tell you that you really should add that station, as it will improve transit quite a bit.

        It seems to me that for something so big as this (and this is huge) we should hire several agencies, have them come up with several alternatives, explain why they think their approach is the most cost effective, and go from there. ST3 is nothing like that. Whether it be the infatuation with the spine, or thinking that West Seattle rail is due (or even appropriate) or — my favorite — the ridiculous concept of Issaquah to Bellevue rail, they have completely ignored what would be a logical approach.

    2. Well said, Chuck. What is amazing are the projects that weren’t seriously considered. The Metro 8 line is still not going to be studied, let alone funded. For Seattle, this set of projects (or even just a subset) would of course provide much more mobility for the region that what is in ST3: For the East Side, Kirkland’s Gold Level BRT plan ( would have been extremely cost effective, and provided exactly the type of network you are talking about. Similar improvements up north and down south (similar to Swift) would be way more beneficial than extending the spine.

  3. “we represent environmental, land use, active transportation, social justice, affordable housing, and transit stakeholders,”

    What does “active transportation” mean? Is that human-powered movement? Does it include taking a bus/train?

    “Ensure funding for 130th St. Station in a way that doesn’t jeopardize Lynnwood Link, including creative partnerships with the FTA.”

    Maybe ST could simply ask the FTA how it could make this improvement without stepping on the terms of the grant. The FTA must have a list of ways, or be easily able to compile one. It’s not the first city or the last that this will come up in. The fact that the FTA awarded the grant and doubled it means they see the overall extension as strong and want it to succeed. And all projects have a range of better and worse design features in them. So it’s not surprising at all that this project has one worst feature that the community wants to rectify now. That shouldn’t blow away the entire extension, as if there’s nothing important in the rest of it. The FTA must want the extension to succeed, and ST wants it to succeed, so why can’t they get together and identify some ways that both the extension and 130th-by-2023 can succeed. The answers may or may not be something ST can afford by 2023, especially with all the other North King projects in ST3, and the political support West Seattle has that means it can’t be downgraded. But at least make a list of ways, whether by 2023 or not, and publish that. That would give transparency for ST and the public to choose one of the ways. And that could be a strategy stakeholders could push for.

    “We urge Sound Transit to conduct a comprehensive needs assessment for all planned parking facilities to … accommodate changes in density that will occur around station areas as land use zoning and development changes over time.”

    Another factor is how the garage itself displaces TOD, walk-up riders, people walking from the station to area businesses, etc. This is a kind of environmental impact, and should be addressed as such.

    Another issue is that, while it’s great that ST acknowledges a long-term future in which the P&Rs are converted to TOD either fully or partially, nobody has looked how that transition would occur. If the demand for non-driving access increases and driving becomes less popular, there will be a period of transition where it could go either way. The urbanists will be pressing for conversion, and the decentralists and NIMBYs will be pushing to keep the P&R as-is. How will we push the conversion through in that situation? It’s not something we can do now but it will be a medium-term issue. Are there any national precedents we can look at? Or how should we get ST to approach this, and what does that imply for the “needs assessment” above, and for ST3’s general P&R planning?

    1. I’m not sure it would be easy or practical to convert a parking structure to TOD. Demolish and rebuild perhaps, but conversion is doubtful. Furthermore, in the suburbs I have a hard time seeing a mass exodus from suburban to urban living. Alternative fueled vehicles (cng, electric, etc) I see happening in the next ten years, but a mass exodus for urban living – no.

      1. I don’t know, having lived in post-WWII-construction apartment complexes back east, I might prefer a high-density-living building with a parking garage skeleton. A little work on the facade, maybe, but they would be a whole lot more solid than most of today’s stick-frame boxes.

        Except maybe for the apartments on the ramp portions

    2. That’s what I mean by conversion: demolishing the parking structure. Retrofitting it would lead to inconvenient ugly spaces.

      The suburbs are already densifying their downtowns and urban centers to comply with the Growth Management Act and avoid a fight with their single-family residents. That will lead to a higher percentage of urban residents who will demand good corridor transit, even if most of them have cars. That’s even if the single-family residents do nothing. But over several decades and generations, some of the single-family residents might change their attitude and want a more walkable area and less car-dependency even if they have to live in a denser area in order to get it. If the urban villages are full by then, the cities will have to convert single-family areas to more urban villages. At any of these stages, the total number of cars at stations might go down, and the demand for non-SOV access to stations might go up, along with the demand for multifamily housing at stations. That’s when it would be possible to convert a P&R to TOD, or even half a P&R to TOD.

      1. There are a lot of opportunities yes, I just don’t know if some of these cities will take advantage of them. it seems the eastern pierce county cities are more concerned about keeping their small town feeling rather than any kind of density. They don’t care what happens outside their city limits as long as they can get the sales tax from the businesses (strip development) they annex in and the commuters stay out.

      2. I was mainly thinking about the Eastside, south King County, and southwest Snohomish County. I don’t know much about east Pierce County. In the cities’ letters to ST last year, it’s interesting that the largest cities talked about their urban centers and growth while tiny towns like Pacific said they want to keep their single-family character and don’t want changes. It may be that Sumner, Puyallup, Bonney Lake, Orting, etc want to remain small towns. I’m not sure it’s necessary for them to change; I’m more concerned about density in the larger cities and their immediately-surrounding neighbors. But remaining small towns goes hand in hand with not getting better transit. Sumner and Puyallup are lucky that way because they’re on Sounder’s way to Tacoma: we can’t increase it to Tacoma and Lakewood without also increasing it for them. But other towns like Bonney Lake and Orting may have to temper their expectations. As for Spanway, I haven’t been there since the 80s so I imagine it’s a sprawl horror show now, with no edges that can be called a small town.

  4. Sounds great for Seattle. Just not everywhere else. I agree with user fees for park and ride lots, I agree with some of the TOD and access, however seattles solutions don’t work everywhere, especially if the communities do not want higher density projects rammed down their throats, but just want a parking garage. Also, I question how practical it would be to conver a parking garage into TOD to begin with.

  5. “Demonstrate regional leadership by providing funding to cities….”

    Not a chance. I don’t want to see light rail money syphoned off for goodies that cities should be delivering. Seattle just raised $900 Million in new taxes, a lot of which is for this sort of access stuff. Other cities should step up and follow that example. The ST Board’s leadership should be focused on completing the mass transit system and spending as far as regional funding will allow.

    There is $100 million in there for access stuff. They should cut that and use it to add the 130th St station.

  6. Graham Street to be an early win as the first change to the plan! I like it. Point for the little guys. I love the Ballard Line and 130th St station, but not enough people are advocating for this station to get done sooner.

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