HomeMy WebLinkAboutFebus Ltr - quadrant corp reply to City's response Denis Law Mayor
City Clerk-Jason A.Seth,CMC
January 22, 2019
Jeremy Febus
KPFF
1601 5th Avenue, 1600
Seattle, WA 98101
Subject: Quadrant Corporation's Reply to the City's Response to Motion for
Reconsideration
RE: Solera Master Plan, Preliminary Plat, Conditional Use and Street
Modification (LUA-18-000490)
Dear Mr. Febus:
Enclosed please find Quadrant Corporation's Reply to the city's Response to Motion for
Reconsideration, Declaration of Kerry L. Nicholson, Declaration of Bonnie Geers, and
Declaration of Service dated January 18, 2019.
If you have any questions, please contact me at (425) 430-6510 or jseth@rentonwa.gov.
Sincerely,
Jason S. Seth, CMC
City Clerk
cc: Hearing Examiner
Matthew Herrera,Senior Planner
Jennifer Henning, Planning Director
Brianne Bannwarth, Development Engineering Manager
Craig Burnell, Building Official
Kyle Wunderlin, Planning Technician
Julia Medzegian,City Council Liaison
Parties of Record (8)
1055 South Grady Way,Renton,WA 98057 • (425)430-6510/Fax (425)430-6516 • rentonwa.gov
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BEFORE THE HEARING EXAMINER
9 FOR THE CITY OF RENTON
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11 In the Matter of: LUA-18-000490, SA-M, PP, CU-H, MOD
12 SOLERA MASTER PLAN, QUADRANT CORPORATION'S REPLY
TO THE CITY'S RESPONSE TO MOTION
13 A Master Plan, Preliminary Plat, Conditional FOR RECONSIDERATION
14 Use and Street Modification Decision
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Quadrant is proposing a phased, mixed-use project in the Sunset Highlands area of the
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City of Renton abutting NE Sunset Blvd("Project"). City Code requires that any residential
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19 proposal along NE Sunset Blvd. include a ground floor commercial component. Accordingly,
20 Quadrant's proposal,which was approved by the Hearing Examiner,proposes 39,000 sq. ft. of
21 commercial space. Quadrant is committed to the success of the Project, including its commercial
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component.
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Based on recent experiences with other developers, the City is concerned that Quadrant
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25 will construct the townhomes only, and that the mixed-use components will be abandoned. In
26 order to address this (hypothetical) concern, the City has proposed a phasing condition,
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McCullough Hill Leary. PS
701 Fifth Avenue,Suite 6600
QUADRANT'S REPLY TO RESPONSE TO Seattle,Washington 98104
MOTION FOR RECONSIDERATION—I of 7 206.812.3388
206.812.3389 fax
t Condition#18,that seeks to force construction of the mixed-use concrete podium before
2 Quadrant can initiate construction of the townhomes.
3 Rather than ensuring success of the Project, Condition#18 will jeopardize it. If
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townhome construction is held hostage pending construction and inspection of the mixed-use
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podium (both of which are largely outside Quadrant's control), the impact will be increased
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7 costs, decreased construction efficiencies, and less incentive for potential mixed-use partners.
8 The City is attempting to force construction timelines that the market should dictate. This
9 attempt is unlawful and exceeds the City's authority. Ultimately, the parties agree that the mixed-
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use component of the project must, and will, be constructed. The issue is timing. A condition
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requiring Quadrant to delay townhome construction until certain arbitrary milestones are
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13 achieved is not in the best interests of the City or the developers. Quadrant's proposed revisions
14 to Condition#18 are sufficient to ensure construction of the mixed-use component of the Project.
15 I. ARGUMENT
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The City's argument in response to Quadrant's Motion for Reconsideration is as follows:
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(1)the Project is required to have a mixed-use component; (2)the City is concerned that
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19 Quadrant will construct only the townhome component and abandon the rest; (3)delaying
20 townhome construction until the mixed-use podium is completed is the only way to provide
21 assurances that the mixed-use element will be built(the City's ability to withhold occupancy
22 permits is somehow insufficient); and (4)the City has proposed two viable "alternatives" to the
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podium construction requirement: the ability to provide a letter of credit or cash set aside for the
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entire cost of the building($75 - $90 million dollars), or the ability to negotiate a future,
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26 unspecified arrangement with the City when a mixed-use partner is identified.
