Comment (2017-07-26) for Landmarks Preservation Board

To: Seattle Landmarks Preservation Board
From: Protect Volunteer Park Steering Committee
Subject: Asian Art Museum Renovation and Expansion
Date: July 26, 2017

As the steering committee of Protect Volunteer Park, a growing organization of over 1200 petitioners, we offer this comment to the Landmarks Preservation Board regarding the application for a Certificate of Approval to renovate and expand the Asian Art Museum building.

This comment is a comprehensive summary of the key points that we have been making in verbal and written comments, with new material included as well. Certain topics need additional detail, so we are simultaneously submitting three additional articles, which are listed at the end.

We ask the Board to deny the request for a Certificate of Approval (CoA) for the additions as designed. We discuss below a number of aspects in which the proposed additions do not comply with the Secretary of Interior’s Guidelines for Rehabilitating Cultural Landscapes or with the Standards for Rehabilitation codified as 36 CFR 67.7.

Significance of Volunteer Park

Volunteer Park is listed with National significance, the highest level, in the National Register of Historic Places. The first paragraph of Volunteer Park’s 1976 federal nomination form discusses the urban growth pressures which are not new to Volunteer Park:

“Owing to its central location in the urban setting, its various recreational facilities and visitation generated by the Seattle Art Museum, the park is subject to exceptional visitor-use pressure. Recommendations set forth in a recent Master Plan Report on Volunteer Park indicate that maintenance and future development are planned to deflect excessive automobile traffic and protect the park’s historic landscape characteristics.”

The Olmsted brothers predicted these urban pressures even in the 1930’s, and chose to design Volunteer Park as a landscape park in order to offer a respite from urban life. The park’s 2011 City of Seattle landmark nomination discusses the naturalistic intentions of the Olmsted design:

“Olmsted and other urban reformers of the 1850s viewed parks as places in which the oppressive and unhealthy stresses of urban environments could be mitigated through passive recreation and the beneficial psychological effects of viewing naturalistic landscape scenery.”

Today we have new stresses to mitigate, such as climate change and its potential consequences such as coastal flooding. It is undeniable that the construction of facilities on existing parkland carries a substantial adverse climate impact, especially when alternative space downtown is already built and publicly subsidized for museum use (but more on that later). Were the Olmsteds here today, we think they might agree that beyond the psychological benefits, protecting natural areas has become important for our mere survival.

Alterations to a Cultural Landscape

“When alterations to a cultural landscape are needed to assure its continued use, it is most important that such alterations do not radically change, obscure, or destroy character-defining spatial organization and land patterns or features and materials.”
Secretary of Interior Standards for Rehabilitating Cultural Landscapes

Placing a new structure, furnishing, or object where it may cause damage, or is incompatible with the historic character of the landscape. For example, constructing a new maintenance facility in a primary space.” …
Secretary of Interior Standards for Rehabilitating Cultural Landscapes

Firstly, no one should claim that the museum expansion is necessary to assure the “continued use” of Volunteer Park. Indeed, Volunteer Park has been thriving in the 5 months since the Asian Art Museum closure in February. All areas of the park are well used, including the east greensward. The parking occupancy within Volunteer Park has regularly been over 80% on weekends (which we discuss in more detail below). The building’s external architectural appearance continues to function unchanged for the appreciation of park users.

Rather, Volunteer Park, a landmark of national significance, is proposed to be altered in order to ensure the continued use of a different landmark of local significance, the museum building. Below we also discuss whether this is truly necessary and whether the continued use will even be assured by this alteration.

In general the greensward is a character-defining feature of Volunteer Park. This particular east greensward, which extends the full length of the park from north to south, is a full-fledged instance of that character-defining feature, and without doubt a primary space.

The park contains a central plaza, but the Olmsteds’ naturalistic design philosophy clearly does not relegate other sectors to a back-door secondary status. Rather, it would be appropriate to consider the greenswards as being more important than the central plaza.

The proposed east addition projects 40′ into a greensward area which is relatively narrow in the east/west direction, creating a pinch point which interrupts long-distance views along the N/S and NNW/SSE axes, which otherwise would reveal the full extent of the park. The earlier addition already bisects the greensward and this new East Addition would further extend that bisection, an unnatural barricade to Olmsted’s carefully orchestrated landscape flow. In addition, opportunities to enjoy privacy and peaceful contemplation would be destroyed by the looming Park Lobby where users of an indoor facility have a commanding view over people using the park. This impairs the use of the park as Olmsted intended – for intimate socialization, passive recreation and rejuvenation of body and spirit.

Long shadows would extend across most of the remaining lawn east of the museum, and the addition’s huge overhangs cast permanent gloom to the north, creating  a haven for illicit activity. That area would be transformed to unusable open space in addition to land taken for the enlarged museum footprint.

Simply said, this very assertive museum alteration is incompatible with the historic character of the landscape.

The restoration of original Olmsted paths has been offered as potential mitigation to the damage done to the function and naturalistic feel of the greensward. However, mitigation must be proportional to damage done to the resource. The value of pathway improvements does not seem commensurate with the harm.

