Tideflats Public Comment Letter

6/6/2025

June 6, 2025

City of Tacoma
Planning Commission
747 Market Street, Room 345
Tacoma, WA 98402

Dear Commissioners,

The Tideflats Subarea Plan and associated code amendments are a significant step toward achieving economic development objectives that will support existing businesses and key economic and environmental priorities. We recognize the tremendous amount of work the City of Tacoma and its partners: Puyallup Tribe of Indians, Port of Tacoma, Pierce County and City of Fife, have done over the past seven years. This plan goes a long way towards protecting and growing the Tideflats Manufacturing Industrial Center’s nearly $14 Billion in economic activity and associated employment.

The jobs in the Tacoma Tideflats are among the highest wage and the lowest barrier jobs in our region. The wages within the Manufacturing Industrial Center are consistently 30% higher than in surrounding areas of Tacoma and Pierce County. We encourage the Planning Commission to recognize the significance of the unanimous vote to adopt the proposed Subarea Plan from the Steering Committee.

The Manufacturing Industrial Council and the undersigned members and affiliated partners are supportive of the Steering Committee’s recommendation to adopt the Subarea Plan and implement code amendments. The plan generally supports the priorities and conclusions developed by planning department staff and supported by the Steering Committee and the Technical Advisory Group.

We recognize that not all goals and priorities can be achieved through the Subarea Plan document. We will focus our comments on the code amendments and a call for the development and implementation of an economic development strategy that will move our city and region toward a more sustainable, dynamic, and prosperous future for all.

We encourage the Planning Commission to direct staff and the City of Tacoma to develop additional clarifying language that would further codify commitments to existing business and create better alignment in support of cleaner fuels and energy transition.

Throughout the planning process, the Steering Committee and the Technical Advisory Group expressed a clear commitment to supporting established businesses’ ability to scale, modernize, and adapt to changing markets. The established businesses support a wide range of economic opportunities in our region, supporting trade and Port operations, Tacoma’s Green Economy Strategy, circular economy, manufacturing, boatbuilding, aerospace, agriculture, and Joint Base Lewis-McChord. The support for established businesses should be represented in the language of the code not just the use tables and footnotes. The code language should solidify support for these key pillars of our region’s economic prosperity. It is our recommendation that these amendments be developed in consultation with industry and subject matter experts.

We applaud the strong commitment to cleaner fuels in both the Subarea Plan and the code amendments. The Subarea Plan lays out specific policy objectives that express the City’s commitment to encourage and partner on the development of the green economy and the reduction of regulatory burdens. However, these commitments are contravened by the proposal to change cleaner fuel projects from permitted use to a use requiring a conditional use permit. This change adds an additional process for these projects not required in the prior version of the code. The robust regulatory environment, large levels of capital required, lack of incentives, and long project horizons make cleaner fuel projects vulnerable to the unintended consequence of additional and often duplicate processes.

The non-interim regulations on both traditional and cleaner fuels established and codified during the subarea planning process were negotiated and adopted in good faith by industry and community partners represented on the Steering Committee and the Technical Advisory Group. This process was conducted with transparency and with opportunity for community input and engagement. It is our position that there is clear intent and clear language in the Subarea Plan to limit regulation above and beyond the non-interim regulation process as reflected in the exiting code. The shift to conditional use runs contrary to this intent. We again are advocating for additional clarifying language developed in partnership with industry and subject matter experts to increase policy alignment.

If Tacoma is going to meet the existing and future needs of our city and region, we will need a clear economic development strategy that supports and incentivizes cleaner fuels and energy transition. The first step to that end is to not introduce new code that creates unnecessary, uncertain, and burdensome conditions that would disincentivize investment in cleaner fuels and energy transition.

It is our hope that the planning commission will honor the years of effort and the unanimous recommendation for adoption of the Tideflats Subarea Plan by the City of Tacoma, Puyallup Tribe of Indians, Port of Tacoma, Pierce County and City of Fife. It is also our hope that the proposed code will be clarified and aligned with the plan to maximize the economic and environmental opportunities made possible through this historic effort.

Sincerely,