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McCullough Hill Leary.PS
701 Fifth Avenue,Suite 6600
QUADRANT'S REPLY TO RESPONSE TO Seattle,Washington 98104
MOTION FOR RECONSIDERATION—2 of 7 206.812.3388
206.812.3389 fax
Quadrant agrees with the City on only one of these points:the Project is required to have
2 a mixed-use component. Quadrant disputes the remainder of the City's arguments.
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A. Condition #18 is based on a hypothetical future impact, not a specific identified
4 impact, as required by law.
5 The City has repeatedly stated that"there is a risk"that Quadrant will not secure a mixed-
6 use development partner, which "could result" in a block of townhomes completed with no work
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initiated on the mixed-use blocks. City's Response to Motion for Reconsideration, p. 2. The City
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has taken it upon itself to address this hypothetical concern by imposing arbitrary and onerous
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10 requirements designed to delay townhome construction.
t t The City reasons: "It is the City's duty to ensure that the master plan is constructed with a
12 reasonable guarantee that the mixed-use portion is constructed and complete as Phase I and if
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there are financial constraints on the project it is the ancillary and subordinate components
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(townhome blocks)that should be sacrificed." City's Response,p. 2 (emphasis added). This
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16 rationale is extremely troubling. This City does not get to decide, based on future hypothetical
17 concerns, which parts of a project to "sacrifice" if market conditions are challenging. Rather, the
18 developers who have invested millions of dollars into these projects get to make those calls. The
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City is overreaching here; the issue is not whether the mixed-use component of the Project will
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be constructed (it will); the issue is whether the City gets to dictate construction timelines based
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on arbitrary milestones—when no specific Project impact has been identified.
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23 Development conditions must be based on specific, identified development impacts. Isla
24 Verde Intl Holdings v. City of Camas, 146 Wn.2d 740, 759,49 P.3d 867 (2002); Citizens'
25 Alliance for Prop. Rights v. Sims, 145 Wn. App. 649, 665, 187 P.3d 786 (2008). Here, the City is
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still unable to point to a specific development impact that justifies the imposition of Condition
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McCullough Hill Leary. PS
701 Fifth Avenue,Suite 6600
QUADRANT'S REPLY TO RESPONSE TO Seattle,Washington 98104
MOTION FOR RECONSIDERATION—3 of 7 206.812.3388
206.812.3389 fax
1 #18. The best it can do is point to a future hypothetical "risk" that the mixed-use components of
2 the project will be abandoned. This is not legally sufficient.
Condition#18 is not based on an identified Project impact;therefore, it lacks a nexus to
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the Project. Benchmark Land Company v. City of Battle Ground, 146 Wn.2d 685, 49 P.3d 860
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(2002) (Washington Supreme Court held that project conditions cannot be imposed without a
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7 showing that they are reasonably related to a development's impacts). Again,the burden is on
8 the municipality to establish that development conditions are tied to a specific, identified
9 development impact. That burden has not been met here.
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B. The mixed-use podium construction requirement is arbitrary,excessively
tt burdensome, and unnecessary to address the"impact" identified by the City.
12 The City claims that its proposed Condition#18 is the only possible mechanism to ensure
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construction of the mixed-use building. That is not the case. No one disputes that the Project is
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required to have a mixed-use component. Quadrant has repeatedly acknowledged the mixed-use
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16 requirement, which is required by the Decision approving the Project. The City has a variety of
17 tools in its toolbox to ensure compliance with that requirement.
18 The City offers no rationale for identifying the "construction of the mixed-use podium"
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as the point of no return for a commercial developer. The podium is admittedly an expensive,
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lengthy, and complicated piece of construction, but from a mixed-use developer's perspective,
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22 development is assured when property is acquired, fees are paid, and building permits are
23 obtained. Kerry Nicholson, Senior Managing Director of Legacy Partners, a privately-held real
24 estate firm that owns, develops, and manages multi-family communities across the country, sees
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no rationale for tying townhome construction to podium construction in this case. Rather, Mr.