(Update 2017-07-27: we are simultaneously submitting a letter from heritage landscape management expert Eliza Davidson which more thoroughly discusses the landscape preservation issues.)

Massing, Size, Scale, and Architectural Features

Although our comments primarily discuss park impacts, we would like to mention some issues about the building and the Standards for Rehabilitation section 36 CFR 67.7 (b)(9), which requires new work to be “compatible with the massing, size, scale, and architectural features” of the original.

The museum today is over 50% larger than when it was built in 1933. With proposed additions, it would be 82% larger, which is approaching a doubling of the original size.

The proposed East Addition is just under 50′ high, the equivalent of a 4 story office building. It extends an asymmetrically placed mass attached to what was originally a symmetrical building. The east face of the addition would become the tallest face of the building as measured from ground level, and also the most visually imposing on people in the park, given its protrusion into and dominance over the downward-sloping greensward to the east. The addition would cast a surprising amount of shade into the park in the afternoons, because of its location above the slope and to its west.

The proposed Park Lobby is particularly incompatible with the existing architecture of both the building and park. Having no relationship with the architectural features of the original, it would overhang three of the original central windows and cast them into deep shadow.

Trees #27 and #46

Two exceptional beech trees would be adversely impacted, both in themselves and in their relationship with the greensward. Referring to the project’s Arborist Report, he European Beech (tree #27) east of the museum, the largest of its kind in Volunteer Park, would essentially be subtracted from the greensward as seen from the south, and completely shaded in winter. The building footprint would become an almost square rectangle, minus a rectangular notch containing the European Beech, which would become enclosed by the building to almost 180 degrees as seen from its trunk. The overhang of the Park Lobby avoids ground disturbance within the narrowly defined critical root zone of this tree, but would completely eliminate rainfall over part of that same critical root zone.

The Copper Beech (tree #46) is the largest in Seattle, designated as Seattle Heritage Tree TRE-100959. This tree is strikingly close to the proposed north addition and temporary construction road. Seattle’s Department of Construction and Inspections (SDCI) requires protection to the drip line for exceptional trees. Based on discussion with arborists, we understand that drip line-defined root zone protection is nowhere near adequate to protect the mature beeches, which are extremely sensitive to disturbance and compaction. Arboricultural Best Management Practices require approximately double that diameter. SDCI’s requirements are widely criticized as woefully inadequate.

The arborist report consists solely of a tree inventory. We find that very surprising. A project of this nature, in this sensitive area surrounded by exceptional trees, would be expected to have an arborist report that makes clear recommendations for tree protection. This relates to the “may cause damage” clause in the cultural landscape standards. The applicant has not taken sufficient measures to ensure the avoidance of damage to these exceptional and well-loved trees.

Alternative Designs to Expand the Building

The expansion proposal has not fully utilized areas available south of the museum. The south side is unattractive and there is space into which an addition could be built. There is also never-excavated space within the building footprint and underneath the west terrace.

These possibilities have been dismissed by the applicant, but not with good justification. We are submitting concurrently an article by structural engineer Ron Taylor which discusses alternative possibilities in more detail.

Alternative Expansion Area Downtown

The alternative of SAM expanding downtown has been too casually dismissed. The downtown location is well suited to hosting traveling art exhibits without creating adverse impacts on Volunteer Park.

SAM’s downtown building was designed to include 8 floors of future expansion space for SAM. The total area of the expansion space is 232,000 square feet, according to the SAM Press Kit. At 29,000 square feet per floor, each floor has over twice the area of the 12,500 square foot expansion proposed in Volunteer Park. The building is owned by SAM but subsidized by a City guarantee of repayment of $45.3 million in bonds, as of 2014 when it was refinanced (as reported by Bloomberg).

The expansion space is leased until 2031, but SAM’s tenant Nordstrom, Inc., has already vacated the 13th floor and is seeking to move out of two other floors, marketing the three floors for sublease, according to a February report in Puget Sound Business Journal. It seems likely that the floors could be used by SAM under reasonable terms.

According to a recent SAM mailing, two galleries at SAM’s downtown location are currently dedicated to showcasing Asian art, with new artworks installed regularly. During the closure of Asian Art Museum which began on February 27, 2017, the museum’s educational programs continue at different locations around the community. Clearly the flexibility exists to site new capabilities elsewhere than Volunteer Park.

New Additions Should Be Avoided If Possible

“The installation of additions to a cultural landscape may seem to be essential for the new use, but it is emphasized in the Rehabilitation guidelines that such new additions should be avoided, if possible, and considered only after it is determined that those needs cannot be met by altering secondary, i.e., non character-defining, spatial organization and land patterns or features.”
Secretary of Interior Standards for Rehabilitating Cultural Landscapes

 In discussion, one Board member has said that an important outcome for the Board is to keep buildings occupied. SAM officials have stated that the proposed expansion is necessary for SAM to continue operating in the building. But it is important to note that SAM is not uniquely qualified to occupy this historic Carl Gould building in Volunteer Park. SAM pays the City of Seattle no monetary compensation to occupy the building, and additionally the City pays for SAM’s utilities and custodial expenses, and provides free parking in Volunteer Park, amounting to a large subsidy in total. Seattle has many other wonderful arts, cultural, and recreational institutions who would likely be thrilled to occupy this building if we extended to them the same subsidies we currently give SAAM (and there is no reason why we couldn’t do that). An institution originating from Seattle’s Asian American / Pacific Islander community could be chosen if the City wished to maintain that cultural focus.