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Nicholson believes, based on his 40-years of experience in real estate development and
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28 financing,that property acquisition, impact fee payment, and building permit issuance constitute
McCullough Hill Leary. PS
701 Fifth Avenue,Suite 6600
QUADRANT'S REPLY TO RESPONSE TO Seattle,Washington 98104
MOTION FOR RECONSIDERATION—4 of 7 206.812.3388
206.812.3389 fax
1 the reasonable"point of no return" for mixed-use developers. See attached Declaration of Kerry
2 Nicholson. Construction of the mixed-use podium offers no additional assurances to the City; it
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simply creates an arbitrary obstacle preventing Quadrant from initiating construction of the
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townhomes, consistent with its construction schedule and market forces.
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Project conditions must be based on identified impacts, and they must be proportionate to
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7 those impacts in order to be lawful. Agency action is arbitrary and capricious if it is "willful and
8 unreasoning and taken without regard to the attending facts and circumstances." Washington
9 Indep. Tel. Ass'n v. Washington Utils. & Transp. Comm'n, 148 Wn.2d 887, 905-06, 64 P.3d 606
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(2003) (citations omitted). Condition#18 does not meet these tests. This requirement lacks
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proportionality to the hypothetical "impact"the City is trying to address.
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13 C. Neither of the "alternatives" identified by the City are viable.
14 The City claims that its Motion for Reconsideration provides "three options for
15 Compliance that are reasonable to ensure compliance with the phasing plan." Motion at 3. That
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is not the case.
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As explained previously, a requirement that the mixed-use podium be completed and
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19 inspected before townhome construction can begin is not reasonable. It is excessive, arbitrary
20 and unlawful.
21 Alternatively,the City has offered that a developer could complete shoring walls and
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foundation excavation—in addition to providing a"cash set aside, letter of credit or an
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assignment of funds approved by the city for the entire cost of the mixed-use building."Decision,
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25 pg. 32. This is not a viable alternative. No mixed-use developer would set aside such an
26 exorbitant sum of money while simultaneously trying to expend funds on actual construction.
27 Declaration of Bonnie Geers; Declaration of Kerry Nicholson.
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McCullough Hill Leary. PS
701 Fifth Avenue,Suite 6600
QUADRANT'S REPLY TO RESPONSE TO Seattle,Washington 98104
MOTION FOR RECONSIDERATION—5 of 7 206.812.3388
206.812.3389 fax
1 A third alternative offered in the City's Motion is an as-yet-to-be-determined option to be
2 approved by the City"that assures the initiation and completion of the project's mixed-use
3 components are consistent with the expectations of the phasing plan." City's Motion, pg. 2.
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Similar to the financial security concept, this is not a viable option. It is completely arbitrary and
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hypothetical, with no guarantee that the City would accept reasonable assurances.
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7 II. Conclusion
8 Condition#18, as proposed by the City, is unnecessary, infeasible, and exceeds the City's
9 authority under state law.
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Quadrant has proposed an alternative condition that would require a building permit to be
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issued, and all impact fees to be paid, for the mixed-use building before townhome construction
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t3 could begin:
14 [Proposed] Condition 18. The applicant shall follow the Phasing Plan as provided in
Exhibit 12 in order of phasing such that the first townhome phase shall not begin building
15 construction until the building permit for one of the two mixed use buildings has been
16 paid for by the developer and issued by the City. Further, the second townhome phase
may not begin building construction until the building permit for the second mixed-use
17 building has been paid for by the developer and issued by the City. Certificates of
occupancy for the second townhome phase will not be issued until the podium and
18 framing for the first mixed use building have passed inspection.
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Such a condition would provide the assurances the City needs without jeopardizing the viability
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of the Project. It would allow Quadrant and its mixed-use development partner to coordinate and
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22 sequence construction in a way that will reduce costs, increase efficiencies, and allow the Project
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24 For the reasons outlined above, Quadrant respectfully requests that the Examiner reject
25 the City's proposed Condition#18 and incorporate Quadrant's proposed Condition#18 to govern
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the phasing requirements of the Project.
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McCullough Hill Leary. PS
701 Fifth Avenue,Suite 6600
QUADRANT'S REPLY TO RESPONSE TO Seattle,Washington 98104
MOTION FOR RECONSIDERATION—6 of 7 206.812.3388
206.812.3389 fax
1 DATED this 18th day of January, 2019.
2 s/Courtney E. Flora, WSBA#29847
3 Attorneys for Quadrant Homes
McCULLOUGH HILL LEARY PS
4 701 Fifth Avenue, Suite 6600
Seattle, WA 98104
5 Tel: 206-812-3388
6 Fax: 206-812-3389
Email: cflora@mhseattle.com
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McCullough Hill Leary. PS
701 Fifth Avenue,Suite 6600
QUADRANT'S REPLY TO RESPONSE TO Seattle,Washington 98104
MOTION FOR RECONSIDERATION-7 of 7 206.812.3388
206.812.3389 fax
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BEFORE THE HEARING EXAMINER
9 FOR THE CITY OF RENTON
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11 In the Matter of: LUA-18-000490, SA-M,PP, CU-H,MOD
12 SOLERA MASTER PLAN, DECLARATION OF BONNIE GEERS
13 A Master Plan, Preliminary Plat, Conditional
14 Use and Street Modification Decision
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16 I, Bonnie Geers,declare:
17 1. I am Senior VP of Community Development for Quadrant Corporation. I am
18 competent to make this declaration based on my professional knowledge.
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2. Quadrant Corporation is the applicant for the"Solera Project,"a phased,mixed-use
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project in the Sunset Highlands area of the City of Renton along NE Sunset Blvd. We understand
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22 and support the City's mixed-use vision for the property, which the City has clearly and
23 consistently communicated to us in the 18-plus months we have been working with them on the
24 project.
25 3. I believe we have established a good, cooperative working relationship with City
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staff, but we have been unable to reach agreement on proposed "Condition 18,"which relates to
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project phasing.
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McCullough dill Leary.PS
701 Fifth Avenue,Suite 6600
DECLARATION OF BONNIE LEERS-1 of 3 Seattle,Washington 98104
206.812.3388
1 4. Condition #18 would prevent Quadrant from initiating construction on the
2 townhome component of the project until the concrete podium for the mixed-use building is
3 completed and passed inspection. Condition #18 will jeopardize the success of this project and
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deter mixed-use developers from participating in it.
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5. The first phase of townhome construction is anticipated to take 12 months,barring
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7 unexpected issues impacting the construction timelines (which can always arise). After the
8 construction of the Phase I infrastructure, Quadrant would be prepared to initiate townhome
9 construction immediately. But under Condition #18, we cannot begin construction until the
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concrete podium for the mixed-use building passes inspection(which is outside our control).
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6. The City is saying this condition is necessary because it will provide the needed
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13 assurances that the mixed-use component of the project will be constructed and not abandoned.
14 From our perspective, this condition is unnecessary, arbitrary, and extraordinarily burdensome.
is This condition will prevent us from coordinating construction sequencing with our mixed-use
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partner, it impairs our ability to control our own construction schedule, and it will delay
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construction of a residential component that will make the mixed-use component more viable.
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19 Ultimately, it will interfere with market conditions, which ultimately dictate the project's success
20 or failure.
21 7. Alternatively, Condition #18 says we can begin construction when shoring walls
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and excavation are completed for the mixed-use building,provided a cash set aside,letter of credit,
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or assignment of funds for the entire cost of the mixed-use building(an estimated$75-$90 million)
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25 is provided. This is not a viable alternative.
26 8. Pete Nichols,Quadrant's VP of Acquisition,and/or I have personally discussed the
27 cash set aside and letter of credit concept with the following potential mixed-use partners: Legacy
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McCullough Hill Leary. PS
701 Fifth Avenue,Suite 6600
DECLARATION OF BONNIE GEERS--2 of 3 Seattle,Washington 98104
206.812.3388
1 Partners, Johnson Development Associates, Lennar, Bridge Housing, and Avalon Bay
2 Communitiespany. This list includes some of the largest, most well-financed developers in our
3 region.Every single one of them said they would be unwilling or unable to provide a cash set aside
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for the mixed-use building while simultaneously proceeding with construction. The City suggests
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6 that such a requirement is "common" and "reasonable." To the contrary, none of the developers
7 listed above had ever heard of a city imposing such a requirement.