SAM officials sometimes claim that SAM has a special entitlement to the Asian Art Museum building because the building was donated by SAM to the City. This is unreasonable. The donation of the building was 83 years ago. City property cannot be managed out of an attempt to repay the philanthropy of rich people generations ago, but must be managed in the public interest.

In a letter to the Board, SAM CEO Rorschach stated (p. 5) that the 1933 agreement enacted in Ordinance #61998 requires that the building be used for public museum purposes. We see no basis for that reading of the agreement. Clause 2 does state that the building shall be constructed solely as a museum, but does not condition its future use. Rather, the agreement is clear that SAM has no “right, title, property, or interest” in the building, except as provided by the agreement which either side can terminate with three years notice.

SAM’s financial situation is relevant here. SAM originally agreed to renovate the Gould building (without expansion) as part of a voter-approved renovation project in connection with the 2008 Parks and Open Spaces levy. SAM then became unable to finance its share of the project because of financial difficulties. SAM remains financially compromised, unable to use its intended downtown expansion space because the lease revenue is needed, according to SAM officials. It is not certain that SAM will be able to finance its share of this proposed larger project. Also, SAM CEO Kimerly Rorschach has stated, in a letter to the Board, that this expansion project will increase SAM’s operating expenses more than revenue, creating a $180,000 to $280,000 per year budget deficit which SAM will need to finance from other sources. Therefore it is also not certain that the operating obligations of this larger museum will be sustainable for SAM. It would be wrong to compromise the Secretary of the Interior standards, and permanently degrade Volunteer Park, because of a misperceived necessity to maintain SAM’s current use of the building.

The factors that do threaten the continued use of the building are its lack of seismic safety and ADA access. We are disappointed that instead of addressing these issues with a project scoped as agreed in the 2008 levy, SAM has chosen to combine this necessary work with expansion work which is financially ambitious and at minimum requires a much longer design and approval process (and which we believe should not be approved), because of its adverse impacts on the surrounding landmark, as well as its violations of existing land use code. A better scope of rehabilitation would be to fix just the seismic and ADA issues, ensuring that the building will continue to offer life safety while the other issues get worked out.

Insufficient Parking for New Museum Uses in Volunteer Park

We understand that the Board does not normally consider traffic and parking. We submit that this is an unusual situation where one landmark is physically contained within another, with the inner landmark’s vehicle access and off-street parking entirely located on the outer landmark (and that being of higher, national, significance). We believe the Board should evaluate and avoid or mitigate any adverse impact to the demand for parking on this landmarked site.

As we mentioned above, Volunteer Park has been thriving and well-used since the museum closure in February. We have studied the parking occupancy with the museum closed, and found it regularly exceeds 80% on weekend afternoons in the warmer season since mid-May. This suggests that a reopening of the museum at its present size will routinely exceed Volunteer Park’s parking capacity. Any additional demand created by new museum uses will increase the parking overload. But the museum plans for its new uses to increase annual visitorship by 54%.

To provide more detail, we are simultaneously submitting two additional articles regarding the parking situation:

  • Our Parking Study: An informal study consisting of 14 measurements of parking availability within Volunteer Park.
  • Parking Impact of Museum Expansion: Discussion of the results of our study, the implications for museum expansion, and our disagreements with the traffic study submitted by the applicant.

We hope the Board will take this matter seriously. In addition to the feature of parking availability, excess traffic and parking within a landmark can adversely impact the landmark’s intended function & user experience, through vehicle noise and emissions, increased vehicle-pedestrian conflicts, and disrupted pedestrian circulation within the park. But the landmark status can be used to bypass the normal parking requirements of city land use code.


No museum or other public building was ever intended to go in this landscape park, much less its very heart. Although 85 years have passed since the museum’s construction, and additions have already increased its area by over 50%, neither justifies further damage to this valuable historic landscape. Landmark damage is the litmus by which the SAAM expansion project must be tested.

The question to consider is not just one of square feet taken, but of lost landscape feeling, function, extent and continuity. Project proponents choose to ignore these significant, irreversible adverse impacts to these contributing, character defining features as if they understood nothing of aesthetics. It is in your power to make this project better or make it go away. We urge you to rise to this challenge, shoulder your responsibility and do your impartial best to protect Volunteer Park from short sighted proposed development. What you decide will affect generations, of plants, animals and human beings.

With appreciation for the dedicated volunteer work of the Board,


Protect Volunteer Park Steering Committee

Supporting Comments Being Submitted Simultaneously:


This article was written by Jonathan Mark and the Protect Volunteer Park steering committee. If you have comments, please email: .