8 9. We have tried in good faith to negotiate a phasing condition we can live with that
9 would provide the City the assurances it needs. We have proposed a condition that would prevent
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Quadrant from initiating the first townhome phase until a building permit for the first mixed-use
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building is issued, which would require in excess of$1 million in design costs and fees to be paid
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13 by the developer. Further,we have proposed that the second townhome phase may not begin until
14 the building permit for the second mixed-use building is issued, which would again require in
15 excess of $1 million in costs and fees. Finally, we would agree to a condition providing that
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certificates of occupancy for the second townhome phase cannot be issued until the podium and
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framing for the first mixed-use building have passed inspection. It is difficult to understand how
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19 the City could need a higher level of assurance that its authority to withhold certificates of
20 occupancy for the townhomes if the mixed-use building is not sufficiently complete. From our
21 perspective, attempts to force a higher level of assurance are unnecessary, infeasible and
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extraordinarily burdensome.
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Executed this 18th day of January, 2019, at .Q��'{' u.t1 L''''��
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Bonnie Geers
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McCullough Hill Leary.PS
701 Fifth Avenue,Suite 6600
DECLARATION OF BONNIE GEERS--3 of 3 Seattle,Washington 98104
206.812.3388
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BEFORE THE HEARING EXAMINER
9 FOR THE CITY OF RENTON
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11 In the Matter of: LUA-18-000490, SA-M,PP, CU-H,MOD
12 SOLERA MAS 1ER PLAN, DECLARATION OF KERRY L.
NICHOLSON
13 A Master Plan,Preliminary Plat, Conditional
14 Use and Street Modification Decision
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16 I, Kerry L.Nicholson,declare:
17 1. I am Senior Managing Director for Legacy Partners, a privately-held real estate
18 firm that owns, develops, and manages multi-family communities throughout the United States. I
19 am competent to make this declaration based on
P my professional knowledge.
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2. I have been an active participant in the Pacific Northwest real estate market since
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1978. Prior to joining Legacy Partners in 1999, I financed the commercial real estate industry for
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23 over 20 years,holding various senior management positions with GE Capital Real Estate,Bank of
24 America and Wells Fargo.During this time, I made loan and equity commitments in excess of$2
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billion.
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3. Legacy Partners is based in California, with regional offices in Dallas, Denver,
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Irvine, Seattle,and Orlando. I direct Legacy's activities in the Pacific Northwest.
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McCullough Hill Leary.PS
701 Fifth Avenue,Suite 6600
DECLARATION OF KERRY L.NICHOLSON—1 of 3 xi Seattle,Washington 98104
206.812.3388
1 4. I am familiar with Quadrant Corporation's "Solera Project," a phased, mixed-use
2 project in the Sunset Highlands area of the City of Renton along NE Sunset Blvd. I have had
3 numerous discussions with Bonnie Geers, Quadrant's Sr. VP of Community Development, and
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Pete Nichols, VP of Acquisition, related to partnering with Quadrant to develop the mixed-use
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6 component of Solera.
7 5. It is clear to me that Quadrant is committed to the success of Solera's mixed-use
8 blocks and highly motivated to identify a partner who will develop a high-quality mixed-use
9 project on schedule.
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6. I understand that the City's Hearing Examiner has approved the Solera Project,but
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the City has recommended a condition preventing Quadrant from initiating construction on the
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13 townhome component of the project until the mixed-use building concrete podium is completed
14 and passed inspection. I understand the intent behind this condition, but its application will
15 jeopardize the success of this project. Construction of the podium is a complex and lengthy phase
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of construction, which will likely take 6 — 8 months to complete. And the City's inspection
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timelines are outside Quadrant's control. The mixed-use developer cannot be successful if its
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19 residential partner is prevented from initiating and pursuing construction of the residential
20 component. The mixed-use and residential construction timelines should be coordinated, so that
21 construction costs and impacts can be minimized and efficiencies can be achieved.
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7. Alternatively,the City has offered that in lieu of completing the concrete podium,
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townhome construction can begin when shoring walls and foundation excavation are completed
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25 for the mixed-use building, along with a receipt of a cash set aside, letter of credit,or assignment
26 of funds approved by the city for the entire cost of the mixed-use building.The City has not offered
27 a bonding alternative,which in my experience would be typical and reasonable in this situation.
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McCullough Hill Leary.PS
701 Fifth Avenue,Suite 6600
DECLARATION OF KERRY L.NICHOLSON—2 of 3 Seattle,Washington 98104
206.812.3388
8. The entire cost of the mixed-use building is estimated to be $75 - $90 million
2 dollars. Accordingly, a mixed-use developer would have to obtain and reserve $75 - $90 million
3 dollars to sit in escrow or be held at the City(the mechanics of the City's proposal are not clear).
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At the same time, the mixed-use developer would need to expend significant funds to construct
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6 the building,with this$75-$90 million dollars not available for actual construction efforts.
7 9. It is my opinion that neither the"cash set aside"nor the "letter of credit"concepts
8 are feasible.Based on my experience,I would not expect Legacy Partners or any other mixed-use
9 developer to accept this "alternative" offered by the City. Even the most well-financed (or self-
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financed)developers in the region cannot afford to have$75 -$90 million dollars sitting in reserve
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while expending funds on construction. I would expect developers who are less well-financed
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13 would be unable to obtain such a large letter of credit from a bank.
14 10. It is also my opinion that the security "alternatives" proposed by the City are
is unnecessary. Once a developer has fullydrawnplans, bought land P g , paid fees and initiated
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excavation and shoring activities,all out of equity,it would be ruinous not to complete the project.
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In other words, construction of the mixed-use building would be assured.
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19 11. In my 40 years of experience in the real estate industry in the Pacific Northwest, I
20 have had direct involvement with hundreds of mixed-use projects in various jurisdictions.It is my
21 opinion that the phasing condition proposed by City in this case is highly unusual and infeasible,
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and it will deter potential mixed-use developers from partnering on this project.
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Executed this 18th day of January,2019,at i4D via 1 N 6 ti i ft"=.w.,;
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Kerry L.Nicholson
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McCullough Hill Leary.PS
701 Fifth Avenue,Suite 6600
DECLARATION OF FERRY L.NICHOLSON—3 of 3 Seattle,Washington 98104
206.812.3388
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8 BEFORE THE HEARING EXAMINER
9 FOR THE CITY OF RENTON
l0 In the Matter of: LUA-18-000490, SA-M, PP, CU-H, MOD
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SOLERA MASTER PLAN,
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A Master Plan, Preliminary Plat, Conditional Use DECLARATION OF SERVICE
1' and Street Modification Decision
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17 I, Lauren A. Verbanik, declare as follows:
18 I am employed with McCullough Hill Leary, P.S., which represents The Quadrant
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Corporation, applicant. I electronically filed with the Hearing Examiner for the City of Renton
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and served a copy of QUADRANT CORPORATION'S REPLY TO THE CITY'S RESPONSE
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22 TO MOTION FOR RECONSIDERATION, DECLARATION OF KERRY L.NICHOLSON,
23 DECLARATION OF BONNIE GEERS, and this DECLARATION OF SERVICE via electronic
24 mail on the following parties:
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Cynthia Moya Phil Olbrechts
26 Renton City Clerk's Office Hearing Examiner for the City of Renton
Email: cmoya@rentonwa.gov Email: olbrechtslaw@gmail.com
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DECLARATION OF SERVICE McCullough Hill Leary. PS
-Page 1 of 2 701 Fifth Avenue,Suite 6600
Seattle,Washington 98104
206.812.3388
206.812.3389 fax
1 Matt Herrera,AICP
Senior Planner
2 City of Renton
3 Email: mherrera@rentonwa.gov
4 I declare under penalty of perjury under the laws of the State of Washington that the
5 foregoing is true and correct to the best of my knowledge and belief.
6 DATED this 18th day of January, 2019.
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s/Lauren A. Verbanik
9 Lauren A. Verbanik
10 Paralegal
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DECLARATION OF SERVICE McCullough Hill Leary. PS
-Page 2 of 2 701 Fifth Avenue,Suite 6600
Seattle,Washington 98104
206.812.3388
206.812.3389 fax